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Privacy Policy


Privacy Policy


You or your, refers to the individual whose personal information is being collected, shared and or processed. 


This Privacy Policy sets out how and why the COEN COLEMAN LTD and COE Group Ltd. collects and processes your personal data through your use of this website and/or when we provide our services as a real estate business. 


Please read this Privacy Policy carefully as it contains important information about how we protect your personal data, in accordance with applicable data protection laws. It sets out the circumstances in which we may disclose your personal data to others and the rights you have regarding our use of your personal data.

You have the right to object to us processing your personal data. This is discussed in further detail in the section Your legal rights in relation to your personal data.


Who we are

West Bay 1 West Bay 2, Grand Cayman Beach Resort, Boggy Sands Club, The Ironshore Club, Sky Lofts and other real estate developments brought to the Cayman Islands are designed by the COE Group Ltd.


Coen COLEMAN LTD & COE Group Ltd is located at Alissta Towers 400, The Loft, 85 North Sound Road, George Town, Grand Cayman, Cayman Islands. 


To arrange sharing property information, property sales and purchases, we and other real estate brokers are required to collect, use and share personal data.


Who is responsible for your personal data?


Where you made a direct inquiry for a development investment:

COE Group Ltd. which originally collected information from you (and where applicable, an intermediary from whom you may use to represent you in a real estate transaction) will primarily be responsible for processing your personal data in accordance with applicable data protection laws.

COE Group Ltd is responsible for any personal data collected from you when using our websites.


Where another real estate agent/broker requested information for your benefit:

Where another real estate agent/broker requested property information from the COE Group Ltd. for your benefit, you should contact your real estate broker or agent if you have any questions about your personal data and they should provide you with details of the property development or the intermediary that they passed your personal data to.


Collection of personal data

The types of personal data we collect will depend on the nature of the relationship you have with us.

We may collect and process different kinds of personal data about you, which we have grouped together below.

  • Individual Data includes first name, maiden name, last name, address and other contact details including email and telephone numbers, marital status, title, date of birth, gender, nationality, employer, job title, employment history and family details;

  • Identification Data identification numbers issued by government bodies or agencies, including passport number and driving licence number;

  • Financial Data includes bank account, payment card details, income or other financial information;

  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us;

  • Credit and anti-fraud data includes credit history, credit score, sanctions and criminal offences, and information received from any anti-fraud databases relating to you;

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;

  • Usage Data includes information about how you use our website, products and services.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested or object to the processing of that data, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with real estate services). In this case, we may have to cancel a service/transaction you have with us but we will notify you if this is the case at the time.

Where you provide us with information about someone else, you must ensure and we will assume that you have their permission. We will process their personal data in accordance with our Privacy Policy so please encourage them to read it.


Where we might collect your personal data from

We may collect your personal data directly from you through different sources, (depending on the nature of the relationship you have with us) which may include:

  • You - such as when you submit an information inquiry request through our website, social media platforms (such as, but not exclusive to Facebook) or through phone calls and or emails and apply for our services; contact us in respect of your real estate needs (including when you provide us with information for a real estate transaction).

  • You, your family members, employer or representative for due diligence to facilitate a real estate transaction;

  • Anti-fraud databases, sanctions lists, court judgements and other applicable databases;

  • Government agencies;

  • Other publicly available sources and material.

How we use and process personal data

We use your personal data for the provision and administration of sharing property development and real estate opportunities with you and the related services we provide. We set out below the purposes for which we may process your personal data.  We must have a lawful basis to process your personal data.


Legitimate Interests

In all cases, where we have relied on our legitimate interests to process your personal data, we have balanced those interests against your rights as an individual and make sure we only use personal data in a way that you would reasonably expect in accordance with this Privacy Policy.



In some circumstances, applicable data protection laws may require us to obtain your consent to the processing of your personal data and special category data. Where this is the case, we will ask you for consent in accordance with those laws. You may withdraw your consent at any time (see the section below Contact Us). This will not affect the lawfulness of any processing based on consent before its withdrawal. However, if consent is withdrawn we may no longer be able to administer existing insurance policies or pay insurance claims.


Direct Marketing

We may contact you about the services and products we think may be of interest to you, by post, telephone or e-mail. We do so on the basis of our legitimate interests. You may opt-out of marketing at any time by getting in touch through the Contact Us section.

We will not sell your data to third parties for them to market to you.


Disclosure of personal data

We consider your personal data to be private and confidential. We may sometimes disclose your personal data to third parties under the following circumstances:

  • Coe Group Ltd. companies. We operate as a parent company to multiple subsidiaries in the real estate industry, so we may share your personal data with our group of companies who may use this data for the purposes described in this Privacy Policy.

