Sandy Toes is committed to protecting the privacy of its clients, employees and other individuals served by or providing services to Sandy Toes. The proper safeguarding of all personal information collected in the course of Sandy Toes’s day-to-day activities is the cornerstone of this commitment. Personal information is any information that identifies and individual, or by which an individual’s identity could be deduced.
Our Ten Privacy Principles
Sandy Toes is responsible for maintaining and protecting the personal information under its control. Sandy Toes has appointed a Privacy Officer who is responsible for ensuring Sandy Toes’ compliance with its privacy obligations.
2. Identifying Purposes
Sandy Toes provides a day excursion or private island destination to individuals and groups/companies. Sandy Toes collects personal information in order to provide these services, establish and maintain client lists and records, establish and maintain mailing lists, identify fraud or error, to ensure regulatory compliance, for internal accounting and administration and servicing our relationship with our customers by communicating updates on promotions and services and performing market research.
Sandy Toes also collects personal information from its employees for the purposes of establishing, maintaining or terminating the employment relationship including managing payroll, benefits, employee performance evaluations, making recruitment and selection decisions, and to meet legal, security or regulatory requirements.
Sandy Toes shall identify the purposes for which it is collecting personal information before this information is collected. If Sandy Toes wishes to use personal information for a purpose not contemplated at the time of collection, the individual’s consent will be sought in advance.
Individuals shall be informed and their consent obtained for the collection, use and disclosure of their personal information, except where otherwise required or permitted by law. When it is appropriate, the written consent of the individual shall be obtained (i.e. by mail, email or fax). Sometimes, an individuals’ consent may be obtained verbally or implied through their conduct with Sandy Toes (i.e. if subscribing to a service, consent to collect the personal information necessary to obtain such service will be implied).
As well, Sandy Toes may periodically request written confirmation from an individual that the information collected and maintained by Sandy Toes is up to date and accurate. Sandy Toes, at its option, may also ensure that it has continuing consent to use and retain personal information.
Sandy Toes will disclose personal information, without notice and without consent, only if required to do so by law or in the good faith belief that such action is necessary to:
a) cooperate with regulatory bodies and law enforcement officials to conform to obligations imposed by law or statute;
b) meet an emergency need; or
c) as required pursuant to an investigation.
4. Limiting Collection
Sandy Toes shall only collect the personal information that is required to meet the purposes identified by Sandy Toes. Sandy Toes is committed to collecting personal information in a fair, open and lawful manner. For this reason, Sandy Toes does not indiscriminately collect personal information.
5. Limiting Use, Disclosure and Retention
Sandy Toes does not use personal information for purposes other than those for which it was originally collected, unless it has first obtained the consent of the person from whom such information was received. Sandy Toes retains personal information only for as long as it is needed and only for the fulfillment of the purposes for which it was originally collected.
Personal information shall be maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purpose for which it was collected.
Personal information shall be protected by security safeguards appropriate to the sensitivity of the personal information. Sandy Toes’ security safeguards include premises security, locked file cabinets, restricted access to files containing personal information, technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access, internal passwords and security policies to control access to the Sandy Toes network and software policy prohibitions against unauthorized use or disclosure.
If Sandy Toes uses the services of any third parties to process personal information, Sandy Toes will enter into legal agreements that require them to protect this personal information in a manner acceptable to Sandy Toes. In entering into these legal agreements, Sandy Toes does not transfer any interest in this personal information to them. Rather, the purpose of these legal agreements is to ensure that the personal information delivered to third parties is maintained at a level of security equal to that proved by Sandy Toes under this Policy.
Sandy Toes will also do its best to ensure that any of its employees who deal with personal information are properly trained and are aware of the necessary and appropriate measures required to protect personal information.
Sandy Toes’ website may contain links to other sites. Sandy Toes is not responsible for the privacy practices or the content of such websites and encourages users to read the privacy statements of any such sites. Clients are reminded that no data transmission is 100% secure over the Internet.
Sandy Toes shall make available to individuals on whom it may keep records, all relevant information about Sandy Toes’ policies and practices that apply to the management of their personal information. This policy is available on our website at www.sandytoesroseisland.com and can be accessed at any time.
9. Individual Access
Upon request, Sandy Toes will inform an individual if Sandy Toes has any personal information about the individual under its care and control, as well as provide the individual with details about such personal information. Sandy Toes reserves the right to confirm the identity of the person seeking access to personal information before complying with any access request. In responding to an access request, Sandy Toes may charge a reasonable fee.
Sandy Toes is also committed to ensuring the personal information that is collected and maintained is accurate. An individual may challenge the completeness of the personal information under Sandy Toes’ care and control. Where an individual successfully demonstrates that an error in the accuracy or completeness of their personal information exists, Sandy Toes will amend the personal information accordingly.
Sandy Toes may deny access to personal information when denial of access is required or authorized by law. Possible reasons for denying access to personal information include when granting access would have an unreasonable impact on other people’s privacy to protect Sandy Toes’ rights and property where the request is frivolous or vexatious.
If Sandy Toes is unable to provide access to all of the personal information it holds about an individual, then the reasons for the denial of access will be provided to the individual.
Requests for access to an individuals personal information shall be made to the Privacy Officer through email@example.com or by mail at:
1 Marina Dr. Paradise Island, Bahamas P. O. Box CB – 11115
10. Challenging Compliance
An individual may challenge Sandy Toes’ compliance with this policy by directing their questions, concerns or complaints to the Privacy Officer at the aforementioned contact information.