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 use any of our sign-up forms.

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 applicable privacy laws, including the EU and the UK General Data Protection Regulation.

2. CHANGES TO THE PRIVACY NOTICE AND OUR DUTY TO INFORM YOU OF CHANGES

Please see the date of the last update to the privacy notice above. We will inform you in advance if we make substantial changes to this privacy notice via the Website.

3. WHO WE ARE (CONTROLLER) AND HOW YOU CAN CONTACT US

 a. 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.

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 or UK representative.

b. 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.

4. THE DATA WE PROCESS ABOUT YOU 

 a. 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, gender, 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.
• Marketingand 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.

Under specific circumstances, e.g. when you register for a webinar, training, sponsorship or similar event, or when you request specific assets from us, we may also process the following categories of your Personal Data, depending on what we ask you to provide in the applicable sign-up form:

• Financial Data includes bank account details, tax information, pay slips, credit card details, and other financial information.
• Company Data includes corporate name, account statements, tax information, type of business, job roles.
• Research Data includes visitor spend, demographic data, and characteristics of visit.
• Employment Data includes company name, company address, company email address, company phone and fax numbers, company website, references, job history, business travel arrangements, and safety data;
• Daily Work Data includes information collected and created in context of your working relationship with CIDOT including emails, work products/ services, bookings, rewards and evaluation data.
• Educational Data includes education and vocational training records including qualifications, grades, training received;
• Health Insurance
• Other Personal Data that data subjects provide to us which is specified in the respective forms or similar unless data subjects provide it to us without specific occasion. 

 b. 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.

5. HOW WE COLLECT YOUR PERSONAL DATA? 

1. Direct interactions.  By filling in forms on the Website or by corresponding with us by post, phone, email or otherwise, you may give us the Personal Data requested in such sign-up forms or that you decide to provide us with. This includes Personal Data you provide when you:
   • subscribe to our publications/ newsletters
   • fill out a form;
   • participate in our activities (e.g. webinars and trainings);
   • request marketing to be sent to you; or
   • apply for a programme or visitor status with us
2. Automated technologies or interactions. As you visit the Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data, and Marketing and Communications 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 or for training purposes. In which case how your data would be used by each party will be made clear.

6. 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:

  a. Purposes for which we process your Personal Data

We have set out below, in a table format, a description of all the ways we may process your Personal Data in connection with your visit of the Website, and which of the legal bases we rely on to do so. Please note that not all processing activities may be applicable to your Personal Data and that this depends on how you use the Website and interact with us. Wherever the legal basis is consent, we will ask you explicitly to consent on our Website or otherwise.

b. Your 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 messages, particularly marketing messages, at any time by contacting us at dpcm@caymanislands.ky. Each communication we send will also have an unsubscribe option in the footer. Please note, however, that you will not be able to opt out of certain messages that we are required to send by law or in order to fulfil contractual obligations towards you.

c. Cookies

     i. What are cookies and how do we use them?

"Cookies" are pieces of information that may be placed on your computer by us or a service we use 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. Beacons and pixels are content included on the Website and in emails to collect Technical Data about your equipment, Usage Data, and Marketing and Communications Data when you interact with the Website and emails.

     ii. Which types of cookies do we use?

We use the following types of cookies on the Website:

• Essential Site Functions 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. The data processed by this type of cookies is more of a technical than a personal nature and concerns e.g. the type and settings of your device.

• 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. These cookies process and save data like your browser type, referrer URLs, operating system, date / time stamp, views and clicks on the Website and your (truncated) IP address. We use these cookies only if you have consented via our cookie settings page.

• Advertising cookies

These cookies assist us with providing you with ads on our website and on partner websites that are relevant for you. They also help us to adjust how often a specific ad is shown to you and measure the effectiveness of our marketing campaigns. These cookies process and save data like your user agent (name and version of the browser software) as well as clicks, views, referrers, URL calls. We use these cookies only if you have consented via our cookie settings page.

• Social Media Cookies

These Cookies have similar functionalities like the Advertising Cookies and assist us with providing you relevant ads based on your interests on social platforms. They also help us to measure the effectiveness of marketing campaigns on the social platforms. These cookies process and save data like your user agent (name and version of the browser software) as well as clicks, views, referrers, URL calls.
We use these cookies only if you have consented via our cookie settings page.

      iii. Which specific cookies do we use?

Please find a list of the cookies we are using at https://www.visitcaymanislands.com/en-us/cookie-settings where you can also change your cookie preferences.

      iv. How can you control cookies?

