Last Updated: January 2019
We are a corporation registered in the Republic of Singapore with the company number 200509766G and a registered office at 99 Duxton Road, The Co., Cayman, #02-00 Singapore 089543. For the purpose of the Personal Data Protection Act (“PDPA”), we are the data controller. Our data protection officer can be contacted at firstname.lastname@example.org.
What information do we collect about you?
We collect information when you submit enquiries or when you contact us and use our services, such as contact details and other personal information. We also collect information about your preferences from your interactions with our consultants, and from the specific requests that you make. In addition, we collect device and technical information from you when you use our website or mobile application.
How will we use the information about you?
We use your information to fulfil our contract (“Proposal”) with you, to service your account with us, be it Raffles Immigration Pte. Ltd., or Singapore Corporate Advisory Pte. Ltd. and Cayman Group Holdings. We also use your information to maintain our website and mobile application, and to tailor our services to your preferences to provide the best service possible. In addition we use your information to market our services to you, and those of our group companies, partners and agents (with your consent where required by applicable law).
Who do we share your information with?
We share your data with our third party service providers to the extent necessary for them to provide their services such as translations, notarizations and so on so forth. We use these third parties services solely to process or store your information for the purposes described in this policy. We also share your information strategic alliance partners, other companies who help us provide our services, related group companies and our overseas stations and with government bodies as required by law.
Where do we process your information?
Our servers are located in Singapore.
How long do we keep hold of your information?
We retain your information for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of Cayman, or as required by relevant laws. We will usually keep your Customer Data for up to 3 years to ensure that any contractual disputes can be addressed.
How can I exercise my rights over my information?
You may have various rights in relation to your data.
If you have any concerns or complaints, please contact us at email@example.com.
How will we notify you of changes?
1. The types of Customer Data we collect
The types of Customer Data that Cayman collects depends on the circumstances of collection and on the nature of the service requested or transaction undertaken.
There are two broad categories of Customer Data that Cayman collects:
• Personal Data. The data we collect includes but is not limited to:
(i) personal information that can be used to identify an individual, such as name, gender, date of birth, passport or other personal identification numbers;
(ii) contact information, such as mailing address, phone number, email address;
(iii) your customer preferences;
(iv) information about your interactions with our consultants
(v) health information, such as doctors’ notes, medical certificates and letters and requests related to medical conditions;
(vi) information we receive from the queries you enter into our website, Facebook page and Website (as defined below);
(vii) information we receive from other sources e.g. our page on social media websites; and
(viii) business contact information, such as the contact details of the employees of our vendors and corporate customers, as well as the contact details collected by our divisions.
• Technical Data. This includes device and technical information you give us when using our website or mobile application (“Website”) such as IP addresses or other unique identifiers, cookies, mobile carrier, time zone setting, operating system and platform.
For purposes of this policy statement, Customer Data means Personal Data and Technical Data.
We also use Customer Data to derive Statistical Data, such as the number of clients. This is processed and stored purely for analytical purposes, and is entirely anonymous. This information will not be stored to your customer record, and will only be aggregated for statistical analysis so that we can better understand Cayman's customer profile and improve Cayman’s service offering.
Special categories of information or “sensitive personal data”
Certain categories of Customer Data, such as information about your race, ethnicity, religion or health, are considered special categories of information, or “sensitive personal data” under the PDPA.
Generally, we try to limit the circumstances where we collect your sensitive personal data. However, this can occasionally occur because you have made certain requests in connection with your travel arrangements that reveal or suggest something about you that could be considered “sensitive personal data”, or if you otherwise choose to provide such information to us (or a third party such as the referral through which you know us).
How we collect data from you
Cayman collects Customer Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised and/or persons who have been validly identified as being your authorised representative (e.g. your organisation’s corporate travel manager) pursuant to our then-current security procedures).
Cayman also collects Customer Data from third parties which are located in various countries. This includes, but is not limited to, travel agents, our partners, our service providers.
2. Is the provision of Customer Data required?
The collection of the following types of Customer Data is mandatory to enable Cayman to fulfil our contract of carriage with you. These types of Customer Data are marked as mandatory. If you do not provide this information, we will not be able to provide you with our services required.
• Personal details, e.g title, first/given name, last/family name, date of birth.
• Contact details, e.g. email address, mobile phone number, home number or business number.
Additional information may be mandatory e.g. your gender, nationality, passport number, the country of issue of your passport, the name, GST registration number and address of the business you are flying on behalf of, and your business email address and phone number.
These types of Customer Data are marked as mandatory on our enquiries form. If you do not provide this information, you will not be able to benefit from our service and we will not be able to provide you with our services and/or products required.
The failure to supply the following types of Customer Data will result in (i) Cayman being unable to update you on our latest services; and/or (ii) your inability to enter or participate in contests, promotions or redemption activities organised by Cayman:
• Contact Information e.g. email address, telephone number; and
• Country of residence.
3. How we use your Customer Data
We will use the Customer Data in the following ways:
In accordance with our contract with you, we will use the Customer Data to:
i process and assist you with any transactions related to our contract;
ii notify you about changes to our service;
iii. facilitate membership-related transactions and services and;
iv. send you membership status updates and other account related information.
As it is in our legitimate interests to be responsive to you, to provide customised services and marketing and to ensure the proper functioning of our products, services and organisation, we will use your Customer Data to:
• improve the Website and to ensure content from the Website is presented in the most effective manner for you and your device;
• administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• monitor and record calls for quality, training, legal compliance, analysis and other related purposes in order to pursue our legitimate interest to improve service delivery;
• send you surveys by email. You can opt-out of receiving these surveys at any time by contacting us;
• send you service emails, such as reminders when you have not responded to our reminders. You can opt-out of receiving service emails at any time by contacting us;
• respond to your enquiries, requests or feedback;
• enforce our terms, conditions and policies;
• allow you to participate in interactive features of the Website, when you choose to do so;
• customise our services to you, including by responding to and catering for your customer preferences;
• keep the Website safe and secure;
• aggregate Customer Data into anonymised statistical data, which we will use for statistical analysis so that we can better understand Cayman’s customer profile and improve Cayman’s service offering;
If you are an employee of an entity with a contractual relationship with us:
i. to contact you to perform our services, and in particular, to monitor and record calls for quality, training, legal compliance, analysis and other related purposes in order to pursue our legitimate interest to improve service delivery;
ii. enforce our terms and conditions against your employer; and
iii. communicate with you about products, services, promotions, events and other news and information we think will be of interest to you.
With your consent where required by applicable laws, we will use your Customer Data to:
• send you marketing and promotional materials in relation to products and services offered by Cayman, Cayman’s subsidiaries and affiliated airlines and service partners, as well as Cayman’s appointed agents.
4. Disclosure of your Customer Data
Cayman will share your Customer Data with selected third parties in the situations set out below:
• translation and notarization services
• advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
• analytics and search engine providers that assist us in the improvement and optimisation of the Website.
Cayman will share your Customer Data with any member of our group, which means our overseas stations and our subsidiaries in order to better customise your preferences when you sign with us.
• For the purposes of our contract with you
• As it is in our legitimate interests to be responsive to you, to provide customised services and marketing, to:
i. Respond to complaints or compliments received by Cayman from clients who are sharing their experiences
ii. Providing an enhanced customer experience and personalising services to clients;
iii. Anticipating the servicing needs of clients in contract with us;
iv. Understanding clients better through analytics and research (including marketing research) to support personalisation;
• For the purposes of undertaking targeted direct marketing and other forms of marketing or advertisement, provided we have the consent of the recipient and/or have provided the opportunity to opt-out, in each case where required by applicable law. Cayman will also use and disclose your Customer Data to persons who have been validly identified as being you or your authorised representative(s) pursuant to our then-current security procedures, for the purpose of the relevant transaction or enquiry. Cayman will disclose your Customer Data to law enforcement agencies, public or regulatory authorities, securities commissions or other organisations for security, customs and immigration purposes, if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
• comply with legal obligation, process or request;
• enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
• detect, prevent or otherwise address security, fraud or technical issues; or
• protect the rights, property, health or safety of us, our users, a third party or the public as required or permitted by law (including exchanging Customer Data with other companies and organisations for the purposes of fraud protection and credit risk reduction).
• to comply with legal obligations, processes or requests (such as disclosing Customer Data to executors in response to court orders).
In addition, Cayman may disclose Customer Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law. Cayman also reserves the right to share Customer Data as is necessary to prevent a threat to the life, health or security of an individual or corporate entities such as Cayman. Further, Cayman will disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.
You may have certain rights in relation to the Customer Data we hold about you, which we detail below.
You have the right to know whether we process Customer Data about you, and if we do, to access Customer Data we hold about you and certain information about how we use it and who we share it with.
Where permitted by law, Cayman reserves the right to charge a reasonable administrative fee for this service. In exceptional circumstances, Cayman reserves the right to deny you access to your Customer Data and may provide an explanation as required by applicable laws.
