The policy articulates the legal justifications for the processing of your personal data and sets out your data subject rights under the Cayman Islands’ Data Protection Law, 2017 (“DPL”).
We use your information to provide the products and services you request, as well as to understand how and why our users engage with us. This allows us to personalise content, show you relevant adverts, and improve your experience of our products and services.
CLEAN GAS respects your privacy, and you are entitled to have your personal data processed in accordance with the DPL. Below are the privacy principles CLEAN GAS applies when processing your personal data:
- Lawfulness: CLEAN GAS will only collect your personal data in a fair, lawful and transparent manner.
- Data minimisation: CLEAN GAS will limit the collection of your personal data to what is directly relevant and necessary.
- Purpose limitation: CLEAN GAS will only collect your personal data for specified, explicit and legitimate purposes.
- Accuracy: CLEAN GAS will keep your personal data accurate and up to date while there continues to be a customer relationship, and in certain circumstances, after that relationship has ended.
- Data security and protection: CLEAN GAS has implemented technical and organisational measures to ensure an appropriate level of data security and protection appropriate to the sensitivity of the personal data it processes. Such measures provide for the prevention of any unauthorised or unlawful processing of your personal data and against accidental loss or destruction of, or damage to that data.
- Access and rectification: CLEAN GAS will process your personal data in line with your legal rights under the DPL.
- Retention limitation: CLEAN GAS will retain your personal data in a manner consistent with applicable data protection legislation and regulation (including the DPL) and no longer than is necessary for the purposes for which it has been collected in accordance with its retention policy.
- Protection for international transfers: CLEAN GAS will ensure that if your personal data is transferred outside the Cayman Islands, it is adequately protected.
What personal data does CLEAN GAS collect?
CLEAN GAS collects various personal data about you which may include the following (this list is not exhaustive):
- name and address
- date of birth
- telephone number
- email address
- identification details (for example, your driver’s license or passport)
- details of phone usage including numbers called and duration of calls
- general Internet traffic data related to your IP address
- details of your downloads using peer to peer file sharing software
- financial information such as credit card numbers or certain banking information
- your communications with us, including emails and phone calls (and any recordings made for training or security purposes)
- details of the products and services you use and how you use them
- information voluntarily provided to CLEAN GAS by a data subject on a social media platform such as Facebook, Twitter or a chat application such as WhatsApp.
How does CLEAN GAS use the personal data it collects?
CLEAN GAS may use your personal data to (this list is not exhaustive):
- respond to your inquiries
- perform the contract with you
- manage our relationship with you
- send or process invoices and collect payment for goods or services rendered
- undertake or assist with credit and fraud prevention checks (including requesting information about you or responding to requests about you from other providers)
- conduct promotional activities
- conduct surveys
- market goods and services
- engage with you on social media platforms
- handle your complaints
- helping you access your account on sign-on
- prevent fraud or other criminal activity
- maintain, develop and test our products and services, to provide you with a better service
- train our employees to provide you with products and services
- diagnosing or fixing technology problems
- monitoring metrics, such as numbers of users, traffic and demographic patterns
- comply with any regulatory reporting obligations
- record health and safety details .
When does CLEAN GAS disclose your personal data?
CLEAN GAS may disclose your personal data in the following circumstances (this list is not exhaustive):
- on social media where you may have already made the personal data public
- if CLEAN GAS uses a third-party service provider or partner for advertising, marketing, marketing research, payment management or client relationship management
- where CLEAN GAS uses an independent contractor to carry out services on our behalf, for example, independent drivers to deliver orders
- to other market providers for the purpose of credit and fraud prevention checks
- to debt collection agencies or other third parties for the purposes of debt collection
- if you request or consent to your personal data being disclosed to a third party
- to a third party that CLEAN GAS partners with for special events so that the third party might contact attendees for marketing purposes
- if there is a legal request or regulatory, civil or criminal investigation or dispute
- if it is required to seek legal advice from CLEAN GAS legal counsel or to other advisors including auditors and insurers
- if required for auditing, insurance or other internal management purposes
- any other circumstance where it may be required by law or regulation
Change of control
International transfer of personal data
The legal basis for processing your personal data
The DPL sets out some different reasons for which a company may process personal data, and CLEAN GAS does so under the following legal conditions:
- Consent: In specific situations, CLEAN GAS may collect and process your personal data with your consent. For example, if you tick a box to receive email newsletters or information on promotions and events.
