Privacy Notice

1. About this notice

Caymanians First Charitable Foundation (the “Foundation”, “we”, “us”, or “our”) respects your privacy. We are the data controller for personal data collected through this website, our related communications and the administration of the Stingray Raffle.

This notice explains what personal data we collect, why we use it, who we may share it with, how long we keep it, and the rights available to you under the Cayman Islands Data Protection Act (2021 Revision) (the “DPA”).

This notice covers this public website, general enquiries sent to the Foundation and the Stingray Raffle, as described in section 15. A separate or additional privacy notice may be provided when we introduce online donations, applications, volunteer registration, or other services that require additional personal data.

2. Who we are

Caymanians First Charitable Foundation is a registered non-profit organisation in the Cayman Islands.

Registrar of Companies No.

AY-427735

NPO number

NP-721

Address

P.O. Box 31910, 20 Genesis Close, George Town, Grand Cayman

Email

[email protected]

3. Personal data we collect

Information you provide

When you email or otherwise contact us, we may collect your name, email address, telephone number, organisation, and any information you include in your message. If you choose to provide information about another person, you should have authority to do so.

Website and technical information

Our website host and security providers may automatically record limited technical information needed to deliver and protect the website. This can include an Internet Protocol (IP) address, browser and device type, operating system, requested pages, referring page, and the date and time of a request.

Information we do not currently collect through this website

As of the date of this notice, the website does not process payments, accept programme applications, create user accounts, or submit information entered into the displayed contact form. Please do not send payment-card information, medical information, or other sensitive personal data through a general enquiry.

4. How and why we use personal data

We may use personal data to:

• provide, maintain, secure, and troubleshoot the website;
• respond to enquiries and communicate with you;
• keep appropriate administrative and correspondence records;
• understand website performance using technical or aggregated information;
• establish, exercise, or defend legal rights; and
• meet legal, regulatory, safeguarding, and reporting obligations.

Depending on the activity, our processing may be necessary for our legitimate interests in operating and protecting the Foundation, to take steps at your request, to comply with a legal obligation, or because you have given consent. Where consent is the relevant condition, you may withdraw it at any time without affecting earlier lawful processing.

5. When we share personal data

We may share personal data only where reasonably necessary with:

• service providers that support website hosting, security, email, and information technology;
• Stingray Raffle Ltd (the Operator), Stingray Media Ltd (the Promoter), and the service providers they engage to process raffle data on the Foundation’s behalf;
• publishers and platform operators for winner publicity under the consent and conditions described in section 15;
• professional advisers, including legal, audit, insurance, and compliance advisers;
• regulators, courts, law-enforcement bodies, or other authorities where required or permitted by law; and
• another organisation where necessary to protect a person’s vital interests or the Foundation’s legal rights.

We require service providers processing data on our behalf to protect personal data and use it only for authorised purposes. We do not sell or rent personal data or share it for third parties’ own direct marketing. This does not prevent the processing and sharing needed to run the Stingray Raffle or the winner publicity described in section 15, including publicity promoting the Raffle and future raffles staged by the Foundation.

6. Processing outside the Cayman Islands

Some website, email, or technology providers may process personal data outside the Cayman Islands. For example, this website currently requests font files from Google when a page loads, which means ordinary connection information such as an IP address may be transmitted to Google.

Where the DPA applies to an international transfer, we take reasonable steps to ensure that the information receives an adequate level of protection or that another lawful transfer condition applies.

7. Cookies and similar technologies

As of the date of this notice, this website does not intentionally set first-party cookies and does not use advertising cookies, tracking pixels, or website analytics. The website does load fonts from Google, as described above.

If we later introduce cookies or similar technologies, we will update this notice, explain their purposes and durations, and provide consent controls where required.

8. How long we keep personal data

We keep personal data only for as long as reasonably necessary for the purpose for which it was collected, including to respond to an enquiry, maintain appropriate organisational records, meet legal or regulatory requirements, resolve disputes, and enforce agreements. Retention periods vary according to the nature and sensitivity of the information and any applicable legal requirements.

When information is no longer required, we securely delete or anonymise it where reasonably practicable.

9. How we protect personal data

We use reasonable administrative, technical, and physical safeguards designed to protect personal data against accidental or unlawful loss, misuse, alteration, disclosure, or access. No website, email, or storage system can be guaranteed completely secure, so please take care when deciding what to send electronically.

10. Children and young people

The Foundation’s mission and programmes may benefit children and young people, but this public website does not currently accept programme applications or knowingly collect children’s personal data through an online service.

When a future programme requires information about a child or young person, we will provide clear information at the point of collection, collect only what is needed, and use appropriate parent, guardian, and safeguarding procedures. Children and young people should ask a parent or guardian for help before sending personal data through our general contact channels.