Exceptional circumstances include (to the extent allowable under applicable law) where:
• an investigating authority or government institution objects to Cayman complying with a customer’s request;
• the information may, in the exercise of Cayman’s reasonable discretion and/or assessment, affect the life or security of an individual; and
• data is collected in connection with an investigation of a breach of contract, suspicion of fraudulent activities or contravention of law.
If you require more than one copy of the Customer Data we hold about you, we may charge an administration fee.
We may not provide you with certain Customer Data if providing it would interfere with another’s rights (e.g. where providing the Customer Data we hold about you would reveal information about another person) or where another exemption applies.
You have the right to correct any Customer Data held about you that is inaccurate.
Feedback and complaints.
If you have any concerns, feedback or complaints about the use and/or sharing of your Customer Data, we are open to receiving your feedback or complaints.
You may request that we erase the Customer Data we hold about you in the following circumstances:
• you believe that it is no longer necessary for us to hold the Customer Data we hold about you;
• we are processing the Customer Data we hold about you on the basis of your consent, and you wish to withdraw your consent and there is no other ground under which we can process the Customer Data;
• we are processing the Customer Data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such Customer Data;
• you no longer wish us to use the Customer Data we hold about you in order to send you promotions, special offers, marketing and lucky draws; or
• you believe the Customer Data we hold about you is being unlawfully processed by us.
Also note that you may exercise your right to restrict our processing of the Customer Data whilst we consider your request as described below.
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. However, we may retain the Customer Data if there are valid grounds under law for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Please note that after deleting the Customer Data, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences.
Where you have requested that we erase Customer Data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the Customer Data or providing links to the Customer Data to erase the Customer Data too.
Exercise of Rights.
To exercise any of your rights, please email us at firstname.lastname@example.org.
Please note that we will require you to provide us with proof of identity before responding to any requests to exercise your rights. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances).
6. Restriction of Processing to Storage Only.
You have a right to require us to stop processing the Customer Data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the Customer Data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defence of legal claims or for another’s protection).
You may request we stop processing and just store the Customer Data we hold about you where:
• you believe the Customer Data is not accurate, for the period it takes for us to verify whether the Customer Data is accurate;
• we wish to erase the Customer Data as the processing we are doing is unlawful but you want us to just store it instead;
• we wish to erase the Customer Data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims; or
• you have objected to us processing Customer Data we hold about you on the basis of our legitimate interest and you wish us to stop processing the Customer Data whilst we determine whether there is an overriding interest in us retaining such Customer Data.
At any time you have the right to object to our processing of Customer Data about you in order to send you promotions, special offers, marketing messages, including where we build profiles for such purposes and we will stop processing the Customer Data for that purpose.
You also have the right to object to our processing of Customer Data about you and we will consider your request in other circumstances as detailed below by emailing us at email@example.com.
You may object where we are processing the Customer Data we hold about you (including where the processing is profiling) on the basis of our legitimate interest and you object to such processing.
Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. Also note that you may exercise your right to request that we stop processing the Customer Data whilst we make the assessment on an overriding interest by emailing us at firstname.lastname@example.org
Cayman will retain Customer Data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of Cayman, or as required by relevant laws. We will usually keep your Customer Data for up to 3 years to ensure that any contractual disputes can be addressed. This includes standing requests which contain sensitive personal data about yourself. You can amend your standing request at any time to change your preferences in the future.
If you opt-out or withdraw your consent to marketing, we will remove you from our marketing database.
Cayman needs your assistance to ensure that your Customer Data is current, complete and accurate. As such, please inform Cayman of changes to your Customer Data by contacting Cayman and submitting your updated particulars to Cayman through an email.
Cayman will also request Customer Data updates from you from time to time.
9. Security safeguards
Cayman takes the protection of your Customer Data seriously but, unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Customer Data, we cannot guarantee the security of your Customer Data transmitted through the Website; any transmission is at your own risk.
10. Links to other websites
Cayman’s Website is not directed at children under the age of 16 and Cayman cannot distinguish the age of persons who access and use our Website. If a minor (according to applicable laws) has provided Cayman with Customer Data without parental or guardian consent, the parent or guardian should contact Cayman to remove the relevant Customer Data and unsubscribe the minor. If we become aware that Customer Data has been collected from a person under the age of 16 without parental or guardian consent, we will delete this Customer Data and, where that minor has an account, terminate the minor’s account.
13. Contact us
Cayman Management Consultants DPO
99 Duxton Road
The Co., Cayman