Privacy Policy

Leisure Travel Update
Global Citizen Concierge
Privacy policy for the Cayman Islands Department of Tourism Instagram page
 
Dear visitors of our Instagram page,
 
The following information explains the data processing on our site at https://www.instagram.com/visitcaymanislands/ (“Instagram Page”) by
 
  • us, the Cayman Islands Department of Tourism, Government Administration Building, Box 134, 133 Elgin Avenue, Grand Cayman, KY1-9000, Cayman Islands (“CIDOT” or “We”), as the operator of this Instagram Page, and
 
  • Facebook (located in Ireland at Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland; located in the USA at Facebook, Inc., Facebook Headquarters, 1 Hacker Way, Menlo Park, CA 94025, USA) (“Facebook”) as data controller of the Instagram platform (“Instagram”).
Both Facebook and we are responsible for certain portions of the processing of your data when you use the Instagram Page. However, Facebook primarily processes the data. Below we explain how this works and what your rights are:
 

I.Statistical evaluations

 
When you visit our Instagram Page, we do not receive any personally identifiable information about you unless you actively like, post, share, comment, or take other active steps to use it.
However, we do receive statistical evaluations of the use of our Instagram Page, which are made available to us in anonymised form by Facebook via the “Instagram Insights” function. These evaluations include the following data in particular:
  • Number of “Like” statements on our posts
  • Number of comments on our posts
  • Number of people who have seen a post
  • Number of times a post was shared
  • Number of times a post was reported as spam
  • Number of times that users no longer want to follow our page
 
This information transmitted to us by Facebook is aggregated, i.e. summarised in such a way that we cannot associate it with your person. However, this does not necessarily mean that the data collection and data processing at Facebook itself is also anonymous. Please read further information on data processing by Facebook on Instagram: https://en-gb.facebook.com/help/instagram/155833707900388 and below.
 

II.Collection and use of personal data

    1.Data processing by CIDOT

The manner and extent to which personal data is collected when you visit Instagram sites depend primarily on the behaviour of the user, i.e. you. Therefore, you can partly influence the collection of data.
 

    a)User actions and action data

We only receive personal data from you when you like, post, share, or comment on content on our Instagram Page, or otherwise actively use it. We also receive personal data from you when you voluntarily share or respond to posts posted on Instagram or post a link to your Instagram profile. In these cases, however, we will only process the information you have made public on Instagram for us and other users (“Action Data”).
 
The Action Data includes your (user) name and the content published via your profile if you have set your privacy settings at Instagram accordingly. We do not receive background usage data (such as your IP address or device number or information you have not made public) or other “hidden” data from you or Facebook.
 

    b)Processing purposes - Presenting our Instagram Page and answering inquiries

We process Action Data solely for the purposes that you and we pursue with the use of Instagram, namely
 
  • Presentation and operation of our Instagram Page, and
  • Reply to your non-public messages (direct messages) and your public messages addressed to us, as well as your comments or posts on Instagram or our Instagram Page.
 
In particular, we do not create profiles of you or mix the Action Data with other data we might have about you.
 

    c)Legal basis

We process the Action Data on the basis of our legitimate interest in providing our visitors and subscribers on Instagram with relevant content so they can use our Instagram Page and its functionalities. We respond to your messages, comments or posts in order to answer your requests, so for fulfilling contract-like obligations towards you, or based on our legitimate interest to interact with visitors of our Instagram Page (e.g. thanking you for contributions).
 
In individual cases, we may need your consent to process your Action Data, e.g. if a post we post contains a picture of you. If so, we will explain further details about this data processing in connection with obtaining your consent.
 

    d)Data retention

We process your Action Data for the described purposes only as long as necessary, i.e. usually as long as we operate our Instagram Page or as long as your user activity on our Instagram Page is online or until we have finally answered your direct message. Beyond that, we only store the Action Data for the fulfilment of any legal retention obligations.
 

    a.Data recipients

  • Processors. In connection with the purposes described here, we may transfer your Action Data to external service providers, such as IT service providers. We have carefully selected these service providers and have concluded data processing agreements as required by applicable law with them.
  • Partners. In individual cases, we will pass on your Action Data to other controllers who process the personal data for their own purposes, as far as this is necessary for contract fulfilment or the provision of services, e.g. in the context of competitions. Our contractual partners may use the data transmitted in this way exclusively for the purpose for which we have transmitted it. The transmission of your Action Data for these purposes is carried out in order to fulfil a contract or due to our legitimate interest in making our operations efficient.
  • Other recipients. We will otherwise only transfer your Action Data to other recipients in individual cases if and to the extent required or permitted by law, or to enforce legal claims or to investigate or prevent suspected or actual illegal activity. In these cases, we will inform you separately about the respective transfer if and to the extent that this is legally required.
 
