Types of Personal Data We Collect
Methods of Personal Data Collection
How we use Personal Data
Sharing and Disclosure of Personal Data
Your Options for Managing Our Use and Disclosure of Your Personal Data
Other Important Information
Contacting Us

Aman Group, which includes Aman Group S.a.r.l as well as its affiliates/subsidiaries (i.e., all companies whose shares are held or beneficially owned, in whole or in part, whether directly or indirectly, by Moto Investco Limited) (hereafter collectively, the “Aman Group”, “we”, or “us”), values you and recognizes that privacy is important to you. We want you to be familiar with how we collect, use and disclose your Personal Data.

This Privacy Notice describes the privacy practices of the Aman Group for Personal Data that we collect in connection to our website (the “Website”), including through the newsletter sign-up and residence enquiry forms pertaining to:

• https://www.atma.com
• https://www.atma.com/miami

When we request your consent for specific data processing activities, we refer either to this Privacy Notice or to separate notices for these activities, providing tailored information to help you understand how your data is used in different contexts.
Collectively, we refer to the Website and our Social Media Pages, as the “Online Services” and, together with offline business interactions, the “Services.”

TYPES OF PERSONAL DATA WE COLLECT
“Personal Data” are data that identify you as an individual or relate to an identifiable individual. We collect the following Personal Data:

• Your identifying and contact information (e.g., first name, last name, email address and telephone number);
• Your country of residence;
• Information relating to your residence enquiry (e.g., the residence project you are interested in, how you heard about us, and any follow-up communications about your enquiry);
• Your newsletter subscription details (e.g., email address, subscription status and marketing preferences);
• Your interactions with our marketing emails (e.g., email opens and clicks); [Note: confirm whether Braze open/click tracking will be enabled.]
• Your IP address (we may also derive your approximate location from your IP address) and system data when you use your devices to access the Online Services, we collect certain data through your browser or automatically through your device, such as your computer type, screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version.

When you use the Online Services, we also collect data typically collected through websites, such as browser and device information, website usage data, information collected through cookies, pixel tags and other similar technologies, and IP addresses. For more detail please see our Cookie Policy.

METHODS OF PERSONAL DATA COLLECTION
We and our service providers collect Personal Data in a variety of ways, including:

• Online Services: Personal Data collected through browsing the Website, residence enquiry forms and newsletter sign-ups.
• Communications with us: Personal Data collected through email and telephone communications regarding residence enquiries and newsletter subscriptions
• Aman Group Companies: Personal Data collected from other Aman Group companies for communications and business operations relating to ATMA.
• Aman Partners: Personal Data collected from service providers acting on our behalf, such as residence sales lead management and advertising agencies.
• Other Sources: Personal Data collected from social media and advertising platforms about your interactions with our advertisements and Social Media Pages.

HOW WE USE PERSONAL DATA
We and our service providers use Personal Data for the following purposes:

• Processing residence enquiries: Handling residence enquiries, providing residence information, arranging follow-up communications and managing sales leads. (Pre-contractual steps, legitimate interests)
• Marketing and communications: Sending newsletters and marketing emails, and managing subscriptions. (Consent, legitimate interests)
• Responding to public authorities: Providing information to law enforcement and authorities for security and legal requirements. (Legal compliance)
• Protecting rights and interests: Safeguarding individuals in case of vital interests. (Vital interests)
• Business operations: Website security, fraud prevention, audits, data analysis, website and communications improvements, campaign effectiveness, investigation of complaints. (Legal compliance, legitimate interests)
• Analytics and advertising: Analysing website use and measuring social media advertising performance. (Consent, legitimate interests)
• Anonymising personal data: Removing identifiable data to create anonymised datasets for various purposes. (Legitimate interests)

SHARING AND DISCLOSURE OF PERSONAL DATA
We disclose Personal Data to:

• Third-party sales team. We may share your name, contact details, residence preferences and information relating to your enquiry about an ATMA residences project with third-party licensed real estate brokers and agents, including Aman Property Corp. and Fortune Development, who assist with the marketing and sale of residences at the relevant project. These agents may contact you directly to respond to your enquiry, provide project information, arrange appointments and assist with a potential purchase, subject to your communication preferences and any consent required by applicable law. We require brokers receiving this information from us to protect its confidentiality and security, honour applicable marketing preferences and opt-out requests, and limit its use to activities relating to that project and applicable legal or professional obligations. Your enquiry does not authorise a receiving broker to use your information for unrelated marketing or to transfer it to others for that purpose.
• Aman Group affiliates (list here) for the purposes described in this Privacy Notice, such as communication and business operations.
• Developers of ATMA residences projects (e.g., OKO Group and Oak Row Equities), who receive residence enquiry data to manage residence enquiries and may use it for their own purposes as independent controllers.
• Digital service providers who support our operation, such as marketing platforms, data routing, residence enquiry hosting, consent management, website hosting, data analysis, information technology and security.
• Advertising partners to facilitate marketing communications, promotions, and advertisements in alignment with your preferences.

