This website is operated by and on behalf of C2 Group – including its affiliates, divisions, business units and subsidiaries – (“C2”).

This privacy policy applies to personal information C2 Group may collect through this website, and to other information we may collect in the course of our business. It does not apply to personal information relating to C2 Group’s own employees, and we have a separate Applicant Privacy Statement in relation to personal information regarding candidates for employment with C2 Group.

C2 Group recognizes and respects the privacy of the individuals whose personal information it collects, uses and otherwise processes in the course of its business.

Collection of Your Personal Information

Personal information you provide

C2 Group collects personal information about individuals when specifically, and knowingly provided by such individuals for purposes disclosed or otherwise known to them when they provide their information or for the wider purposes set out below. This includes, for example, voluntary submission of an email address for our news email update list, providing a business card in a meeting, sending us an email which includes personal information about you, providing basic details for building security purposes when you enter C2 Group premises, or allowing us to photograph, film or otherwise record you when you attend an event that we host or sponsor.

Unless we explain otherwise at the time, providing personal information that we request is optional and disclosures are made voluntarily.

Automatic collection of your personal information

We collect certain information by automated means when you visit our premises or websites. In particular:

• Our websites log IP addresses, the type of operating system that the visitor’s computer uses, the type of browser software used by the visitor, and the pages accessed by the visitor.

C2 Group uses this data, in aggregated form, to perform statistical analyses of the collective characteristics and behaviour of our visitors and to measure overall user demographics and interests regarding specific areas of the site.

• Our websites also use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for evaluating your use of the website, compiling reports on website activity, and providing other services relating to website activity and internet usage for us and our affiliates. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out herein.

Collection of your personal information from third party sources

If you are involved in a business relationship with us, we may also obtain some limited information about you indirectly, for example when your colleagues give us your contact details and information about your role, or from publicly available sources such as the Internet and/or subscription-based services.

Use of Your Personal Information

We may use the information we collect about you for purposes which are made clear to you (or which you already know) when you provide your information or for the following purposes:

Business-related purposes

• protecting the security and integrity of our premises, websites and other information technology systems;
• responding to and communicating with you about your requests, questions and comments;
• managing and developing our relationship with you and the organization that you represent; and
• operating, evaluating and improving our business.

Legal and compliance purposes

• protecting ourselves and our employees and business counterparties against fraud and other criminal activity, and co-operating with law enforcement and other regulatory agencies;
• exercising and defending our legal rights and legal claims made against us; and
• complying with our legal and regulatory obligations.

Except as otherwise allowed by this policy, C2 Group will not trade, sell, or rent personal information but may collect, or provide aggregate statistics about its websites and their users to other parties who do not provide services directly to C2 Group.

Except in rare circumstances where C2 Group is required by law to disclose or otherwise process your personal information, C2 Group will only process your personal information as necessary for the purposes explained to you when the information is collected or otherwise set out in this policy. C2 Group will not collect your personal information unless it has concluded that it has a legitimate interest in pursuing the relevant purpose. We may occasionally ask for your consent to allow us to process your personal information – for example, if we wish to use images of you in published materials relating to an event that you attended.

Disclosures

C2 Group entities may share personal information about you between themselves, and they may disclose your personal information to technology and other service providers, including professional advisors, who hold and process the information on their behalf.

C2 Group may also disclose your personal information if it has a good faith belief that this is necessary for the legal and compliance purposes set out above. For these purposes, we may, for example, disclose information about you to courts and litigation counter-parties, insurers, the police and other competent governmental authorities.

As we continue to develop our business, we might sell or buy assets. In such transactions, personal information is generally one of the transferred business assets. Also, if either C2 Group itself or substantially all of C2 Group’s assets were acquired, personal information may be one of the transferred assets. Therefore, we may disclose and/or transfer personal information to a third party purchaser in these circumstances.

If your personal information is collected or processed by a C2 Group entity within the European Economic Area (the “EEA”) or the United Kingdom (the “UK”), you should be aware that the disclosures described above may include transfers of your personal information to recipients outside the EEA or the UK, including recipients in countries (such as the United States) which do not have data privacy laws as strict as those in the EEA and the UK. Personal information transferred to C2 Group entities in the United States is protected by the commitments made by C2 Group through its participation in the EU-US Privacy Shield discussed below. Where your personal information is transferred to other C2 Group entities, or to third party service providers, in countries without strict data privacy laws, the information will be protected by data transfer agreements in the appropriate form approved for this purpose by the European Commission – if you would like further information about these agreements, or to see a copy of any of them, please contact us as described below.