You can control the use of cookies on our Website via our cookie settings page.
In general, 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.

 d. Social plug-ins

      i. Social plugins

Our Website also uses so-called social plugins from Facebook, Twitter, LinkedIn, Pinterest, WhatsApp, Tumblr and Reddit. These services are provided by Facebook Inc, Twitter Inc., LinkedIn Corporation, Pinterest Inc., WhatsApp Inc.,Tumblr Inc.and Reddit Inc. (“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

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

Reddit is operated by Reddit, Inc., 1455 Market Street, Suite 1600, San Francisco, CA 94103, USA.

You can use these plugins to like, share or otherwise be active directly on the respective network.
You can identify the social plugins on our Website by their respective company logos.

We use a data protection-friendly tool called the “Shariff button” so that before you click on the social plugin buttons, only the server address is sent to the respective social network instead of your IP address (which would otherwise immediately happen when you are on our Website). As long as you do not click on the social plugin, you remain invisible to the operators of the respective social network.

We use the Shariff button to prevent social networks from tracking and storing Internet behaviour without the users' active contribution.

By using the social plugin, you agree to the collection of your personal data by the respective network. The respective social network is then itself responsible for the collection and processing of data, including the use of cookies and similar technologies by the social network. Specifically, information about which of our Internet pages you have visited, and your IP address are then transmitted to the social network, even if you do not have a profile with the respective network or are not logged in there at that time. If you are logged in as a member of the social networks, the network assigns the information to your personal user account.

We therefore recommend that you read the privacy policy of the respective network before using the social plugin:
Facebook: https://www.facebook.com/policy.php
Twitter: https://twitter.com/en/privacy
LinkedIn: https://www.linkedin.com/legal/privacy-policy
Pinterest: https://policy.pinterest.com/en/privacy-policy-2016
WhatsApp: https://www.whatsapp.com/legal/?lang=en
Tumblr: https://www.tumblr.com/privacy
Reddit: https://www.redditinc.com/policies/privacy-policy

      ii. 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.

We have integrated the YouTube videos in our Website via the YouTube "nocookie" solution. This ensures that a connection to the YouTube servers is only established when you click on a video. Your personal data is only transmitted to YouTube after you do so. YouTube is responsible for the personal data you submit to YouTube in this manner. You can prevent transmission to YouTube by logging out of your YouTube account.

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.

 7. 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 6 (a) above:

• Cayman Islands Government entities
• CIDOT agreed partners or agencies on record providing technical assistance
• Service providers who provide IT and system administration services.
• Customer Relationship Management (CRM) platforms.
• Email marketing platforms.
• Website/content platforms
• Data validation / storage 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.

Third party services providers may only process your Personal Data for their own purposes if you have consented to this or as otherwise allowed to do so under our contracts in accordance with applicable privacy laws.

We do not rent, sell, or share personal information (as defined by California Civil Code §1798.83) about you that we collect on the Website with other people or unaffiliated companies for their direct marketing purposes, unless we have your permission. We allow access to your information to enable the delivery of online advertising to you and others on the Website and on other websites and online services from us and our third-party advertising partners, or to send you information we think may be useful or relevant to you.

In addition to other consent rights you may have, you may be able to opt out of receiving personalized advertisements on this browser or device from advertisers, or other advertising networks who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out options of each of those organizations and/or via our cookie management tool that you can find here. Links to those sites are here:

Browser Opt-Out:

• Network Advertising Initiative: http://www.networkadvertising.org/choices/
• Digital Advertising Alliance: http://www.aboutads.info/choices/

When you opt out of personalized advertising, you may continue to see online advertising on the Website and/or our ads on other websites and online services.

 8. INTERNATIONAL TRANSFERS

Whenever we transfer your Personal Data to a party located out of the EU/EEA/UK, 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 or the UK Information Commissioner.
• Where we use certain service providers, we may use specific contracts approved by the European Commission or the UK Information Commissioner which give Personal Data the same protection it has in Europe/the UK (so called Standard Contractual Clauses).

Please contact us at 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 jurisdiction.

 9. THIRD-PARTY LINKS

This Website may include links to third-party websites, blogs, news articles, 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.

 10. 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 as required for the respective purpose or 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.

 11. 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 that we process based on your consent for as long as you do not withdraw consent.
• We store cookie data as set forth under "lifespan" in the cookie consent tool (cookie settings page).

 12. YOUR LEGAL RIGHTS 

    a. Your rights

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

Particularly as an EU-based or UK-based 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 and UK Information Commissioner at https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ or contact a data protection authority in the EU or UK.

    b. 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.

    c. 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.

    d. 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.