  • Financial institutions and business partners that use your personal data in the connection with the provision of insurance services or products and the processing of claims.

  • Service providers, contractors or agents appointed by us. We may share personal data with service providers or agents that perform services and other business operations for us, for example, IT and analytics providers, medical specialists and hospitals, actuarial service entities, auditors and advisers.

  • Any law enforcement agency, court, regulator, government authority or professional body. We may share your personal data with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the property of the COE Group Ltd., including, without limitation the security and integrity of our network, or the rights of any third party.

  • Purchasers (potential and actual). We may share your personal data with any third party that purchases, or to which we transfer, all or substantially all of our assets and business or with whom a restructuring transaction is contemplated. In such circumstances, we will use our reasonable efforts to try and ensure that the entity receiving the personal data uses it in a way consistent with this Privacy Policy.


Retention of your personal data

We will hold on to your personal data in accordance with our data retention policy and only for as long as is necessary in relation to the purposes for which it was collected and processed.

We also hold on to your personal data for as long as is necessary to allow either you or us to commence or defend legal claims in relation to the insurance and/or for as long as where we are required to do so to comply with any applicable legal and/or regulatory requirement.

It is not possible to guarantee complete information security, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the internet. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the website.

We will continue to test, assess and evaluate the effectiveness of our technical and organisational measures.

In the event of a personal data breach, we act in accordance with all applicable data protection laws.


Software Quality

We do not warrant that any information, software or other material accessible through this site is free of viruses, worms, Trojan horses or other harmful component. The COE Group Ltd. assumes no responsibility and shall not be liable for any direct, indirect, incidental or consequential damages that result from the use, access to, browsing in or downloading of any information, data, text, images or other material accessible through one of its web pages, this site or the website of any linked third party.



"Cookies" are small text files stored on your computer by websites that you visit. They are used by most websites in order to make them work efficiently, make controls respond properly and to provide information to the owners of websites. The cookies stored by our site cannot be used to identify you personally, as no personal data is stored in them.

Our cookies can store information about you, including IP addresses, navigational data, server information, data transfer times, your preferences, and passwords needed to access the special areas on our site.

We use cookies for the following purposes:

  • as part of the basic functioning of our website;

  • to analyse traffic on our site and measure the performance of it; and

  • for enhanced personalization and functionality, such as storing and retrieving session information in our inquiry form and Contact us forms.


Disabling Cookies

Most browsers automatically accept cookies. You should have the ability to disable cookies or request that you be warned when a website is trying to install a cookie. This can usually be done by modifying the settings in your browser. If you want to know more on how to disable the use of cookies on your device, visit

Please note that disabling cookies may affect the functionality of some parts of our websites.

Your legal rights in relation to your personal data

If you have any questions in relation to the use of your personal data, or would like to exercise any of the following rights, you should contact us by the means set out under the Contact Us section.

Under certain conditions you may have the right to require us to:

  • provide you with access to the personal data you have provided to us;

  • correct and update any inaccuracies in the personal data we process;

  • delete or remove any special category or personal data that we no longer have a lawful basis to process it. Note that we may not always be able to comply with your request of deletion for specific legal reasons which will be notified to you, if applicable, at the time of your request;

  • stop a particular type of processing, where processing of your personal data by us is based on consent alone. We may not, as a consequence, be able to provide certain services, administer requests and support real estate transactions;

  • stop processing your personal data, where we are relying on the legitimate interests grounds, unless our reasons for performing that processing outweigh any prejudice to your personal data protection rights;

  • provide your personal data in a usable electronic format so it may be transferred to a third party (where technically feasible) and, where the data is automated and which you initially provided consent for us to use or where we used the information to perform a contract with you;

  • restrict how we use your personal data whilst a complaint that has been submitted us being investigated;


There may be other circumstances in which your rights may be restricted in order to safeguard public interest or to preserve the establishment, exercise or defence of legal claims.

Contact Us



If you have any questions about this Privacy Policy or would like to exercise any of the rights listed in Your legal rights in relation to your personal data please contact our Data Protection Officer by the following means:

Post: COE Group Ltd, P.O. Box 30121, KY1-1201 George Town, Grand Cayman, Cayman Islands

Email at:




If you have any concerns or complaints about how we have handled your personal data, please contact us on the details above.

You also have the right to complain to your local supervisory authority i.e. the supervisory jurisdiction where you live or work or the supervisory authority of the jurisdiction where you believe that an infringement of data protection laws has occurred.


Changes to this Privacy Policy

We may change this Privacy Policy from time to time. When we do, we will also revise the 'last updated' date at the bottom of the Privacy Policy. A copy of this Privacy Policy will be maintained on  We encourage you to periodically review this Privacy Policy to stay informed about how we are helping to protect the personal data we collect.

Last updated: 24 November 2021

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