Privacy Policy

  1. PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how CIDOT processes your Personal Data through your use of this Website, including any data you may provide through this Website when you sign up to any of our newsletters.

This Website is not intended for children and we do not knowingly collect data relating to anyone under the age of 16

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are processing Personal Data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. It is designed to also reflect the requirements of the EU General Data Protection Regulation.

  1. WHO WE ARE (CONTROLLER) AND HOW YOU CAN CONTACT US
    1. Who we are

Cayman Islands Department of Tourism, Government Administration Building, Box 134, 133 Elgin Avenue, Grand Cayman, KY1-9000, Cayman Islands, is the controller and responsible for processing your Personal Data (collectively referred to as ”CIDOT’’, “we”, “us” or “our” in this privacy notice) in context of this Website.

  1. Our Data Protection Compliance Manager

We have appointed a Data Protection Compliance Manager (DPCM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPCM using the details set out below or at dpcm@caymanislands.ky.

  1. Contact details for EU users

If you are a user located in the European Union or in the European Economic Area, you can contact our UK office as follows: Cayman Islands Department of Tourism, Email address: gdpruk@caymanislands.ky, Postal address:  34 Dover Street, London, W1S 4NG, United Kingdom.

CIDOT is a government entity who performs tasks in the public interests of the Cayman Islands. As such, CIDOT does not formally have to appoint a local EU representative.

  1. Lodge a complaint with EU supervisory authority

If you are a user located in the European Union or in the European Economic Area, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk ), or your local EU/EEA data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or other authorities so please contact us in the first instance.

  1. THE DATA WE PROCESS ABOUT YOU
    1. Personal Data

Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer (together “process”) different kinds of Personal Data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, or similar identifiers.
  • Contact Data includes postal address, email address and telephone numbers.
  • 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.
  • Marketing and Communications Data includes your choices as well as preferences in receiving marketing from us and our third parties, your communication preferences, data in social media profiles and social media username, and all information you provide to us via email or the Website or otherwise.
 
  1. Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for certain purposes. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

  1. HOW WE COLLECT YOUR PERSONAL DATA?
    1. Direct interactions. You may give us your Identity and Contact Data as well as Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
      • enter competitions;
      • subscribe to our publications;
      • participate in our activities; or
      • request marketing to be sent to you.
    2. Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies. See ‘’COOKIES’’ below for more information.
    3. Third parties. We do not collect data from third parties except in the event that we are partnered with another brand or organisation (e.g. a tour operator) to undertake joint marketing activity. In which case how your data would be used by each party will be made clear.
  2. HOW WE PROCESS AND USE YOUR PERSONAL DATA

We will only use your Personal Data when the law allows us to as described below.. Most commonly, we will use your Personal Data in the following circumstances:

  1. Purposes for which we  process your personal data

We have set out below, in a table format, a description of all the ways we process your Personal Data, and which of the legal bases we rely on to do so. Where ever the legal basis is consent, we will ask you explicitly to consent on our website or otherwise.

# Purpose/Activity
 
Type of Personal Data
 
Lawful basis for processing including basis of legitimate interest 
1 To manage our relationship with you which will include:
(a) Respond to inquiries.
(b) Notifying you about changes to our terms or privacy policy
(c) Asking you to leave a review or take a survey
(i) Identity
 
(ii) Contact
(iii) Profile
(iv) Marketing and Communications
(a) Necessary to comply with a request from you (contract performance).
(b) Necessary to comply with legal obligations.
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
2 To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
 
(i) Identity
 
(ii) Technical
 
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security.
(b) Necessary to comply with a legal obligation
3 We send you marketing communications from us if you have requested information from us based on your interests (i) Identity
 
(ii) Contact
(iii) Profile
(iv) Usage
(v) Marketing and Communications
(vi) Technical
Your consent
4 To deliver relevant website content to you and measure or understand the effectiveness of the communication that we serve to you
 
(i) Identity
(ii) Profile
(iii) Usage
(iv) Marketing and Communications
(v) Technical
Your consent 
5 To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (i) Technical
 
(ii) Usage
 
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
6 To deliver relevant Marketing materials to individuals subscribed to our mailing lists. Materials including news articles, newsletters and event invitations.
 
We use mailing list software in conjunction with our CRM to deliver the communication by email.
(i) Identity
 
(ii) Contact
(iii) Profile
(iv) Usage
(v) Marketing and Communications
(vi) Technical
Your consent
7 To feature your images published on Instagram on our Websites, our Instagram or Facebook profile and in other ways as permitted in the license agreement [link] between you and us. (i) Identity
 
(ii) Marketing and Communications Data 
Necessary to prepare and perform the license agreement with you (contract performance)
 
  1. Your marketing choices

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. For example, when subscribing for our newsletter, we offer a variety of information options you can choose from.