Please note that since Instagram is a public platform, potentially anyone can see your posts on Instagram.
 

    2.Data processing by Facebook

    a)Usage data and user content

When you visit our Instagram Page, Facebook also collects and processes your personal data, including your Action Data. We do not influence what data Facebook processes, to what extent and how, or whether and how Facebook passes this data on to third parties, especially in countries outside the European Union. It is your responsibility to familiarise yourself with this information and to decide whether you agree to it.
 
In essence, to the best of our knowledge, Facebook processes the following personal data about you when you visit our Instagram Page or the Instagram platform:
  • Registration data, such as username, password, e-mail address;
  • Profile information such as first and last name, phone number, picture;
  • Log file information and usage data, such as web request, IP address, browser type, landing pages, pages viewed (even if you are not logged in - as far as technically possible); and
  • Device ID, metadata like hashtags, geotags, and comments.
 
Facebook uses this personal data to provide you with the Instagram platform, but also to analyse your usage behaviour and to offer you personalised content - also across other Facebook platforms (e.g. Facebook or Messenger). You can find detailed information on the processing of your personal data by Facebook in the Instagram Platform Privacy Policy (https://en-gb.facebook.com/help/instagram/155833707900388).
Facebook offers you the ability to restrict the processing of your personal data by Facebook in the privacy settings of your Instagram profile. Information about the privacy settings can be found here (with further links):
https://help.instagram.com/196883487377501/?helpref=hc_fnav&bc[0]=368390626577968&bc[1]=1757120787856285
 

     b)Data processed via Facebook cookies and app interfaces

When you visit our Instagram Page through the Instagram website or Instagram app, Facebook may use cookies and similar technologies such as pixels, web beacons and local storage (LocalStorage) or app interfaces (graph.facebook.com) to collect information about your use of the Instagram Page and the Instagram platform as a whole, as well as to provide you with features on the Instagram platform.
In addition, advertisers or other partners of Instagram or Facebook may place cookies or similar technologies on your device. We have no influence on these data processing activities.
For more information about cookies on Instagram, please visit https://www.instagram.com/legal/cookies/.
 

III.Your data protection rights (particularly if you are in the EU – might not apply / fully apply in other jurisdictions)

    1.With us

You have the following legal rights against CIDOT with regard to the Action Data, provided the respective requirements are met. You can find more information about your rights and the relevant requirements on the website of the EU Commission at https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
 

     a)Right of access to data

You have the right to request confirmation as to whether we process personal data concerning you. If this is the case, you have the right to be informed about this personal data and to receive further information, e.g. the purposes of processing, the recipients and the planned duration of storage or the criteria for determining the duration.
 

     b)Right to rectification and completion

You have the right to request that your incorrect personal data be corrected immediately. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data.
 

     c)Right to erasure (“right to be forgotten”)

You may have the right to have your personal data erased. This is the case, for example, if your personal data are no longer necessary for the original purposes, if you have revoked your consent under data protection law or if the personal data have been processed unlawfully.
 

     d)Right to limit processing

You have the right to limit the processing of your personal data in the cases prescribed by law.
 

     e)Right to data portability

You have the right, in the cases required by law, to receive personal data concerning you in a structured, common and machine-readable format.


     f)Right to object

You have the right to object at any time, for reasons arising from your specific situation, to the processing of certain personal data concerning you.
In the case of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including any profiling, insofar as it is connected with such direct marketing.


     g)Right to revoke your consent

You can revoke your consent to the processing of your personal data at any time with effect for the future. However, the legality of the processing carried out up to the time of revocation is not affected by this.


     h)Right to complain to a data protection authority

You have the right to complain to a supervisory authority, in particular in the EU Member State in which you are resident, in which your place of work or the place of the suspected infringement is located, if you believe that the processing of personal data concerning you is in breach of applicable data protection laws, particularly the GDPR.


  2. At Facebook

For information on data processing and your data protection rights, please refer to the Instagram Privacy Policy https://en-gb.facebook.com/help/instagram/155833707900388. For more information on how to manage or delete information about you on Facebook through Instagram use, please visit the following Instagram support pages: https://help.instagram.com/196883487377501/?helpref=hc_fnav&bc[0]=368390626577968&bc[1]=1757120787856285.
 

IV.Further Information and Contact

If you have any further questions that this privacy policy could not answer, you are welcome to send us an e-mail to the following address: dpcm@caymanislands.ky.
 
If you would like to learn more about the Cayman Islands, please visit our website at https://www.visitcaymanislands.com/. We inform you about data processing in connection with the Visit Cayman Islands website in our website privacy policy, available at https://www.visitcaymanislands.com/privacy-policy.
 
 
Version December 2020