The Caymanian Journal Ltd (“we”, “us”, “our”) operates a news and media website and related digital services (the “Services”). In this privacy and cookies policy (“Privacy Policy”), we refer to our website and any webpage hosted by us under the caymanianjournal.ky domain as the “Website” or “site”.

We are committed to protecting your privacy and handling your personal data in a lawful, fair, and transparent manner.

This Privacy Policy explains how we collect, use, share, transfer, store and protect your personal data when you use our Website, read our content, subscribe, comment, or interact with advertisements and analytics systems.

By using our Services, you agree to the practices described in this Privacy Policy.

The Caymanian Journal Ltd is the data controller and responsible for your personal data in connection with your use of the Services.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the information set out in the contact details section below.

1. Legal Framework

We process personal data in accordance with the Cayman Islands Data Protection Act (2017 Revision) and, where applicable, internationally recognised data protection principles, including the European Union General Data Protection Regulation (GDPR).

2. Information We Collect

We use different methods to collect data from and about you including through:

a. Information you provide to us directly

• Name
• Email address
• Telephone number (if provided)
• Postal address (if provided)
• Subscription or account details (if you set up an account on our site)
• Information submitted to our site or us via forms, surveys, competitions, correspondence or otherwise

b. Comments and public interaction data

When you comment or interact with content on our site, we may collect:

• Display name or username
• Email address (which will not be publicly visible)
• Comment content
• IP address and browser user agent (for spam and abuse prevention and analysing use of our site)
• Timestamp and moderation history

Approved comments may be publicly visible.

c. Technical and usage data

When you visit and interact with our site, we may also collect technical information, including:

• IP address
• Device type and operating system
• Browser type
• Pages visited and time spent
• Navigation, click behaviour and other page interaction information
• Referring website or link
• Other technical information about your visit such as Uniform Resource Locators (URL), clickstream to, through and from the site, download errors, and methods used to browse away from the website.

d. Advertising and analytics data

• Cookie identifiers
• Approximate location (derived from IP address)
• Advertising interaction data (views, clicks, engagement)
• Browsing behaviour used for analytics or advertising optimisation

3. How We Collect Information

We collect personal data when you:

• Browse or interact with our Website
• Subscribe to newsletters or alerts
• Submit comments or forms
• Enter competitions or promotions
• Contact us directly via any available method
• Give us feedback or complete surveys
• Engage with advertisements or embedded content on our site

We also collect data automatically using cookies, analytics tools and advertising technologies.

4. How We Use Your Information

We may use your personal data in order to:

a. Provide and operate our Services

• Deliver news content and Website functionality
• Set up accounts
• Manage subscriptions and communications
• Enable commenting and user interaction
• Enable participation in prize draws, competitions or surveys

b. Improve our Services

• Analyse readership and engagement
• Improve content, layout and performance of the site
• Understand audience interests
• Develop, tailor and improve our Services

c. Advertising and monetisation

• Display advertisements (including contextual and interest-based advertising where permitted)
• Measure advertising performance
• Prevent fraud, invalid traffic or misuse
• Support advertising partners and networks

d. Communication

• Respond to enquiries, requests or complaints
• Send newsletters or updates (with your consent to the extent required)
• Communicate with you in connection with the delivery of our Services (with your consent, to the extent required)
• Market our Services to you (with your consent)

5. Legal Basis for Processing

We are required to have a legal basis for collecting and using your personal data. We process personal data under the following lawful bases:

• Consent — where we have obtained your agreement (e.g. newsletter subscription, certain cookies, marketing)
• Contractual necessity — where we need to perform a contract between you and us (e.g. subscriptions or services requested)
• Legitimate interests — where it is necessary to conduct our business and pursue our legitimate interests, including to prevent fraud/misuse/harm and enable us to provide our Services securely (e.g. analytics, advertising, site improvement, security). In this case, we will take into account any potential impact on you and your rights before we process your personal data for our legitimate interests and will not use personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation — where we are required to comply with any applicable laws we are subject to or a legal duty

6. Cookies and Tracking Technologies (Cookie Policy)

We use cookies and similar technologies to improve user experience, analyse traffic and support advertising.

6.1 What are cookies?

Cookies are small text files stored on your device that help websites function and collect information about user activity.

