Privacy Notice

Last Updated: August 24, 2018

The Sandals Foundation is a charity whose role is to raise funds and work on projects to assist in a number of welfare and sustainability projects in the Caribbean and around the world.

Unique Travel Corp ("Unique") is the worldwide representative for the Sandals Foundation. Unique is committed to protecting your privacy and this Privacy Notice sets out what personal data we collect, how we collect it, what we use it for and who we share it with.

By "personal data" we mean information about you which could identify you such as your name and contact details and your donation history. Personal data does not include data where you can no longer be identified from it such as anonymised aggregate data.

For the purposes of data protection legislation, Unique is considered the "data controller" of personal data processed in connection with this Privacy Notice. This means that we are responsible for deciding how we hold and use personal data about you. Our address is Calle Aquilino De Guardia, No. 8, Igra Building, Panama, Republic of Panama. As Unique is established outside of the EEA, we are required to appoint an EU representative for the purposes of providing an EU based point of contact. Our EU representative is Unique Caribbean Holidays Limited and their address is 32 St Ives Street, London, SW3 2ND. Should you have any questions about this Privacy Notice you can contact us at privacy@uniquecaribbean.co.uk

We have appointed a data protection officer (DPO) to oversee our data privacy matters. If you have any questions about this privacy notice or how we handle your personal data, please contact the DPO at privacy@uniquecaribbean.co.uk.

This Privacy Notice applies to personal data about you that we collect, use and otherwise process in connection with your relationship with the Sandals Foundation as a donor or potential donor or volunteer in one of our community projects or voluntourism tours, including when you use our website sandalsfoundation.org or donate through third parties such as travel agents and tour operators, or engage with the Sandals Foundation at a Charity fair or Trade event we are attending.

Where you provide us with personal data of others, for instance, making a donation on behalf of or in the name of a friend(s) or relatives please provide those persons with a copy of this Privacy Notice.

What information do we collect about you and what do we use it for?
The types of personal data about you we may collect, store and use are set out in the table below and in each case we have specified what we use it for and our ‘lawful basis’ for processing it. The law specifies certain ‘lawful bases’ under which we are allowed to use your personal data. Most commonly, we will rely on one or more of the following lawful bases for processing your personal data:

  1. Where we need to comply with a legal obligation;
  2. Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
  3. Where you have consented to us doing so.
Category of personal data What we use this data for Lawful basis

Personal contact details including name, contact number, e-mail address, postal address

Contacting you if necessary in relation to the donation and processing your donation. Fulfilling brochure requests

Contacting you with updates and latest information (if you have consented to us doing so)

Handling complaints

Managing our relationship with you

Our legitimate interests in processing donations.

Our legitimate interests in providing you with information about community projects, developing and growing our charity efforts

Our legitimate interests in customer care and handling your complaint

To comply with our legal obligations

Our legitimate interests in maintaining our donors’ accounts and records

Payment card information

Processing your payment for the donation

Our legitimate interests in collecting the funds from your donation

Name of your host resort

Identifying the resort at which you made your donation

Our legitimate interests in collecting and processing your donation

Information about how you use our website (for example, the pages you visit and how you navigate through our website)

To use data analytics to improve our website, community projects/services, donor relationships and experiences

Processing is necessary for the purposes of our legitimate interests to define donors for our community projects/services, to keep our website updated and relevant, to develop our programs and to inform our Community Projects

Information about your location based on your IP address

Knowing the country you are in helps us to provide you with more relevant content. We also use this information to analyze how our website users interact with our websites.

Processing is necessary for the purposes of our legitimate interests in providing you with relevant content and studying how our website users interact with our websites.

Special categories of personal data
Certain categories of personal data, such as race, religion or health, are considered to be “special categories” of personal data as they are more sensitive types of data. We try to limit the circumstances where we process special categories of personal data as much as possible, however, we may also occasionally collect, store and use the special categories of personal data set out in the table below.

"Special categories" of more sensitive personal data require higher levels of protection whereby we need to have further justification for collecting, storing and using this type of personal data. We may process special categories of personal data with your explicit consent. Less commonly, we may process this type of information where it is needed in relation to legal claims.

Category of special category personal data What we use this data for Lawful basis

Dietary requirements revealing or suggesting a religious or philosophical belief or a health condition.

Minimising health risks (e.g. allergic reactions) and accommodating donor preferences when joining a community project or voluntourism tour/program

Your explicit consent

Relevant medical information such as current medications taken and/or physical disability

In case of an emergency
Minimizing health risks or discomforts when joining a community project or voluntourism tour/program For your safety

Your explicit consent

You may also have made other requests in relation to your involvement in a community project or voluntourism tour/program that may contain or suggest some details about you that could be data special category of data. For instance, if applicable, you may request that special meals are available to you in the community project site or voluntourism tour, which could imply or suggest that you hold particular religious beliefs or have a particular medical condition.

By providing us with special categories of personal data you explicitly consent to our collecting, using and sharing this information with third parties and transferring such data outside of the EU as described in this Privacy Notice. We do not require you to provide us with special categories of personal data, however, if you do not do so we are unlikely to be able to accommodate your needs. Similarly, if you withdraw your consent (see Right to withdraw consent below) we are unlikely to be able to accommodate your needs.

