Privacy Policy
This Privacy Policy has been developed by Keystone Builders Ltd. (hereinafter — the “Company,” “we,” “us,” or “our”) in accordance with the Data Protection Act (2021 Revision) of the Cayman Islands (the “DPA”).
This Policy outlines our commitment to protecting the rights and freedoms of individuals when processing their personal data, including respecting their right to privacy and maintaining data confidentiality under the supervision of the Ombudsman of the Cayman Islands.
This Privacy Policy applies to all personal data collected and processed by Keystone Builders Ltd. through our operations, customer engagements, and our website (hereinafter — the “Website”).
By accessing or using our Website and services, you acknowledge that you have read and understood the terms set forth in this Privacy Policy. If you do not agree with these terms, please refrain from using our Website or submitting personal data to us.
1. Definitions
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"Personal Data" means any data relating to an identified or identifiable living individual. This includes information such as full name, date of birth, postal address, email address, contact telephone number, financial or payment details, IP address, and any other information that directly or indirectly identifies the individual.
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"Processing" means any operation or set of operations performed on personal data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment, restriction, erasure, or destruction.
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"Data Subject" (or "User") means an identified or identifiable natural person whose personal data is processed by the Company.
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"Data Controller" means the natural or legal person who determines the purposes and means of processing personal data. For the purposes of this Policy, Keystone Builders Ltd. acts as the Data Controller.
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"Data Processor" means any natural or legal person who processes personal data on behalf of the Data Controller under a binding contract.
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"Ombudsman" refers to the Office of the Ombudsman of the Cayman Islands, the supervisory authority responsible for regulating and enforcing data protection compliance under the DPA.
2. General Provisions & Data Protection Principles
2.1. This Privacy Policy applies to all visitors, clients, and users of our Website and services.
2.2. Keystone Builders Ltd. adheres to the eight Data Protection Principles established under the Cayman Islands DPA:
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Fairness & Lawfulness: Data is processed fairly and lawfully based on valid legal grounds.
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Purpose Limitation: Data is obtained for one or more specified, explicit, and lawful purposes.
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Adequacy & Relevance: Data collected is adequate, relevant, and not excessive in relation to the purposes for which it is processed.
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Accuracy: Data is accurate and, where necessary, kept up to date.
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Retention: Data is kept no longer than is necessary for the specified purposes.
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Rights of Data Subjects: Data is processed in accordance with the rights of data subjects under the DPA.
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Security: Appropriate technical and organizational measures are taken against unauthorized or unlawful processing, as well as accidental loss or damage.
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International Transfers: Data is not transferred to a country or territory outside the Cayman Islands unless that country ensures an adequate level of protection or appropriate safeguards are met.
2.3. Our Website may contain links to third-party websites. Keystone Builders Ltd. is not responsible for the privacy practices or content of third-party websites. Users are encouraged to review the privacy policies of any third-party sites they visit.
3. Categories of Personal Data & Collection Methods
3.1. We collect personal data directly from you when you request information, contract our building and construction services, fill out contact forms, or interact with us online.
3.2. Information You Provide:
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Full Name and title;
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Contact details (email address, telephone number, physical address);
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Project specifications, site locations, and billing/financial details required for contractual agreements.
3.3. Information Collected Automatically: When you visit our Website, our servers may automatically log technical data transmitted by your web browser, including your IP address, browser type, device specifications, access times, pages viewed, and cookie identifiers.
4. Purposes and Legal Bases for Processing
4.1. We process your personal data only for legitimate operational and legal purposes, including:
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Contract Performance: Fulfilling construction, development, and consulting contracts, managing client relationships, and processing billing transactions.
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Customer Support & Communication: Responding to inquiries, managing service requests, and delivering project updates.
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Website Improvement & Analytics: Analyzing Website performance, user traffic, and security threats using anonymized web analytics tools.
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Legal Compliance: Meeting statutory, tax, regulatory, and corporate record-keeping requirements under Cayman Islands law.
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Marketing (With Consent): Sending informational newsletters, project updates, and promotional material. You may opt out of receiving direct marketing messages at any time.
4.2. Withdrawal of Consent / Opt-Out: Where processing is based on consent, you may withdraw your consent at any time. To unsubscribe from direct marketing messages or withdraw consent, contact us with the subject line "Data Protection Request" or follow the "Unsubscribe" instructions provided in our electronic communications. We will process your request without undue delay and within 30 days.
5. Disclosure and Transfer of Personal Data
5.1. We do not sell, rent, or trade your personal data to third parties.
5.2. We may disclose personal data to third parties only under the following conditions:
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Data Processors: Trusted service providers, contractors, IT host providers, and sub-consultants operating under written contracts that require strict data security and confidentiality.
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Legal Obligations: Authorized government agencies, law enforcement bodies, or regulatory authorities in the Cayman Islands when mandated by law.
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Business Transactions: In the event of a merger, corporate restructuring, or sale of company assets, where the acquiring entity agrees to uphold the principles of this Policy.
5.3. Cross-Border Data Transfers: If personal data is transferred to a country outside the Cayman Islands, Keystone Builders Ltd. will ensure that the destination country provides an adequate level of protection for your personal data, or that appropriate safeguards (such as standard contractual clauses) are established in compliance with the DPA.
6. Security and Data Retention
6.1. Security Measures: We implement physical, technical, and administrative security safeguards to protect your personal data against unauthorized access, unlawful processing, accidental loss, destruction, or damage. These measures include restricted physical and electronic access controls, secure network infrastructure, and encryption where appropriate.
6.2. Data Retention: Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, accounting, reporting, or statutory limitations under Cayman Islands law. Once data is no longer required, it is securely destroyed or permanently anonymized.
7. Your Rights under the Cayman Islands DPA
As a Data Subject under the Cayman Islands DPA, you possess the following rights regarding your personal data:
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Right to be Informed: The right to know how your personal data is collected, used, and processed.
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Right of Access: The right to request a copy of the personal data we hold about you by submitting a Subject Access Request (SAR).
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Right to Rectification: The right to request the correction of inaccurate or incomplete personal data.
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Right to Stop Processing: The right to request that we cease or refrain from processing your personal data for direct marketing purposes or where processing causes unwarranted substantial damage or distress.
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Rights in Relation to Automated Decision-Making: The right to request human intervention or object to decisions made solely on automated processing.
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Right to Complain: The right to lodge a complaint regarding our data handling practices directly with the Ombudsman of the Cayman Islands (Website: ombudsman.ky).
To exercise any of these rights, please contact our Data Protection Officer/Contact Person using the details provided below.
8. Liability and Dispute Resolution
8.1. Keystone Builders Ltd. shall handle all personal data disputes and inquiries in good faith and in compliance with the DPA.
8.2. Before initiating legal proceedings, parties are encouraged to submit any claims or concerns to us in writing to allow for an internal investigation and resolution within 30 days of receipt.
8.3. This Privacy Policy and all matters arising out of or related to it shall be governed by and construed in accordance with the laws of the Cayman Islands.