Your data protection rights

You have a right to access the information that C2 Group collects about you, and related rights to require your information to be corrected if it is inaccurate, to object to our processing of your information and, in some circumstances, to require us to delete your information or restrict its processing. If you want to exercise any of these rights, or withdraw a consent that you have given to our processing of your personal information, please contact us at Privacy@c2.aw. If your information is held by a C2 Group entity in the EEA or the UK you also have the right to lodge a complaint with the relevant data protection authority, either in the EEA member state or the UK where the C2 Group entity is located or in your own EEA member state or the UK (see also the discussion of complaints in the EU-US Privacy Shield section of this policy, below).

Opt Out

If you no longer wish to receive our marketing communications, you may opt out of receiving them by following the instructions included in each newsletter.

Retention of Your Personal Information

C2 Group will retain your personal information as follows (or longer if required by law), and will then promptly delete the information:

• We retain personal information in accordance with C2 Group’s records management policies (unless we delete the information earlier at your request). You may contact C2 Group at Privacy@c2.aw for more information on record retention periods.

EU-US Privacy Shield

C2 Group complies with the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the UK to the United States in reliance on Privacy Shield. C2 Group has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information.^₁ C2 Group may be liable for onward transfers to third parties in violation of the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov.

In compliance with the EU-US Privacy Shield Principles, C2 Group commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and UK individuals with inquiries or complaints regarding this privacy policy should first contact C2 Group at: Privacy@c2.aw.

C2 Group commits to cooperate with the panel established by the EU data protection authorities (‘DPAs’) to address any complaints and comply with the advice given by the panel with regard to personal information transferred to the United States from the EEA and the UK. C2 Group’s referral of complaints to the DPAs is provided at no cost to you.

The U.S. Federal Trade Commission has jurisdiction over C2 Group’s compliance with the Privacy Shield Principles. Under certain conditions, individuals also have the possibility of invoking binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other available mechanisms – this is explained in Annex 1 to the Privacy Shield Principles (see https://www.privacyshield.gov/article?id=ANNEX-I-introduction).

California Consumer Privacy Act (“CCPA”)

This statement applies solely to individuals using or visiting this website who are residents of the State of California (“California residents”).

Your CCPA Rights

California residents have the following rights regarding their personal information:

• Right to Request Deletion. You have a right to request that C2 Group delete your personal information from its records and direct any service providers to delete your personal information from their records, subject to certain exceptions.
• Right to Request Information. You have a right to request that C2 Group disclose the following to you as it relates to the 12-month period preceding its receipt of your request: (1) the categories and specific pieces of personal information C2 Group has collected about you; (2) the categories of sources from which your personal information is collected; (3) the business or commercial purpose for collecting your personal information; and (4) the categories of third parties with whom C2 Group has shared your personal information.
• Right to Request Information as to Sale or Disclosure for Business Purpose. C2 Group does not sell your personal information or disclose your personal information for a business purpose.
• Right to Non-Discrimination. C2 Group will not discriminate against you for exercising your CCPA rights.

To exercise any of these rights, please submit a request to Privacy@c2.aw. You must describe your request with enough detail so we can understand and respond to it. A verifiable consumer request is one made by an individual who is: (i) the consumer who is the subject of the request; (ii) a consumer on behalf of the consumer’s minor child, or (iii) by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer. We may request that you provide us with information to verify your identity and/or authority to act on behalf of a consumer. Personal information collected to determine whether your request is a verifiable consumer request will not be used for any other purpose. We will respond to your request within 45 days of its receipt, unless we notify you that we need more time.

Contact Us

If you have any questions or comments regarding this Privacy Policy or our information collection practices, please contact us by sending an email to C2 Group’s Chief Privacy Officer at: Privacy@c2.aw, or by writing to:

C2 Group

Macuarima 32
Santa Cruz
Aruba

[1] In addition to C2 Group Corporation, the following other C2 Group companies adhere to the Privacy Shield Principles: C2 Civil & Construction V.B.A.; Via Verde V.B.A.; and Azul Solutions V.B.A..