You can ask to stop sending you marketing messages at any time by contacting us at any time at dpcm@caymanislands.ky. Each communication we send will have an unsubscribe option in the footer.

  1. Cookies
    1. What are cookies?

Cookies” are pieces of information that may be placed on your computer by a service for the purpose of facilitating and enhancing your communication and interaction with that service. There are other technologies with similar purposes, such as beacons or pixels, that we also call “cookies” in this policy.

  1. Which types of cookies do we use?

We use the following types of cookies on the Website:

  • Strictly necessary Cookies

These cookies are necessary to allow you to browse the Website and use Website functions. Without these cookies the Website would not function properly. These cookies do not collect your Personal Data.

  • Functional Cookies

These cookies allow websites to remember your chosen preferences (such as your language settings). They allow us to provide you with improved functions. It is not possible for us to personally identify you using the information collected by these cookies.

  • Performance cookies

These cookies assist us in understanding how visitors interact with the Website by providing information about the visited pages, the time spent on the Website, and error messages in case of technical problems. This helps us to improve the performance of our websites.

We use these cookies only if you have consented via the cookie banner.

  • Analytical cookies

We use analytical cookies to see, for example, which content on the Website is highly frequented and also to analyse if content should be updated or improved. These cookies are also used to provide you with personalized content based on the pages you have shown interest in.

We use these cookies only if you have consented via the cookie banner.

  1. How do we use cookies?

We use cookies (and similar items such as clear gifs, web beacons, tags, etc.) on the Website to customize your visit and for other purposes to make your visit more convenient or to enable us to enhance our service. For example, we may use cookies to allow easier access to your specific country of origin on the global landing page of the Website. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your computer without your knowledge.

  1. Which specific cookies do we use?

Please find here a list docs.kentico.com/k11/configuring-kentico/adding-cookie-law-consent-to-web-pages/reference-kentico-cookies of the most important cookies we are using.

  1. How can you control cookies?

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

 
  1. Google Analytics

This Website uses Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as “Google”). Google Analytics uses cookies to help a website to analyse how users use the website. The information generated by the cookie about your use of our Website (including your IP address) will be transmitted and stored by Google on servers in the USA.

As the IP anonymization is activated on this Website, your IP address will be truncated by Google within the member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional circumstances a full IP address will be saved to a Google server in the USA and truncated there. The IP anonymization is active on this Website. Google will use this information on our behalf for the purpose of evaluating your use of this Website, compiling reports on website activity, and providing us with other services relating to the use of this Website and the internet.

You can also block the cookie’s collection of data regarding your use of this Website (including your IP address) as well as the processing of this data by Google, by downloading and installing the browser add-on found under the following link: http://tools.google.com/dlpage/gaoptout?hl=en

As an alternative to the browser add-on, you can click this link in order to opt out from being tracked by Google Analytics within this Website in the future. An opt-out cookie will be stored on your device, which means that you will have to click the link above again if you delete your cookies.

You can find more information under the following link: http://www.google.com/intl/en/privacypolicy.html

  1. Social media and Social plug-ins
    1. Social plugins

Our Website also uses so-called social plugins from Facebook, Twitter, Instagram,, LinkedIn, Pinterest, WhatsApp and Tumblr . These services are provided by Facebook Inc, Twitter Inc., Instagram LLC, and LinkedIn(“Providers”).

Facebook is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. An overview of Facebook plugins and their appearance can be found here: https://developers.facebook.com/docs/plugins

Twitter is operated by Twitter Inc, 1355 Market St, Suite 900, San Francisco, CA 94103, USA. An overview of the Twitter buttons and their appearance can be found here: https://about.twitter.com/en_us/company/brand-resources.html

Instagram is operated by Instagram LLC, 1601 Willow Road, Menlo Park, CA 94025, USA. An overview of the Instagram buttons and their appearance can be found here: http://blog.instagram.com/post/36222022872/introducing-instagram-badges

LinkedIn is operated by LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA. Learn more about LinkedIn’s plugins here: https://developer.linkedin.com/plugins

Pinterest is operated by Pinterest Inc., 651 Brannan Street, San Francisco, CA 94103, USA. An overview of the Pinterest badge and its appearance can be found here: https://business.pinterest.com/en-gb/pinterest-brand-guidelines