11. Your data-protection rights

Depending on the circumstances and subject to the DPA, you may have the right to:

• be informed about how your personal data is used;
• request access to personal data we hold about you;
• ask us to correct inaccurate personal data;
• ask us to stop or restrict certain processing;
• object to the use of your personal data for direct marketing;
• receive information and request reconsideration where a significant decision is made solely by automated means; and
• seek compensation or complain to the Cayman Islands Ombudsman where applicable.

These rights are not absolute and exemptions may apply. To exercise a right, contact us using the details below. We may need to verify your identity before acting on a request.

12. External websites

Our website may link to websites or services operated by other organisations. Their privacy practices are their responsibility, and we encourage you to read their privacy notices before providing personal data.

13. Contact us or make a complaint

For a privacy question, request, or complaint, contact:

We will try to resolve your concern. You also have the right to complain to the Office of the Ombudsman, Cayman Islands.

14. Changes to this notice

We may update this notice when our services, technology, or legal obligations change. The current version will be posted on this page with its “Last updated” date.

15. Stingray Raffle

This section summarises the personal-data provisions in the Stingray Raffle Terms and Conditions, version 7.0, dated 2 October 2026.

What we collect

Raffle data includes your name, mobile number, email address, entry and account records, and contribution record. At claim, the Operator inspects valid government-issued photographic identification, proof of contribution and the winning entry record. This also covers identity and authority checks for a vendor’s representative claiming a Vendor Prize.

A verification photograph may be taken only where the claim cannot be verified without recording an image. This is separate from a winner’s publicity photograph: verification photographs and identification documents are not published or used for marketing.

Who processes it and why

The Foundation is the data controller. Stingray Raffle Ltd, the Operator, processes personal data as the Foundation’s processor, together with service providers it engages. Stingray Media Ltd, the Promoter, also acts as a processor for the publicity activities described below. The Operator and Promoter act on the Foundation’s documented instructions.

We use this information to administer entries and run the draw, verify claims, award prizes, prevent fraud, maintain audit records, carry out agreed winner publicity and meet legal obligations. The raffle terms set out the applicable processing grounds, including performance of the entry contract, legitimate interests, legal obligations and consent for publicity.

How long raffle records are kept

• Verification photographs and any identification-document copies: no longer than six months from the relevant draw, after which they are securely destroyed. Access is restricted to personnel who need them for verification, fraud prevention or audit.
• The written verification record: seven years. This records that the claim requirements were satisfied and does not include a verification photograph or identification-document copy.
• Proof of Win Photographs and Recordings: no longer than the publicity-rights period, which is up to 24 months from the relevant draw, subject to earlier withdrawal of consent or a request to stop publication. At the end of that period, they are deleted from the Foundation’s, Operator’s and Promoter’s records and removed from channels under their control. The signed consent form is kept while those rights remain in force.

Other raffle records are kept only for as long as necessary for their purposes, applying the retention criteria in section 8.

Winner publicity and consent

The Stingray Raffle is a public raffle. Under the terms, receiving a Holder Prize requires participation in a Proof of Win Photograph and, if the Foundation requests it, a Proof of Win Recording, with separate written consent signed when the photograph or recording is taken. The winner is shown holding the winning edition of The Caymanian Journal. Identification documents must not appear in this publicity material.

With that consent, the photograph or recording, the winner’s name and parish or district of residence may be used to demonstrate that the prize was awarded and to promote the Raffle and future raffles staged by the Foundation. Permitted channels include the Foundation’s and Promoter’s websites and social media, The Caymanian Journal in print and online, the Promoter’s radio stations and app, other Cayman Islands print and broadcast media, third-party social and search platforms, and material at participating vendors.

You may withdraw publicity consent or ask for publication to stop at any time. The Foundation and Promoter will stop further publication and remove material from channels under their control as soon as practicable and within 21 days of receiving the request. This does not affect earlier lawful use or the validity of a prize already awarded. Material already published by third parties cannot be recalled.

Publication, sharing and overseas processing

Publishers and platform operators determine the purposes and means of their own processing and act as independent data controllers, rather than the Foundation’s processors. Separate editorial reporting is not carried out on the Foundation’s behalf; the Foundation and Promoter will not supply winner photographs, recordings or other claimant data for editorial use without the claimant’s publicity consent.

Raffle processing and publication may involve transfers outside the Cayman Islands. The raffle terms require an assessment of the relevant channels, recipients and locations before the first transfer, reviewed annually and when these change. Consent for publicity includes the associated publication transfers.

Questions and privacy requests

For raffle privacy questions, to exercise your rights or to withdraw publicity consent, email [email protected]. You may also direct a request to the Operator on the Foundation’s behalf at 38 Godfrey Nixon Way, George Town, Grand Cayman, Cayman Islands. Your rights and the route to complain to the Ombudsman are explained in sections 11 and 13.

For the full conditions, see sections 5, 6 and 9 of the raffle Terms and Conditions, available on the Stingray Raffle page.