Other Uses and Disclosure
We may use and disclose your Personal Data when necessary or appropriate, including with your consent or when legally necessary:

• To comply with applicable law and regulations which may include jurisdictions outside your country of residence.
• To cooperate with law enforcement, public and government authorities to fulfil legal or security related requests, including foreign authorities.
• For other legal enforcement reasons, such as protecting our terms and conditions, individual rights, safety, or property, as well as those of affiliates, users, or others.
• Business transactions, including reorganisations, mergers, sales, joint ventures, assignments, transfers, or other asset-related dispositions (including those linked to bankruptcy proceedings).

Your Personal Data and Social Media:
By using the Services, you may disclose Personal Data:

• On social media platforms, chat services, or other interactive channels (including our Social Media Pages). Please note that any information shared on these platforms may become public.

Important Information

We collect Personal Data to provide the Services to you. If you do not provide the information requested, we may not be able to provide certain Services. If you disclose any Personal Data relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.

This Privacy Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.
We use third-party advertising platforms (such as Instagram, Facebook, TikTok, YouTube and LinkedIn) to display online advertisements regarding ATMA that may be of interest to you when you access and use the Services and other websites or online services. For more information on how these platforms serve advertisements please see our Cookie Policy.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organisations, such as Meta, Google, TikTok, LinkedIn, Apple, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Data you disclose to other organisations through or in connection with our Social Media Pages.

You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognise a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognise you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Notice, please visit http://optout.aboutads.info and http://networkadvertising.org/managing/opt_out.asp.

YOUR OPTIONS FOR MANAGING OUR USE AND DISCLOSURE OF YOUR PERSONAL DATA
You have control over how we use and share your Personal Data for marketing purposes. You may opt out from:

• Receiving marketing-related emails. To stop receiving these emails, you can either email dataprotection@aman.com or use the unsubscribe link at the bottom of each marketing email.
• Residence enquiry follow-up. If you no longer wish to be contacted about your residence enquiry, you can opt out by emailing dataprotection@aman.com.

We will process your request as soon as reasonably practicable. Please note that opting out of marketing emails will not affect your receipt of important administrative messages, which we may still send.

HOW TO EXERCISE YOUR INDIVIDUALS’ RIGHTS REQUESTS PERTAINING TO YOUR PERSONAL DATA

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Data, object to or opt out of the processing of Personal Data, withdraw your consent, or if you would like to request to receive a copy of your Personal Data for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Data you would like to have changed or whether you would like to have your Personal Data suppressed from our database. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
Where provided by applicable law, you may also lodge a complaint with the UK data protection authority here or with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs.

OTHER IMPORTANT INFORMATION

Retention
We retain Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law:
The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you are subscribed to our newsletter or your enquiry is active);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Security

We seek to use reasonable organisational, technical and administrative measures to protect Personal Data within our organisation. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section, below.

Sensitive Data
We do not intend to collect Sensitive Data. We ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

Use of Services by Minors
The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Data directly from individuals under 18.

International Transfers

Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

ADDITIONAL INFORMATION REGARDING THE EEA, the UK and Switzerland: Some countries are recognised by the European Commission and UK government, respectively, as providing an adequate level of data protection according to EEA/UK standards. For transfers from the EEA and the UK to countries not considered adequate by the European Commission and the UK government, respectively, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission and UK government to protect your Personal Data. You may obtain a copy of the list of countries with adequate level of protection and the standard contractual clauses by contacting us at dataprotection@aman.com.

CONTACTING US

Aman Group S.a.r.l and its affiliates in Aman Group are responsible (data controllers) for the Personal Data we hold about you. The developers of ATMA residences projects (e.g., OKO Group and Oak Row Equities) are independent controllers of the residence enquiry data they receive from us.

Aman Group S.a.r.l is also the controller of the ATMA marketing database and conducts all marketing activities relating to ATMA.

Aman Group’s address is Grabenstrasse 17, 6340 Baar, Switzerland.
Aman’s European Representative is AMANRESORTS MANAGEMENT NV, a company established in the Netherlands, with offices located in Netherlands, address Herikerbergweg 88, 1101CM Amsterdam, registration number 803529363. You may always contact us at dataprotection@aman.com or our EU Representative at eurepresentative@aman.com with your questions or concerns regarding this Privacy notice or in general about our processing of your Personal Data.

For Turkish residents, our Data Representative in Turkey is Gamze Utar and can be contacted at dataprotection@aman.com.

Updates to This Privacy Notice
The “LAST UPDATED” legend at the top of this Privacy Notice indicates when this Privacy Notice was last revised. Any changes will become effective when we post the revised Privacy Notice on our Website.