WhatsApp is operated by WhatsApp Inc., 1601 Willow Road, Menlo Park, California 94025, USA. . An overview of the Tumblr buttons and their appearance can be found here: https://whatsappbrand.com/

Tumblr is operated by Tumblr, Inc., 770 Broadway, New York, NY, 10003, USA. An overview of the Tumblr buttons and their appearance can be found here: https://www.tumblr.com/buttons

If you access a page of the Website that contains such a plug-in, your browser establishes a direct connection to Facebook, Twitter or Instagram servers. Via the plugins, the Providers receive the information that you visited our Website even if you do not have a profile or are not currently logged in. This information (including your IP address) will be transferred from your browser directly to a server of the respective Provider in the USA and is stored there.

If you are logged in to one of the social media services, the Providers may allocate your visit of the Website to your account with them. Interactions with plug-ins like the “Like-Button” are sent directly to the Providers’ servers and stored there. The information is also stored in the social network and published on your account.

The purpose and scope of the data collection and the further processing of your data by the Providers as well as your relevant rights and setting options for the protection of your privacy can be found in the privacy notices of the Providers.

  1. YouTube embedding

The videos on the Website are embedded from the YouTube platform (part of Google Inc., based in San Bruno/California, USA), which means that the video is played directly on YouTube.com but displayed on the Website. Cookies are placed by YouTube, via which your data is transmitted to YouTube when you are logged in to your YouTube account via your PC. This is necessary to allow you to save the videos in your "watch later" playlist.  You can prevent such data transmission by logging out of YouTube beforehand.

We collect and process your data via these cookies on the basis of your consent (Art. 6 (1) lit. a GDPR) to show you personalised content and thus improve your experience on the Website.

For more information about YouTube's processing of your data, please see YouTube's Privacy Policy at https://policies.google.com/privacy?hl=en&gl=en.

  1. Facebook fan page

We process personal data together with Facebook in connection with the operation of our Visit Cayman Islands Facebook fan page (“Fan Page”). When you visit the Fan Page, Facebook processes your IP address and your usage behavior on the Fan Page, among other things. This information is used to provide CIDOT, as the operator of the Fan Page, with statistical information about the use of the Fan Page (e.g. about the likes, the reach of the Fan Page and user demographics, e.g. age, gender, language, geographical data). Further information is available here: https://www.facebook.com/business/a/page/page-insights#u_0_3 .

The data collected about you in this context will be processed by Facebook Ireland Limited and transmitted to Facebook, Inc. in the USA (and other third countries) in order to provide the Facebook services. In Facebook’s data policy (available here: https://www.facebook.com/policy.php ) you may find further information on what information Facebook receives, how it is used, how long it is stored by Facebook and with which third parties it is shared. Facebook’s data policy also includes Facebook’s contact details and guidance on how to change your settings with regard to advertisement.

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your Personal Data with third parties set out below for the purposes set out in the table in paragraph 5 (a) above:

  • Service providers who provide IT and system administration services.
  • Customer Relationship Management (CRM) platforms.
  • Email marketing platforms.
  • Data collection platforms and
  • Analytics providers.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

  1. INTERNATIONAL TRANSFERS

Whenever we transfer your Personal Data to a party located out of the EU/EEA, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards such as the following are implemented:

  • We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission..
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe (so called Standard Contractual Clauses)..

Please contact us on dpcm@caymanislands.ky if you want further information on or a copy of the specific mechanism used by us when transferring your Personal Data out of the EEA.

  1. THIRD-PARTY LINKS

This Website may include links to third-party websites, blogs, social media platforms and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. DATA SECURITY

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. DATA RETENTION
 
HOW LONG WILL YOU PROCESS MY PERSONAL DATA FOR?

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements, or until you ask us to delete it. For example:

  • We will retain your Personal Data concerning marketing and newsletters for as long as you do not withdraw consent.
  • We store cookie data as set forth under “lifespan” in the table in section 5 (c)iv).
  1. YOUR LEGAL RIGHTS
    1. Your rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data.

Particularly as an EU user of our Website, you have the right to:

  • Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Please keep us also informed if your Personal Data changes during your relationship with us.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
 

If you wish to exercise any of the rights set out above, please contact us at dpcm@caymanislands.ky.

For more information on your rights and accordant requirements, please see the information provided by the EU Commission at https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

  1. No fee usually required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

  1. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

  1. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 05/07/18. We will inform you in advance if we make substantial changes to this privacy notice by e-mail if you are registered with us or on the Website.