Privacy Notice

R3 Cayman Foundation (R3) is committed to being a responsible custodian of the information you provide to us and the information we may collect from you. R3 takes its responsibilities around the correct collection, use and destruction of personal information very seriously and is committed to openness and fairness in the handling of that information. We aim to be clear when we collect information about you and not do anything you wouldn’t reasonably expect.

This privacy notice (Notice) sets out how R3 as a data controller may collect, use and share information and describes:

·            Who we are;

·            The types of information, including personal information, we may collect;

·            How we collect that information;

·            How we may use and share the information we collect;

·            Cookies;

·            The legal grounds for using personal information;

·            The measures we have in place to protect and safely store the information we collect;

·            Retention of the information we collect;

·            Your choices and rights in respect of the information we hold;

·            How to contact us;

·            Complaints; and

·            Changes to this Notice.

Who we are

R3 is a Cayman Islands Foundation Company. Established in May 2020 in response to the unprecedented human and economic hardship resulting from the COVID-19 pandemic, R3 is a private sector-led organisation committed to the sustainable future of the Cayman Islands through readiness, relief and recovery in times of crisis. 

A registered non-profit, R3 brings together a diverse group of business and community leaders to support and strengthen Cayman’s response in the event of a natural or manmade crisis.

The types of information we collect

"Personal Information" is any information that can be used to identify you or that we can link to you as an individual.

In order to collect donations and provide funding of grants in support of our work we may collect and process some or all of the following data about donors, applicants for grants and recipients of grants:

Information you provide to us:

The personal information we collect may include:

·            Full name, date of birth, gender;

·            Contact details including postal and physical address, email address, phone numbers, mobile telephone numbers;

·            Information concerning your identity including passport, driving licence, photographic identity, and other Know Your Customer information;

·            Company or organisation details including details of officeholders.

·            We may also collect information that you voluntarily provide to us, including when you communicate with us via email, phone, on social media or other channels and when you respond to our communications or requests for information;

·            For managing events, marketing and promoting the work of R3, we may collect and process your name, title, postal address, contact details, email address, phone number and links to social media accounts.

Information we collect or generate about you:

·            “know your customer” and source of funds information to substantiate any donations or grants;  

·            information to identify and authenticate you;

·            information included in our grant application form;

·            due diligence checks, sanctions and anti-money laundering and counter-terrorism checks in connection with the verification of your identity;

·            information that we need to support our regulatory obligations, including detection of any suspicious and unusual activity and information about parties connected to you or these activities;

·            records of correspondence and other communications between us; and

·            information we collect automatically through cookies and similar tracking technologies through our website r3foundation.ky (Website)

 

Information we may collect from third party sources:

We may receive information about you from other sources, including third parties that help us prevent or detect fraud or process payments.

How we use the information we collect

We may use the information we collect:

·            to conduct know-your-client and anti-money laundering and other sanctions checks;

·            to request source of funds documentation to verify the source of any donations;

·            to manage our relationship with you, respond to your enquiries or to any problems that may arise and to investigate and resolve complaints;

·            to inform you of important changes or developments;

·            to conduct surveys and process your response to any survey you participate in for research, evaluation and statistical purposes;

·            to undertake data analytics to better understand your circumstances;

·            to protect our legal rights and comply with our legal obligations;

·            to correspond with third party advisors and intermediaries;

·            for insurance, audit and administrative purposes;

·            to send you marketing communications, and other information or materials that may be of interest you or which you have expressed an interest in receiving (and subject to your ability to opt-out from receiving those communications);

·            for internal development of our Website;

·            for our internal business purposes, including data analysis; and

·            as we believe reasonably necessary, advisable or appropriate to comply with our legal or regulatory obligations and to respond to legal, regulatory or government process or requests for information issued by government authorities or other third parties or to protect your, our, or others’ rights.

How we may share the information we collect

R3 will only use the information we collect for the purposes for which it was obtained. We will not under any circumstances sell or rent your data to any third party, and you will not receive marketing from any other companies, charities or organisations as a result of giving your details to us.

We may also disclose information we collect:

·            To financial institutions which hold donations and manage our bank accounts;

·            To our third party service providers that perform services on our behalf, including our auditors, web-hosting companies, analytics providers and information technology providers, or which have reporting obligations in relation to R3. In these circumstances we will always endeavour to put contractual and other technical and security safeguards in place with the third party service provider, including to ensure that your personal information is processed only in accordance with this Notice.

·            To law enforcement, other government authorities, or third parties (within or outside the jurisdiction in which you reside) as may be permitted or required by the laws of any jurisdiction that may apply to us, as provided for under contract, as we deem reasonably necessary to provide our charitable purposes or if we believe your actions are inconsistent with our agreements and policies. In these circumstances, we will take reasonable efforts to notify you before we disclose information that may reasonably identify you or your organisation, unless prior notice is prohibited by applicable law or is not possible or reasonable in the circumstances.