Please note that we may use your personal data without your knowledge or consent, in compliance with the above rules, if we are required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

What if you do not provide the personal data we request?
If you do not provide us with certain information when requested, we will not be able to process your donation.

Change of purpose
We will only use your personal data for the purposes for which we collected it (as identified above in the What we use this data for column), unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

How do we collect this information?
We typically collect personal data about you when you donate to the Sandals Foundation (either directly from you or from our tour operators and travel agents), when you are involved in a community project or voluntourism tour/program and when you use our website. For example:

  • When you donate on the Sandals Foundation’s website (sandalsfoundation.org)
  • When you donate via a tour operator or travel agent
  • When you donate through Sandals call centres or customer care agents
  • When you donate through Sandals, Beaches or Grand Pineapple Resorts
  • When you donate through Island Routes Caribbean Adventure Tours (the tour provider company we use in the Caribbean)
  • If you choose to interact with us via social media
  • When you visit our website you may directly give us some personal data and we may also automatically collect certain data such as technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see the below Cookies section for further details.

In addition, we may receive personal information about you from third parties, such as:
• Donor programmes like online fundraising platforms

Cookies
A cookie is an element of data that is stored on a user's computer. It may be used to identify the device you use to access the website to help us improve and deliver a more personalised service based on browsing style. We use both session ID cookies and persistent cookies. For the session ID cookie, once users close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on the user's hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file instructions.

Types of Cookies:

Category 1– Strictly Necessary Cookies: These cookies are essential for the operation of our web site. These cookies enable services you have specifically asked for such as a donation. These cookies remain on your device only until you close your browser after visiting our web site. This cookie is destroyed at the end of the user’s visit.

Category 2 – Performance Cookies: These cookies collect anonymous information about how visitors use a web site, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a web site works. This cookie is destroyed at the end of the user’s visit.

Category 3 – Functionality Cookies: These cookies remember choices you make to improve your experience. These cookies remain on your device for an extended period of time. When you revisit our web site, we recognize these cookies and remember your preferences and choices such as your user name to log on to the website. Personal information on our system may be associated with these cookies but the cookies themselves do not contain any of your personal information. This type of cookie may also gather information about your computer, IP address and your operating system and browser type in order to enhance your experience.

By using our website you agree that we can place these types of cookies on your device. These cookies can be removed or blocked by following Internet browser help file instructions. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our websites.

Who will it be shared with?
We may share your personal data with third-party service providers and other entities within our group where this is required by law, where it is necessary to process your donation or where we have another legitimate interest in doing so.

We will need to share your personal data with others including:

  • Other entities within our group who participate in the donation process;
  • Our donation system providers;
  • Our tour provider if you choose to join a voluntourism tour/program;
  • Third party service providers we are using to provide services that involve data processing such as IT and system administration services;
  • Third parties we have engaged to run donor surveys on our behalf;
  • Professional advisers including our legal teams (both internal and also external law firms), bankers, auditors and insurers to the extent such information is relevant to the performance of their services

We will share your personal data with other entities in our group who participate in the donation process as part of our regular reporting activities in non-for profit performance, in the context of a charity arm reorganisation or restructuring exercise, for system maintenance support and hosting of data.

We may share your personal data with third parties, for example in the context of the possible restructuring of the Sandals Foundation. We may also need to share your personal data with a regulator or to otherwise comply with the law or a judicial process. We may disclose your personal data if we are required by law to do so or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

We may transfer the personal data we collect about you to Canada where our servers are located for our legitimate interests in hosting all data on our central servers there. There is an adequacy decision by the European Commission in respect of Canada which means it is deemed to provide an adequate level of protection for your personal data.

Your personal data may also be transferred to Honduras and India where our database maintenance teams are located for our legitimate interests in other Caribbean Islands maintaining such database. These countries may not have the same standard of data protection laws as the EU.

However, to ensure that your personal data does receive an adequate level of protection we will put in place appropriate safeguards such as the EU-approved standard contractual clauses to ensure that your personal data is treated in a way that is consistent with and which respects the EU and UK laws on data protection. If you require further information about this protective measure you can request it from privacy@uniquecaribbean.co.uk.

How long will we retain your information?
We will only retain your personal information 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 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.

Generally, we will keep information relevant to our dealings with you for seven years once you have ceased being a donor.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you as it is no longer personal data

Once we no longer require your personal data for the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. We will securely destroy your personal data in accordance with applicable laws and regulations.

Your rights in relation to your information
It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us, for example, if you move house.

You have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:

  • Request access to your personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
  • Request rectification of your personal data;
  • Request the erasure of your personal data;
  • Request the restriction of processing of your personal data;
  • Object to the processing of your personal data;
  • Request the transfer of your personal data to another party.

If you want to exercise one of these rights please contact us at privacy@uniquecaribbean.co.uk.

You also have the right to make a complaint at any time to a supervisory authority for data protection issues

Fees
You will not usually 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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact privacy@uniquecaribbean.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) you originally agreed to unless we now have an alternative legal basis for doing so.

Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will make an updated copy of such privacy notice available on our website and notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.