- Contractual obligations: In certain circumstances, CLEAN GAS may need to process certain your personal data to comply with contractual obligations. For example, CLEAN GAS may process your personal address information in order to deliver your order.
- Legal compliance: If the law requires, CLEAN GAS may need process your personal data. For example, CLEAN GAS may be required to disclose your personal information if there is a legal request or law enforcement or regulatory investigation.
- Legitimate interest: In specific situations, CLEAN GAS may process your personal data to pursue its legitimate interests in a way which might reasonably be expected as part of running its businesses and which does not materially impact your rights, freedom or interests.
How long does CLEAN GAS retain your personal data?
CLEAN GAS retains your personal data for as long as a customer relationship exists and the personal data is necessary to manage that relationship. When there is no longer a customer relationship, CLEAN GAS will retain certain types of personal data for varying periods depending on legal requirements and business needs. Personal data that is no longer needed will be securely destroyed. CLEAN GAS will always hold your personal data for the least amount of time it considers necessary in accordance with its retention policy.
How does CLEAN GAS secure your personal data?
CLEAN GAS employs appropriate technical and organisational measures to protect against unauthorised processing, accidental loss or destruction of, or damage to, your personal data in accordance with its Information Technology and physical security policies.
Please keep in mind that it is not possible to achieve a perfect state of data security. Although we maintain reasonable administrative, physical and electronic security measures designed to protect your personal data from unauthorised access, we cannot ensure absolute security of any information you transmit to us or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your un-encrypted electronically stored personal data.
Loyalty Card Program
CLEAN GAS may, from time to time, enter into loyalty card programs with its affiliates, including Infinity Broadband Ltd T/A C3 and the Hurley’s Group of companies (Hurley’s Food Store) (together “the Group”) in order to reward customers of these companies for their loyalty. By their nature, loyalty card programs involve the collection of personal data, including, but not limited to, name, date of birth, contact and shopping habits. The data will be used by the Group for purposes including marketing, targeted advertising, tracking customer purchases and building consumer profiles. Personal data may be shared between member companies of the Group for the same purposes. By requesting a loyalty card from any Group member company, the customer specifically acknowledges that such company will collect and process the personal data specified in the loyalty card program form as well as data regarding purchases and may share such data with the Group. If you do not wish to have your data collected, processed or shared, in this way, please do not enter any loyalty card program with any member of the Group.
Contact with you
If we have your permission, we may send you materials we think may interest you, such as new services and updates. You can decide not to receive these emails at any time by contacting us at email@example.com, or by following the unsubscribe instructions in the relevant communication.
What rights do you have in respect to your personal data?
You have a right to be informed how your personal data is processed and this privacy notice fulfils CLEAN GAS’s obligation in that respect. If you have further questions or concerns not addressed in the notice, please contact firstname.lastname@example.org.
You have rights (with certain restrictions) to request access to your personal data, request rectification/correction of your personal data, request that processing of your personal data be stopped or restricted and to require CLEAN GAS to cease processing your personal data for direct marketing purposes. If you wish to exercise any of these rights, you should contact email@example.com.
If you feel that your personal data has not been handled correctly, or you are not satisfied with CLEAN GAS responses to any requests you have made to CLEAN GAS regarding the use of your personal data, you have the right to complain to the Cayman Islands’ Ombudsman. The Ombudsman can be contacted by calling 1-345-946-6283 or by email at firstname.lastname@example.org.
Changes to policy