We may also disclose the date and amount of each donation that R3 receives (but not the names of individual donors) to the Kenneth B. Dart Foundation pursuant to the agreement that it will commit to matching donations made to R3 up to CI$4million.

Cookies

When you visit our Website, we use cookies to automatically collect information about how you use our site. Cookies are small text files that websites use to store information about things like user preferences. We use cookies on our Website to:

·            help make the Website easier to use;

·            help people share our content via social media;

·            help us understand how the Website is being used so that we can identify areas that are working well and areas that need improvement.

Our Website uses Google Analytics, a service which transmits website traffic data to Google. This does not identify individual users or associate your IP address with other data held by Google. We use reports provided by Google Analytics to help us understand web traffic and webpage usage.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Website.

Grounds for using your personal information

We rely on the following legal grounds to process your personal information, namely:

·            Necessity for performance of a contract – We may need to collect and use your personal information to enter into a contract with you or to perform a contract that you have with us;

·            Legal obligation – We may process your personal information as may be required to comply with any legal or regulatory obligations that may apply to us.

·            Legitimate interests – We may use your personal information for our legitimate interests to improve our services. Consistent with our legitimate interests and any consents that may be required under applicable laws, we may use technical information as described in this Notice and use personal information for our marketing purposes provided that those interests are not outweighed by your interests, rights and freedoms.

·            With your consent - We may use personal information as described in this Notice subject to your consent.  To withdraw your consent you can contact us via our Contact Us page, or you may be able to disable the sharing of location information in your browser or mobile application settings. Where required by applicable laws, we will rely on your consent for direct marketing and to collect information from your device or computer.

Protection and storage of the information we collect

We deploy administrative, technical and physical safeguards designed to comply with applicable legal requirements and to safeguard the information that we collect. This includes, when required or appropriate and feasible, obtaining written assurances from third parties that may access your data that they will protect the data with safeguards designed to provide a level of protection equivalent to that adopted by us.

No information system can be 100% secure.  We cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the internet and wireless networks.

We may store the information we collect in on our servers, both cloud based or in servers located in secure data centres within the Cayman Islands but also in countries where we or our service providers have facilities. Therefore, we may transfer information to countries outside the Cayman Islands or your country of residence which may have data protection laws and regulations that differ from those in your country.

Retention of the information we collect

We retain the information we collect for no longer than is reasonably necessary to fulfil the purposes for which we collect the information and to comply with our legal obligations.

Personal information related to the application and management of donations and successful grant applications will be retained for at least seven years.

If you request that we stop sending you marketing materials we will keep a record of your contact details to enable us to comply with your request not to be contacted.

Your choices and rights

Under local law, you may have certain rights regarding your personal information that we have collected. You have the right to request (i) access to your personal information, (ii) rectification or erasure of personal information, (iii) restriction of processing concerning you, and (iv) objection to processing that is based upon our legitimate interests. Your ability to exercise these rights will depend on a number of factors and, in some instances, we will not be able to comply with your request, for example because we have legitimate grounds for not doing so or where the right does not apply to the particular information we hold on you. If you would like to discuss or exercise the rights you may have, you can contact us through the methods stated below.

It is important that any personal information we hold about you is accurate and current. Please keep us informed if your personal information changes whilst we continue to retain such information. If you provide information for another person you will need to direct them to this Notice. If we need that person’s consent, we will ask you to confirm that you have obtained such consent. We encourage you to contact us to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate or out of date. You can also ask us to see what personal information we hold about you and to erase your personal information if it is no longer required. You may also tell us if you object to our use of your personal information.

How to contact us

If you would like to contact us regarding this Notice please send us an email to data_protection@r3foundation.ky In each case, to ensure your query is dealt with as swiftly as possible, please include as the subject or heading line “Privacy Notice.”

We may also be contacted at:

Appleby Global Services (Attn: Corporate Services Department)
71 Fort Street
P.O. Box 190
Grand Cayman, KY1-1104

Complaints

We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If you would like to contact us, please use the methods stated above.

If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to complain to the Ombudsman or the relevant data protection authority in your jurisdiction.

Cayman Islands Ombudsman
3rd Floor, Anderson Square,
64 Shedden Road,
George Town,
Grand Cayman

info@ombudsman.ky
+1 345 946 6283

Changes to this Notice

We may update this Notice from time to time and we encourage you to periodically review this Notice. If we make any material changes to this Notice we will notify will notify you by placing a prominent notice on our Website.

We keep our Privacy Notice under regular review. This Privacy Notice was last updated in July 2