Customer Privacy Policy

Scope


The privacy notice explains how C3 collects, uses, discloses, retains and secures your personal data as part of its business practices. The policy clearly articulates the legal justifications for the processing of your personal data and also lists your data subject rights under the Cayman Islands’ Data Protection Law, 2017 (“DPL”).


Overview


C3 respects your privacy, and you are entitled to have your personal data processed in accordance with the DPL. Below are the privacy principles C3 applies when processing your personal data:

  • Lawfulness: C3 will only collect your personal data in a fair, lawful and transparent manner.
  • Data minimisation: C3 will limit the collection of your personal data to what is directly relevant and necessary.
  • Purpose limitation: C3 will only collect your personal data for specified, explicit and legitimate purposes.
  • Accuracy: C3 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: C3 has implemented technical and organisational measures to ensure an appropriate level of data security and protection considering the sensitivity of the personal data it processes. Such measures provide for the prevention of any unauthorized or unlawful processing of your personal data and against accidental loss or destruction of, or damage to that data.
  • Access and rectification: C3 will process your personal data in line with your legal rights under the DPL.
  • Retention limitation: C3 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: C3 will ensure that if your personal data is transferred outside the Cayman Islands, it is adequately protected.

 

What personal data does C3 collect?


C3 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 C3 by a data subject on a social media platform such as Facebook, Twitter or a chat application such as WhatsApp.

 

How does C3 use the personal data it collects?


C3 may use your personal data to (this list is not exhaustive):

  • respond to your inquiries
  • manage our relationship with you
  • send 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
  • prevent fraud or other criminal activity
  • manage bandwidth usage
  • maintain, develop and test our network (including managing the traffic on our network), products and services, to provide you with a better service
  • train our employees to provide you with products and services
  • comply with any regulatory reporting obligations
  • prevent the use and transmission of viruses and other impediments to the provision of service to you
  • record health and safety details if there is an incident at one of C3 establishments or a C3 event

 

When does C3 disclose your personal data?


C3 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 C3 uses a third-party service provider for marketing, marketing research, payment management or client relationship management
  • 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 that or consent to your personal data being disclosed to a third party
  • to a third party that C3 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 C3 legal counsel or to other advisors including auditors and insurers
  • any other circumstance where it may be required by law or regulation

 

International transfer of personal data


All of your personal data is stored in the Cayman Islands. C3 cannot control the security of the data you willingly send outside of the Cayman Islands on its networks.

 

The legal basis for processing your personal data


The DPL sets out some different reasons for which a company may process personal data, and C3 does so under the following legal conditions:

  • Consent

In specific situations, C3 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, C3 may need to process certain your personal data to comply with contractual obligations.  For example, C3 will process your personal information to ensure that you abide by your contract, such as to ensure you are only using our networks legally or not deliberately overloading the network or server resources.

  • Legal compliance

If the law requires, C3 may need process your personal data.  For example, C3 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, C3 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. For example, C3 monitors bandwidth usage according to IP to ensure customers are not negatively affected by others who might inappropriately use too much bandwidth.

 

How long does C3 retain your personal data?


C3 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, C3 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. C3 will always hold your personal data for the least amount of time it considers necessary in accordance with its retention policy.

 

How does C3 secure your personal data?


C3 employs appropriate technical and organizational 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.

 

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 C3’s obligation in that respect. If you have further questions or concerns not addressed in the notice, please contact info@c3.ky .

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 C3 to cease processing your personal data for direct marketing purposes. If you wish to exercise any of these rights, you should contact info@c3.ky.

If you feel that your personal data has not been handled correctly, or you are not satisfied with C3 responses to any requests you have made to C3 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 info@ombudsman.ky.

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