1.  INTRODUCTION  

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.caribbeanfootsteps.org and associated microsites, including any information you may provide through our site when you make a donation to us using our online portal, sign up to our newsletter or take part in interactive elements. See also our Terms and Conditions and Cookies Policy.

By providing us with your data, you warrant to us that you are over 13 years of age.

Caribbean Footsteps International Trust (‘Caribbean Footsteps’) is the data controller and we are responsible for your personal data (referred to as ‘we’, ‘us’ or ‘our’ in this privacy notice).

We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.

Contact Details

Our full details are:

Full name of legal entity: Caribbean Footsteps Incorporated (a US-based registered 501(c)(3) charity, no. TBU)

Name of Data Protection Officer: Carrol Iszard

Email address: info@CaribbeanFootsteps.org

Postal address: 10 Saddletree Lane, Harrison NY 10528.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@CaribbeanFootsteps.org

2.  WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

• Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.

• Contact Data may include your billing address, delivery address, email address and telephone numbers.

• Financial Data may include your bank account and payment card details.

• Transaction Data may include details about payments between us and other details of purchases made by you.

• Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.

• Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.

• Usage Data may include information about how you use our website, products and services.

• Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

We may also process aggregated data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

Sensitive Personal Data

We do not collect any sensitive data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to provide services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have requested but if we do, we will notify you at the time.

3.  HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

• Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
  • order our products or services;
  • create an account on our site;
  • subscribe to our service or publications;
  • request resources or marketing be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback.
    
• Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy at www.caribbeanfootsteps.org/cookies for further details.
  
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below
  • Technical Data from parties such as Amazon Web Services or analytics providers such as Google based outside the US;
  • search information providers such as Google, based outside the US;
  • Contact, financial and transaction data from providers of technical, payment and delivery services, eg Stripe;
  • Identity and contact data from publicly available sources

4.  HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data when legally permitted. The most common uses of your personal data are:

• Where we need to perform a contract between us.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a lawful basis for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at info@CaribbeanFootsteps.org or by using the personalised link provided toward the bottom of any newsletter mailing you may receive.

Purposes for processing your personal data  

Set out below is a description of the ways we may use your personal data and the lawful bases on which we will process such data in each scenario. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful basis, depending on the specific purpose for which we are using your data. Please email us at info@CaribbeanFootsteps.org if you need details about the specific lawful basis we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing communications

You will receive marketing communications from us if you have requested them from us and have not subsequently opted out of receiving that marketing.

You can ask us or third parties to stop sending you marketing messages at any time by emailing us at info@CaribbeanFootsteps.org.

Where you opt out of receiving our marketing communications, this will not apply to any personal data you may have provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transaction.

Change of purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at info@CaribbeanFootsteps.org

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the lawful basis for the processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We may have to share your personal data with the third parties set out below for the purposes/activities set out in the table in paragraph 4 above:

• Other Caribbean Footsteps territories, commands, regions, divisions, corps, centres, outposts as necessary to assist with an enquiry you have initiated or delivery of a service you have requested from us.
• Service providers who provide IT and system administration services
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Third parties with whom we have a legal and established working relationship, in order to provide services requested.

We require all third parties to whom we transfer your personal data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6.  INTERNATIONAL TRANSFERS

Where necessary, we share your personal data within Caribbean Footsteps which may involve transferring your data outside the European Economic Area (EEA)

Countries outside of the EEA do not always offer the same levels of protection for personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third party service providers are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is 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

• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

• Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the United States.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at info@CaribbeanFootsteps.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.  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 receive such data. They will only process your personal data 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.

8.  DATA RETENTION  

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, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.  

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.  YOUR LEGAL RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

You can see more about these rights at:

US: TBU

UK: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at info@CaribbeanFootsteps.org.

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.

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.

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.

10. THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins 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.

11. COOKIES  

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. For more information about the cookies we use, please see www.caribbeanfootsteps.org/cookies.

12. USER CONTRIBUTIONS

Contributions within interactive parts of the website are the opinions of the individual authors and, unless otherwise indicated by a person with the authority to speak on behalf of Caribbean Footsteps, they may not be taken to represent the official position of Caribbean Footsteps on any of the topics under discussion.

Submitting content to a Caribbean Footsteps website or social media platform constitutes granting us a non-exclusive licence to publish that material online and/or in print, including any usernames or other personally-identifying material included in the contribution.

The terms and conditions of use and the privacy policies of third-party social media platforms are not within the control of Caribbean Footsteps, and we encourage you to read the privacy notices of each social media channel you choose to explore.