This website, Wave Development Partners (the “Site”), is operated by S W Hart Enterprises LLC, doing business as (“DBA”) Wave Development Partners (“Wave Development Partners,” “we,” “us,” or “our”), the go-to-market partner that commercializes luxury residential developments in Costa Rica. We are the data controller responsible for the personal information described in this policy.
Registered / business address: 580 N 100 E, Provo, UT 84606, USA.
General contact: spencer@wavedevelopmentpartners.com · +1 (435) 513-0074.
This policy explains how we collect, use, disclose, and safeguard personal information when you visit the Site, submit an inquiry, request information, subscribe to communications, or otherwise interact with us. It applies to individuals in the United States, Canada, the European Economic Area (EEA), the United Kingdom, Costa Rica, and elsewhere. Where local law grants you additional rights, the sections below describe them.
We collect the following categories of personal information:
We do not intentionally collect special/sensitive categories of data (such as health, race, or religion). Please do not submit such information through the Site.
We use personal information to:
If you provide your mobile number and check the SMS consent box on our form, you consent to receive text messages (SMS/MMS) from Wave Development Partners related to your inquiry — including advisor replies, project updates, appointment scheduling, and, where separately opted in, marketing messages. Program details:
Mobile information sharing — our commitment. No mobile information (including your phone number and SMS consent) will be shared with third parties or affiliates for their own marketing or promotional purposes. We may share mobile information only with vendors and subcontractors that help us deliver the messaging service (for example, our messaging platform and CRM), strictly to operate the program on our behalf. Text-messaging originator opt-in data and consent are not shared with any third parties for their marketing, and are excluded from any sale or trade of data. Full details are in our Messaging Terms.
Where the EU or UK GDPR applies, we rely on the following legal bases:
We share personal information only as needed:
We do not permit our service providers to use your information for their own purposes.
We do not sell your personal information, and we do not share it for cross-context behavioral advertising. In particular, we never sell, rent or trade mobile phone numbers or SMS opt-in data.
Cookies are small text files placed on your device when you visit a website. We use them to run the Site, remember your preferences, and — only with your consent — understand usage. We set strictly necessary cookies automatically because the Site cannot function without them; we place non-essential cookies (such as analytics) only after you accept them through our cookie banner. You can accept or decline when you first visit, and change your choice at any time.
wave_consent) that remembers your choice. These do not require consent.Some pages also load resources from third parties — for example, web fonts from Google Fonts — which may process limited technical data (such as your IP address) to deliver the resource. You can control or delete cookies through your browser settings; note that blocking strictly necessary cookies may affect how the Site works.
We keep personal information only as long as necessary for the purposes described here, to comply with legal obligations, resolve disputes and enforce agreements. Inquiry and consent records are retained for the duration of our relationship and for a reasonable period afterward as required by applicable law; you may request deletion as described below.
We use technical and organizational measures appropriate to the risk — including encryption in transit (HTTPS), access controls and vetted processors — to protect personal information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
We operate in Costa Rica and work with service providers in the United States, Canada, the EU and elsewhere, so your information may be transferred to and processed in countries other than your own. Where required, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses (and the UK Addendum) for transfers out of the EEA/UK. You may request a copy of the safeguards we use by contacting us.
Depending on where you live, you may have the right to access, correct, delete, or receive a portable copy of your personal information; to object to or restrict processing; and to withdraw consent. To exercise any right, contact us at spencer@wavedevelopmentpartners.com. We will respond within the timeframes required by applicable law and will not discriminate against you for exercising your rights. EEA/UK residents may also lodge a complaint with their local supervisory authority.
If you are a resident of California or another US state with a comprehensive privacy law (such as Virginia, Colorado, Connecticut, Utah, Texas, Oregon and others), you may have rights to know/access, delete, correct, and obtain a portable copy of your personal information, and to opt out of “sale,” “sharing,” or targeted advertising. As noted above, we do not sell or share personal information for these purposes. California residents may also request information about disclosures under the “Shine the Light” law. To exercise these rights, contact us using the details in Section 19. You may use an authorized agent, and we will verify requests as permitted by law.
For individuals in Canada, we handle personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial laws. We obtain consent appropriate to the sensitivity of the information, limit collection to what is necessary, and let you withdraw consent subject to legal and contractual limits. Consistent with Canada’s Anti-Spam Legislation (CASL), we send commercial electronic messages only with your consent, always identify ourselves, and include a working unsubscribe mechanism in every message. Contact our Privacy Officer (Section 19) with any request or concern; you may also contact the Office of the Privacy Commissioner of Canada.
We process personal data in accordance with Costa Rica’s Law No. 8968 on the Protection of the Person against the Processing of their Personal Data and its regulations. We collect data with your informed consent for the purposes stated at the point of collection, keep it accurate and secure, and honour your rights of access, rectification, and deletion. Where required, databases are registered with the Agency for the Protection of Data of the Inhabitants (PRODHAB). You may exercise your rights or file a complaint with PRODHAB. Data-protection contact: spencer@wavedevelopmentpartners.com.
The Site is intended for adults and is not directed to children under 16 (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us and we will delete it.
We may update this policy from time to time. We will post the revised version here with a new “Last updated” date and, where required, notify you. Your continued use of the Site after changes take effect constitutes acceptance of the updated policy.
For any privacy question or to exercise a right, contact: