compass media privacy policy

Compass Media Privacy Policy

Introduction

Compass Media Ltd and its affiliates (“we”, “our”, “Compass Media”) are committed to bringing you (“you”, “your”, the “user”) the best possible online experience that we can provide. One important aspect of that experience is ensuring that you are aware of when and how Compass Media collects information about you and how that information is used.

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.

Please note that sometimes our websites may contain links to third party sites, which may have their own privacy policies. If you follow a link to a third party, you should read the privacy policy shown on that site.  We are not responsible for the content or data protection practices of these linked sites.

Compass Media Privacy Pledge

Your data protection rights are important to us and we are committed to being clear with you about how we use your personal information.

We commit to:

  • comply with relevant data protection legislation from time to time in place;
  • carefully consider the legal reason(s) for using your data and where necessary ask your permission;
  • put in place controls to protect your information;
  • choose suppliers and partners who share our data protection values;
  • retain your information only as long as there is a legal or business need to do so; and
  • continue to examine how we can provide clarity to our users about our use of personal information.

About this Policy

This Policy explains how we collect, use, share and transfer your personal information when you use the services provided on our websites (“websites”).  It should be read in conjunction with our Terms of Use and Compass Media Community Guidelines[KM1] .

Personal information is any information about you by which you can be identified, including, but not necessarily limited to:

  • your name, date of birth, email address, postal address, phone number, mobile number;
  • payment details, including bank and card details;
  • information about your device;
  • information relating to your personal circumstances or opinions; and
  • how you use our websites and services.

About Compass Media

Compass Media Ltd and its affiliated companies (listed below) will collect, use, share and disclose or otherwise process your information in accordance with this Policy. 

Importantly, some laws (including the Cayman Islands Data Protection Law) distinguish between a “controller” and a “processor”. We note that Cayman Media Ltd is a “controller” for those services where we make decisions on how your personal information is used in connection with our services and, in those circumstances, we are responsible for the obligations of a controller under applicable laws in connection with the processing of personal information.  

  • Compass Media Ltd websites include compassmedia.ky, journal.ky, insideout.ky, flava.ky, caymanhealth.com, grandcaymanmagazine.com, whatshot.ky, caymanfinancialreview.com, keytocayman.com[, other] and other associated sites, including any e-commerce sites, may from time to time be created by or for Compass Media Group or its affiliates[KM2] .
  • Compass Media Ltd affiliates include:  Compass Media Ltd, Compass Media Services Ltd, Compass Media Holdings Ltd, Sluzba Ltd, Atlas Cayman Ltd and all parent, sister or subsidiary companies any entity listed here from time to time.

Information collected

We collect personal information when you provide it to us. For example, when you subscribe online, fill out our online forms, enter a competition or promotion, or pay for an advertisement.  We also collect personal information when you browse our websites.

For the avoidance of doubt we do not collect special categories of data – such as information about your race, political opinions, religion, health or sexual orientation – unless you have chosen to provide that information to us.  Our websites are not intended for children under the age of 18 and we no not intentionally collect or use information from children.

Compass Media account registration

When you register for a Compass Media account we collect your name and email address and, should you choose to provide it, certain other information, including your photographic image, date of birth and contact information. 

Please note that, where you create an account or make a payment, it is your responsibility to choose a secure password and keep it confidential.  Sending information via the internet is never completely secure and, whilst we do our best to protect your personal information, we cannot guarantee the security of any personal information sent to our website and you provide it at your own risk.

Use of our websites

When you use our websites we may also use cookies or similar technology to collect extra data, including:

  • your IP address – a numerical code to identify your device and which can provide information about the country, region or city where you are based;
  • your usage, including browsing history, information on how you were referred to our websites, user movements, and your engagement with advertisements; and
  • details of your device, to show you the best version of the site.

Subscription and classified advertisement purchase

You can renew your subscription to the Cayman Compass Media[KM5]  or place a classified advertisement online and, in processing that purchase, we collect personal information, including payment information and information required to approve the payment. We only use payment information for the express purpose for which you provide it and do not share it internally or externally for any other purpose.

Community interaction

If you correspond or interact with other users or our staff, for example by using online polls or making online comments we may display this content indefinitely in any relevant context, subject to our editorial judgement and your rights as set out in this Policy and in the Compass Media Community Guidelines .

Any information about yourself or others that you post on our websites and social media pages, on platforms like Twitter, Facebook and other chat rooms, blogs and forums, will be viewed by others (including search engines), over which we have no control. You are solely responsible for the information you choose to post or otherwise make available in public areas, and in making it available, you acknowledge that it may be collected and used by third parties. When contributing to a discussion, we strongly recommend you avoid sharing any personal details, and especially information that can be used to identify you directly. We are not responsible for the privacy of any identifiable information that you post in our online community or other public pages of our websites.

Sign in via social media  

If you log in to our websites via a third party site, such as Facebook, that site may pass information to us, as permitted under the privacy policy for that website. Our websites may also return information about you to that site regarding your log in, such as which of our websites you visit and your use of the social media services on those websites.

If you log in with or connect to your account with us using social media, the social media service’s use of shared information will be governed by their privacy policy. If you do not want your personal information shared in this way, please do not participate in social sharing on our websites

Competitions and promotions

You may choose to enter into promotions or competitions on our websites, in which case we will require certain evidence of your identity, your contact details and your date of birth. For some competitions we may require additional information, which will typically be outlined in the relevant competition terms.

Use of information

We use personal information for a number of purposes, including the following:

  • providing the services you sign up for, including subscriptions, competitions and promotions, and related internal administrative purposes, including accounting;
  • improving and maintaining website performance;
  • personalising our services, for example, recognising you, remembering your settings, displaying personalised advertising;
  • carrying out marketing analysis to better understand what your interests and preferences are, to measure how effective our adverts are relevant to your interests and preferences;
  • selling advertising space on our websites;
  • analysing the performance of our websites and understanding how users use them;
  • ensuring security and fraud prevention;
  • making you aware of any changes to our services;
  • sending marketing communications when we have your permission, or where permitted by law;
  • responding to your queries and complaints;
  • invoicing and processing payment for our products, including subscriptions and advertising, providing details to our authorised payment processors;
  • preventing the posting of offensive or objectionable content or disruptive behavior anywhere on or to our websites;
  • recruiting, by facilitating the application process;
  • administration of competitions and promotions;
  • compliance with applicable laws and regulations and our Terms of Use.

Legal grounds for use

We will only use your personal information where we have a legal ground to do so. We determine the legal grounds based on the purposes for which we have collected and used your personal information. The legal grounds we will apply are:

  • Consent: There may be some uses of your information where we ask for your consent. For example, your consent to receive marketing emails from us. You will have the right to withdraw that consent at any time, though if you do so we may not be able to provide the product or service you have requested.
  • Fulfilling a contract: For example, to provide you with access to or process payment for your subscription or other products you have signed up for or to provide a prize to which you are entitled.   
  • For a legitimate interest: We may use your information where there is a legitimate reason to do so. For example, we may use your information where it would help achieve our business objectives or to facilitate a benefit to you or someone else. We only rely on legitimate interests if the reason for using your information is fair and lawful.  For example:
    • it is in our legitimate interests to process personal information in order for us to understand our readers, promote our services and operate our websites efficiently for the creation, publication and distribution of news and other content online and in print form, globally;
    • we will rely on our legitimate interests when we analyse what content has been viewed on our websites, so that we can understand how they are used;
    • it is in our legitimate interest to carry out marketing analysis to determine what products and services may be relevant to the interests of our users;
    • it is in our legitimate interest to check the identity of users, to ensure that comments are not made anonymously;
    • where we offer partnered features such as competitions or promotions, together with a third party, it would be in our legitimate interests to share the information you provide to us with that third party. It will usually be obvious where this is the case and we will provide you with additional information as appropriate and where appropriate, request consent;
    • in the event of a sale or transfer of our business, it would be in our legitimate business interests to provide relevant information to a potential purchaser or successor.
  • Compliance with law: In some cases, we may have a legal obligation to use or keep your personal information. There may be situations where we need to use your information to comply with legal and regulatory obligations or to defend claims.  

Whilst we may rely on one legal basis, if that is no longer available to us, we may be able to rely on another.

Information sharing

We may share your information as follows:

  • Affiliates: we may share information between the companies listed in the “About Compass Media” section above, for use in accordance with this Policy;
  • Suppliers:  we may provide information to other organisations that provide services on our behalf such as dealing with online payments and other forms of payment processing or web analytics;
  • Advertisers: we may provide information to our advertising partners and providers;
  • Other users:  where you post information on the community areas of our websites it will be available to other users;
  • Successors: we may reveal your personal information to any other organisation that buys, or to which we transfer all, or substantially all, of our assets and business. If such a transfer takes place, we will use reasonable efforts to try to make sure that the organisation we transfer your personal information to uses it in line with our privacy policy; and
  • Legal and regulatory bodies: reveal your personal information to any law enforcement agency, court, regulator, government authority or other organisation if we are required to do so to meet a legal or regulatory obligation, or otherwise to protect our rights or the rights of anyone else.

