Terms / Policy - Cayman Consults Ltd (Uganda)

Terms / Policy - Cayman Consults Ltd

CAYMAN CONSULTS POLICY & TERMS

1. About the Policy

This policy is applicable to our online and mobile websites, applications, and digital services which clarifies data collection usage and sharing practices within Cayman Consults Limited, its affiliates and unaffiliated third parties. You consent to the data collection, use, disclosure and storage practices described in this privacy policy when you use any of our website based services, including when you access any content or videos on our websites. We do not seek sensitive information until it is required for legitimate, business and contractual purpose. If such information is received from you the same will be stored as per the retention policy defined at the organization level.

Information Collected by us: We receive both information that is directly provided to us, such as personal information you provide when you request for a service, and information that is passively or automatically collected from you, such as anonymous information collected from your browser or device. Personal information that you directly provide to us when you request for a service, may need to be shared with Cayman Consults Limited customers or third parties for business purpose. In this Privacy Policy, we refer to all of this as "Information".

Information Provided by user: You can register or submit an enquiry to some of the services we offer. In the course of these various offerings, we often seek to collect from you general category information such as: name, address, e-mail address, telephone number, etc.

2. Passively collected information

Cayman Consults Limited uses third party vendor such as Google to analyze usage pattern of our web-site by cookie and http request header to improve our web-site for better user-experience and data architecture.

To opt-out of Analytics for the web, visit Google Analytics Opt-out and install the add-on for your browser. For more details on installing and uninstalling the add-on, please see the relevant help resources for your specific browser.

To know more about google analytics visit

https://support.google.com/analytics/answer/6004245?hl=en-GB

3. Use of cookies and other technologies

Cookies are small, usually encrypted text files, which are used to perform various functions such as storing your preferences, allowing you to easily navigate between web pages, and improving overall user experience. These are located in browser directories and are useful since they have the ability to recognize a user’s PC or mobile device, and customize the user experience by transmitting small amounts of information back to the site. Cookies also help 3rd party agencies to collect information about user profiles, their interactions, actions, and behavior, which help site owners to improve components and functionalities available on the website.

We do not collect personally identifiable information via cookies. The functionalities of some of our cookies that are processed via 3rd parties are limited to providing us with web analytics and more detailed site activity information and intelligence about our website. Information collected via cookies on our website is anonymous and helps us improve our customer service.

For instance, we analyze information pertaining to domains from where visitors come from, visitor activity, etc. Cayman Consults and its affiliates may use this information at an aggregate level to identify trends and statistics, which help us improve the services we offer to our customers.

Highest levels of confidentiality are maintained while processing and analyzing such information.

3.1. Deleting and blocking cookies

By using our website, you agree to provide us your implied consent to the placement of cookies on your device, as explained above. In case you wish to remove these cookies from your device, you can delete these via your browser settings. You can also adjust your browser settings to block these cookies. However, please be informed that deleting or blocking cookies will adversely affect your user experience as certain parts of the website may stop functioning. User discretion is advised while deleting or blocking cookies.

3.2. Use of information

Cayman Consults Limited collects this information to make better business decisions towards our mutual advantage, support the activities you choose to engage in, and provide higher quality solutions and services to you and your customers. We will not sell, share, or rent this information, for commercial purposes, to any person or organization.

3.3. Information security

Cayman Consults Limited classifies your personal information as Confidential Information. Confidential Information is protected by storing it on secure servers that only authorized Cayman Consults personnel have access to.

Our website may contain links to websites of third parties. Cayman Consults Limited has no control over, and is not responsible for, the content, privacy policies or reliability of such sites

4. Review

This policy shall be reviewed periodically (at least once a year) and whenever necessitated by changes within Cayman Consults Limited, to ensure the policy’s appropriateness for the company’s business objectives.

Personal Data Protection Policy

1. Purpose

The purpose of this Personal Data Protection Policy is to protect all personal data collected, stored, processed and/or transferred by Cayman Consults Limited in accordance with internationally recognized standards for data protection in particular: General Data Protection Regulation (GDPR) effective 25th May, 2018.

2. Objectives

To give people control over how their data is used and to protect “fundamental rights and freedoms of natural persons”.

To collect, store, process and transfer personal data in a lawful manner.

Treatment of Personal Data is consistent throughout Cayman Consults Limited entities and operations.

Transfer Personal Data to Cayman Consults Limited entities and other enterprises that use this data in a manner consistent with the data privacy norms set at Cayman Consults Limited.

3. Scope

This policy applies to the following individuals / entities under the Cayman Consults Limited operations that collect, store and/or process personal data:

Cayman Consults Limited Employees;

Cayman Consults Limited Contractors;

Cayman Consults Limited Working Partners

4. Policy Statement

Cayman Consults Limited shall ensure that Personal Data relating to natural persons including employees (current as well as former), suppliers and customers, are obtained and processed fairly, in accordance with the data subjects’ rights under Data Protection Laws and Regulations. Cayman Consults Limited respects the privacy and is committed to promoting the responsible use of personal information and protecting individual’s privacy rights.

5. Policy Guidelines

Cayman Consults Limited as a data controller and processor, shall establish the specific purposes for which Personal Data is being collected and that it’s processing is done in a manner consistent with those purposes.

Cayman Consults Limited shall collect and process only such Personal Data as is adequate, relevant and limited in scope and for a length of time to what is necessary for the stated purposes of its use.

Utilize IT systems and applications that have the ability to comply with Data Protection Laws and Regulations including providing appropriate security for storage and transmission of Personal Data.

Where required by the GDPR, perform Data Protection Impact Assessments. Report breaches promptly and in line with the personal data breach notification process.

