PRIVACY POLICY

Effective Date: July 10, 2025

Two Sisters (“we,” “our,” or “us”) respects your privacy and is committed to protecting your personal data and information. This Privacy Policy outlines how we collect, use, store, and share your information when you visit our website, make a booking, or engage with us through our experiences or services (the “Services”).

It is important that you understand what information we collect and store, and how we use this information. It is also important that you understand your rights in relation to the information we collect, store, and use. How we collect, store, and use your information is governed by the Data Protection Act, 2020 of Jamaica, and any related current or future legislation or regulations (collectively the “Act”).

Your use of our website for the Services, constitutes your consent to us to use your information.

1. Key Terms

“Data controller” means any—

  1. person or

  2. public authority,

who, either alone or jointly or in common with other persons determines the purposes for which and the manner in which any personal data are, or are to be, processed, and where personal data are processed only for purposes for which they are required under any enactment to be processed, the person on whom the obligation to process the personal data is imposed by or under that enactment is for the purposes of this Act a data controller.

“Data subject” means a named or otherwise identifiable individual who is the subject of personal data, and in determining whether an individual is identifiable account shall be taken of all means used or reasonably likely to be used by the data controller or any other person to identify the individual, such as reference to an identification number or other identifying characteristics (whether physical, social or otherwise) which are reasonably likely to lead to the identification of the individual.

“Personal data”—

means information (however stored) relating to—

(a) a living individual or

(b) an individual who has been deceased for less than thirty years, who can be identified from that information alone or from that information and other information in the possession of, or likely to come into the possession of, the data controller and includes any expression of opinion about that individual and any indication of the intentions of the data controller or any other person in respect of that individual.

2. Access to Services

In order to access the Services, we may request certain information from you, which may include Personal data. Once you have provided that information, and we have collected that information, we have become the Data controller, and you have become a Data subject.

3. Information We Collect

We may collect the following types of Personal data, and other personal information when you interact with us:

Contact Information: Name, email address, phone number, home address, and country of residence.

Booking Information: Date of experience, group size, dietary preferences (if shared), and payment details (processed through secure third-party platforms).

Marketing Preferences: Communication preferences and engagement history (e.g., opening emails, clicking links).

Technical Information: IP address, browser type, device identifiers, pages visited on our site, and other usage data collected via cookies or analytics tools.

4. How We Use Your Information

We use your Personal data to:

  • Process and confirm bookings

  • Process payments and manage billing

  • Communicate with you regarding your experience

  • Respond to inquiries and customer service requests

  • Send occasional newsletters, updates, or promotional materials (you may opt out at any time)

  • Improve our website, offerings, and guest experience

  • Comply with legal or regulatory obligations

5. Legal basis for Processing

We process your Personal data based on one or more of the following legal grounds:

  • Your consent

  • Compliance with legal obligations

  • Legitimate interests pursued by us, provided they do not override your rights.

6. Data Storage & Security

Your information is stored securely on encrypted servers and protected by appropriate technical and organizational measures to prevent unauthorized access, disclosure, alteration, or destruction.

All payment transactions are handled through secure, PCI-compliant third-party platforms, and we do not store your payment details.

7. Your Rights as a Data subject

You have the right to:

  • Be informed what Personal data we have collected for you

  • Be informed the purpose for which the Personal data is being processed

  • Be informed to whom Personal data is, or may be disclosed

  • Request, in reasonable circumstances that we cease processing of your Personal data, or that we do not begin processing

  • Request that we rectify any inaccuracies in any Personal data

  • Withdraw consent for marketing communications

  • Lodge a complaint with the Office of the Information Commissioner if you believe your rights have been violated

To make any of these requests, please contact us at hello@twosistersja.com.

8. Disclosure of Personal Data

We do not sell or rent your personal information to third parties. We may share your Personal data, only to the extent absolutely required, in the following circumstances:

Service Providers: With trusted partners who help us manage bookings, process payments, or provide email services.

Marketing & Testimonials: With your permission, we may use your name, hometown, and feedback for testimonials on our website or social platforms.

Additionally, while all Personal data provided by you will be treated securely, we may also share your Personal data, with any regulatory authorities, or government agencies, and any other parties with your explicit consent.  In accordance with the Act, we may also be required to disclose your Personal data. This disclosure may be required in the interest of national security, for the prevention detection or investigation of crime, for the apprehension or prosecution of offenders, or for the assessment or collection of any tax or duty, or of any imposition of a similar nature

9.  Data Retention

We retain Personal data for as long as necessary to fulfill legal obligations, provide the Services, or as required by regulatory standards.

10. Cookies & Tracking Technologies

We use cookies and similar technologies to analyze website traffic, enhance functionality, and personalize your experience. You can modify your browser settings to disable cookies, though some features of our site may not function properly without them.

11. Links to Other Sites

Our website may contain links to external sites not operated by us. We are not responsible for the privacy practices or content of those sites. We encourage you to review their privacy policies independently.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with a revised effective date. We encourage you to review it periodically.

13. Contact Us

If you have any questions or concerns regarding this Privacy Policy or our data protection practices, please contact us at hello@twosistersja.com.