Current information sharing

We currently share information with:

  • Google Analytics – we use Google Analytics to track our website’s traffic. These cookies collect anonymous information and allow us to view how the site, section and/or article performs. We are then able to tailor the website to provide a better experience for the user, as well as optimize our website’s performance.  We collect data about our traffic via Google advertising cookies and anonymous identifiers, in addition to data collected through a standard Google Analytics implementation;
  • Hubspot – we use Hubspot for inbound marketing on our websites. Hubspot allows us to see how users interact with the websites and allows us to improve our marketing efforts. For more information about Hubspot, please visit www.hubspot.com;
  • AdButler and its affiliates:  We use AdButler to serve ads. Cookies may be used on every web page to track ad display, and/or timing between various advertisement displays.  AdButler includes servers from adbutler.com, adbutler-fermion.com, and sparklit.com;

These organisations may change from time to time without any notice to you.  However, any organisations which access your data in the course of providing services on our behalf will be required to comply with all applicable data protection laws and we may, from time to time, review our service providers to make sure that they meet our standards.  Note that we will not share your personal information with any non-affiliated company for their own marketing purposes unless we have your permission to do this.

International data transfers

In connection with the above purposes your personal information may be transferred outside the Cayman Islands, including to a jurisdiction which is not recognised by the Cayman Islands Ombudsman as providing for an equivalent level of protection for personal information as is provided for in the Cayman Islands. If and to the extent that we do so, we will ensure that appropriate measures are in place to protect the privacy and integrity of such personal information and in particular will comply with our obligations under relevant data protection laws and regulations governing such transfers, which may include:

  • entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the Ombudsman;
  • where appropriate, transferring your personal information pursuant to binding corporate rules; or
  • a transfer where the Ombudsman has decided that the recipient ensures an adequate level of protection.

Further details of the measures that we have taken in this regard and the territories to which your personal information may be transferred are available by contacting us at [email protected]

Retention

We will keep your personal information as long as it is necessary for the uses set out in this Policy or where there is a legitimate reason to do so.  We may need to retain information for statutory reasons, accounting purposes or to comply with our obligations under law or regulation.

If we no longer need your personal information in full we will make efforts to anonymise or aggregate it, thereby removing all details that identify you.

If we have asked for your consent to process your personal information and you withdraw your permission, if we have no other lawful grounds to continue with that processing, we will delete your personal information.

When you unsubscribe from marketing communications, we will keep your email address to ensure that we comply with your request.

Contact with you

From time to time we may send you emails, for example, telling you your subscription is coming to an end or confirming your order.

If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.

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 [insert email address], or by following the unsubscribe instructions in the relevant communication.

Updating and editing information

When you register for an account with us, you will receive access to your user page.  By clicking “Settings” you can navigate to:

From the “My Account” page, you can navigate to a further page and enter further, private information, which is not shared with other users (date of birth, contact information).  Provision of this information is optional.

You may update this information at any time.  You may also email us at [email protected] if you wish us to remove information.

You can change your mind about receiving marketing or other communications you receive from us, such as “Today’s News”, by contacting us at [insert email address], or by following the unsubscribe instructions in the relevant communication.

Your rights

You may have the right to:

  • access your personal information, together with information about our processing of that personal information;
  • rectify any inaccuracies in your personal information;
  • have any incomplete personal information completed;
  • erase your personal information (in certain specific circumstances); 
  • request that your personal information is no longer processed for particular purposes (in certain specific circumstances);
  • where the legal basis for processing is consent, withdraw your consent at any time;
  • object to the use of your personal information or the way in which it is processed where we have determined it to be necessary for the purposes of our legitimate interests; and
  • data portability (in certain specific circumstances).

If you want to make any of these requests, please contact [email protected]  We may need to request information from you to confirm your identity.

Note that you additionally have the right to lodge a complaint with a supervisory authority if you consider that the processing of personal information relating to you infringes data protection requirements.  The Cayman Islands supervisory authority is the Ombudsman, PO Box 2252, Grand Cayman KY1-1107, Cayman Islands, https://ombudsman.ky/data-protection.

California privacy rights

If you are a California resident, the California Consumer Privacy Act (CCPA) may provide you with additional rights regarding the use of your personal information. These rights include:

  • The right to access the personal information we process about you;
  • The right to know what personal information is collected about you and if any information is sold or disclosed, and to whom;
  • The right to request the deletion of your personal information, if applicable;
  • The right to opt-out from the sale of your personal information, if applicable; and
  • The right to not be discriminated against for exercising any of the rights above.

You can exercise any applicable rights by emailing [email protected] or contacting us at [email protected] You may be required to submit proof of your identity and/or address, if we are unable to confirm your identity or cannot verify that you are a California resident. We endeavour to respond to a verifiable consumer request within 45 days. You may also designate an authorised agent to make a request on your behalf, subject to proof of identity and authorisation.

Changes to this Policy

This Policy is effective 1 March 2020.

Any changes to the Policy will be posted on this page.  If changes are significant, we may choose to notify you by email or indicate on our homepage that the Policy has been updated.