Record, investigate, analyze and report data protection-related complaints and

Ensure that data protection training is undertaken by all employees.

6. Data Collection, Transfer & Processing

Cayman Consults Limited may collect, store, use and disclose information about data subjects which may constitute personal data (including sensitive personal data) as per GDPR ,for lawful, explicit and legitimate business and contractual purposes and for further processing of personal data consistent with those purposes.

The personal data may be processed for purposes including, without limitation,

Administering relationships services.

Operational purposes.

Conducting market or customer satisfaction research.

Providing individuals with information concerning products and services which Cayman Consults Limited believes to be of interest.

Compliance with any requirement of law, regulation, associations, codes that Cayman Consults Limited decides to adopt.

For the detection, investigation, monitoring and prevention of fraud and other crimes or malpractice.

For the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending legal rights or any other purpose connected to or incidental to the purposes as stated above.

Cayman Consults Limited shall obtain consent from the data subject willingly prior to collecting, storing and processing of personal data.

Cayman Consults Limited shall not utilize an individual's personal data beyond this scope without prior consent from the individual, and shall take measures to ensure that this principle is observed. An individual's personal data shall not be provided or otherwise disclosed to third parties other than Cayman Consults Limited affiliates, investigators, or law enforcement personnel when consent has been obtained from the individual in question or when disclosure is legally mandated.

To the extent permitted by applicable law, Cayman Consults Limited may record and monitor electronic and voice communications to ensure compliance with the legal and regulatory obligations and internal policies and for the purposes outlined above.

7. Confidentiality and Security

Cayman Consults Limited takes prudent steps to safeguard the confidentiality and security of all personal data including taking procedural and organizational steps to protect personal data from accidental or unlawful destruction and disclosure. These steps include entering into written agreements with all its vendors, subcontractors who process personal data.

Cayman Consults Limited strives to protect personally identifiable information by using appropriate administrative, physical, and technical safeguards that it maintains or disseminates, so it is not obtained by unauthorized individuals or used in unauthorized ways.

8. Data Subject Access, Correction & Deletion

Cayman Consults Limited recognizes the right of data subjects at reasonable intervals to seek / request a copy of the personal data held in relation to them by Cayman Consults Limited. If any personal data is found to be wrong, the individual concerned has the right to ask us to amend, update or delete it, as appropriate. In some circumstances individuals also have a right to object to the processing of their personal data as per the prevailing laws.

If Cayman Consults Limited undertakes transactions or other services that involve the disclosure of personal data on behalf of any of its client or counterparty, it shall be the responsibility of such client or counterparty to ensure that they have all necessary authority to permit Cayman Consults Limited to process and disclose the personal data accordingly.

Privacy consent can be withdrawn easily and at any time by the data subject by informing the appropriate authority within Cayman Consults Limited.

The privacy data shall be deleted from the system based on evaluation of compliance with a legal obligation or business process and technologies available to erase individual data. Evaluation will be done by Cayman Consults Limited’s Data Protection Officer.

9. Breach Notification

Any personal data breach shall be reported to the concerned authorities. Measures shall be taken to mitigate and minimize the breach. All personnel of Cayman Consults Limited handling personal data have a responsibility to report any data privacy breach related incidents in case of violation of the data protection policy.

10. Review

11. Responsibility

Cayman Consults Limited is the data controller for the purpose of Data Protection laws and are obliged to keep personal data secure and process it fairly and lawfully.

HR department shall either obtain data subject’s consent for Cayman Consults Limited use of his/her personal data or send out a privacy notice in accordance with this policy.

The Data Protection Officer (DPO) shall facilitate implementation of this policy through the appropriate policies and procedures. The DPO shall ensure protection of personal data in each country where Cayman Consults Limited has an office.

All personnel of Cayman Consults Limited handling personal data shall take reasonable measures for protection of personal data.

12. Enforcement

Enforcement of this policy is mandatory & violations of this policy will be reported through the Breach Notification process and Information Security Council Team.

The action taken after a violation is as follows:

All violations will be reported to the DPO.

The defaulter will be issued a warning or will face stricter action depending upon prevailing circumstances during which the incident occurred.

A repeat violation on part of the same person would result in strict disciplinary action up to termination of employment.

13. Definitions

Data subject refers to any individual person who can be identified, directly or indirectly, via an identifier such as a name, an ID number, location data, or via factors specific to the person’s physical, physiological, genetic, mental, economic, cultural or social identity. In other words, a data subject is an end user whose personal data can be collected.

Personal Data means any information relating to a living individual who can be identified directly or indirectly by an identifier such as:

A name, identification number, image, location data, an online identifier.

One or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Employee personal details like birth date, address, personal phone number.

Personal email address, race, nationality, ethnicity, origin, color, religious or political beliefs or associations, age, sex, sexual orientation, marital status, family status, identifying number, code, finger prints, blood type, inherited, characteristics, health care history including information on physical/mental.

Disability, educational, financial, criminal, history. Photographs of employee and internal gatherings.

Lawful processing means that the activity is conducted in accordance with applicable national or international laws.

Specified purpose means being clear from the outset about why we are collecting personal data and are transparent about our purposes with the individuals concerned.

Accurate means that the data collected and stored are correct and their integrity is protected.

Adequate, relevant and not excessive means that data should be sufficient for the intended purpose and that we should not hold more data than necessary for that purpose.

Data Protection Laws and Regulations means, in the European Union, the General Data Protection Regulation(GDPR) 2016 / 679 and the national statutory legislation passed in each Member State implementing this Directive, as well as national law that exists outside the EU in each country.

European Union – means the current EU Member State countries of:

Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and the United Kingdom.