6.2 Types of cookies we use

Essential cookies

• Required for website operation
• Enable core functions such as page navigation and security

Analytics cookies

• Help us understand how users interact with our website
• Track pages visited, time spent and navigation patterns
• Example tools may include Google Analytics or similar services

Advertising cookies

• Used to deliver and measure advertisements
• May support interest-based advertising
• Help limit repetitive adverts and track performance

Functional cookies

• Remember user preferences (e.g. language or display settings)

6.3 Third-party cookies

Some cookies are placed by third parties such as:

• Analytics providers
• Advertising networks
• Social media platforms (embedded content or sharing tools)

These third parties may collect data about your browsing activity across different websites.

6.4 Managing cookies

You can:

• Accept or reject cookies via browser settings
• Delete cookies at any time
• Adjust tracking preferences in your device or browser

Disabling certain cookies may affect website functionality.

6.5 Consent

Where required by law, we will request your consent before placing non-essential cookies.

7. Comments and User Content

When you post comments:

• Your name and comment may be publicly visible
• We may store your IP address for moderation and spam prevention
• We may use automated systems to detect abusive or spam content
• We reserve the right to moderate, edit or remove content

8. Sharing of Personal Data

We do not sell personal data.

We may share your personal data with third parties where necessary in connection with the uses set out above in section 4, including:

• Service providers (hosting, analytics, email delivery, advertising systems)
• Professional advisers (legal, financial, technical)
• Regulators or authorities where required by law or regulatory requirements
• Third parties in connection with business transfers or restructuring

All third parties are required to protect your data appropriately in compliance with all applicable laws.

9. Data Retention

We retain personal data only as long as necessary for:

• Operational and editorial purposes
• Legal and regulatory compliance
• Security, fraud prevention and dispute resolution

Comments and associated metadata may be retained indefinitely unless removal is required.

10. Data Security

We use appropriate technical and organisational measures to protect your data, including:

• Secure servers and access controls
• Monitoring for unauthorised activity
• Data protection agreements with service providers

However, no system is completely secure, and we cannot guarantee absolute security.

11. Your Rights

You may have the right to:

• Access your personal data
• Correct inaccurate information
• Request deletion of your data
• Object to or restrict processing of your personal data
• Withdraw your consent
• Lodge a complaint with the Cayman Islands Ombudsman or any other relevant authority

To exercise these rights, please contact us at the contact details in section 17 below.

12. Third-Party Links and Embedded Content

Our website may contain links or embedded content from third-party sites. We are not responsible for any content from third-party sites or for their privacy and information security practices.

13. Children’s Privacy

Our Services are not intended for individuals under 16. We do not knowingly collect personal data from children without appropriate consent.

14. International Data Transfers

Your data may be processed in the Cayman Islands or other jurisdictions where our service providers operate.

This may involve transferring personal data outside the Cayman Islands to countries which have laws that do not provide the same level of data protection as under Cayman Islands law. In that case, we will take appropriate safeguards to protect transferred data, including:

• transferring personal data to countries that are deemed to provide an adequate level of protection for personal data, such as the United Kingdom and European Union countries; or
• using specific standard contractual terms approved for use by the Cayman Islands Ombudsman; or
• implementing other safeguards and transfer mechanisms (such as transferring data to recipients subject to a recognised code of conduct or certification regime).

15. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised date. Continued use of the Services indicates acceptance of changes.

16. Retention

We will only retain your personal data for so long as there is a reasonable need to retain the information for the purposes we collected it for, or to comply with legal, accounting, tax or operational/security requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Comments posted on our site may be retained indefinitely or so long as our site is live, unless you make a request for such content to be deleted.

17. Contact Us

If you have any questions or requests regarding this Privacy Policy or your personal data, please contact us:

Email: law@caymanianjournal.ky

Postal Address:
P.O. Box 31910
Grand Cayman KY1-1208
Cayman Islands

18. Complaints

If you have a complaint regarding our processing of your personal data, you may submit a complaint to complaints@caymanianjournal.ky or write to:

The Editor-in-Chief
The Caymanian Journal.
P.O. Box 31910
Grand Cayman KY1-1208
Cayman Islands

Complaints will be handled in accordance with applicable law and our complaints handling policy.

You are also entitled to make a complaint to the Cayman Islands Ombudsman, who is the responsible authority for data protection in the Cayman Islands, by contacting info@ombudsman.ky.