Privacy Policy


This Privacy Notice  (“Notice”) applies to Tortuga Rum Company Limited (“TRC”, “Us”, “We”) and its subsidiaries.

Interpretation  & Definitions

 “Cookies” are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many users

“Device” means any device that can access the Service such as a computer, a mobile phone or a digital tablet or other device.

“The Act” The Data Protection Act (2021 Revision) and or any amendment or revision thereto and where repealed and replaced any Act so replacing.

“Usage Data” refers to data collected automatically, either generated by the use of the Service or from the service infrastructure itself (for example the duration of a page visit)

“Website” refers to

“You”  means the individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service, as applicable

The purpose of this  Notice is to explain to our customers, suppliers and other counterparts (“you”) how we collect and use your personal information in connection with our business. ‘Personal Information” means information relating to a living individual who can be identified (directly or indirectly) from that information.   

We respect to individual’s rights to privacy and the protection of personal information we endeavour to adhere and to comply with data protection laws of the Cayman Islands.   

Tracking Technologies and Cookies

We use cookies and similar tracking technologies to track the activity on Our Service and store  certain information. Tracking technologies used are beacons, tags and scripts to collect and track information and to improve and analyse Our Service. The technologies We use may include.

  • Cookies or Browser Cookies: A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is sent, however if You do not accept Cookies You may not be able to use some parts of our Service, unless you have adjusted Your browser setting so that It will refuse Cookies our Service may use Cookies.
  • Web Beacons Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit TRC, for example to count users who have visited those pages or opened an email and other related website statistics (for example recording the popularity of a certain section and verifying system and server integrity)

Cookies can be “Persistent” or Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies, are deleted as soon as You close Your web browser.

We use both Persistent and Session Cookies for the purposes set out below:

  • Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies the services that You have asked for cannot be provided and We only use these Cookies to provide You with these services.

  • Cookie Policy/ Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of Cookies on the website.

  • Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time you use the Website.

The Information we process.

TRC is a data controller of personal information that we process in connection with our business. We regularly collect and process personal information provided by or in respect of our customers, suppliers and other counterparts, which may include any or all of the following:

  • Name, address, email addresses and other contact details.
  • Age, date of birth and other information contained in identification documents, such as passports and drivers’ licenses provided to us.
  • Payment details including bank accounts and credit card information.
  • Online profile and social media information and activity based on your interaction with us and on our website and applications, including for example information provided when you make an online purchase from us, internet protocol (IP) addresses, smart device information, searches, safe visits, and spending patterns.

Categories of Personal Information we collect and use on or through our Website Include.

  • Information that you provide by filling in forms, in particular at the time of first contact with us.
  • We also collect Personal Information when you enter a contest or promotion sponsored by us and when you report a problem with our Website, records and copies of your correspondence (including e-mail addresses) if you contact us.
  • Details of transactions you carry out if any, and of the fulfillment of orders.

Purposes for Which We use Your Personal Information

  • Providing the products and services that you have requested or purchased.
  • Customer management to manage your account, to provide you with customer support and with notices about your account, including notices, about changes to any products or services we offer or provide through it.
  • Advertising, following explicit consent to communicate with you about products or services that may be of interest to you either from us our subsidiaries, our affiliates or other third parties.
  • Confirming your identity or age to the extent required or appropriate.
  • Processing, collecting and otherwise dealing with payments.
  • Complying with Customs requirements in respect of products sold duty free.
  • Functionality and security to detect, prevent and respond to actual or potential fraud, illegal activity, or intellectual property infringement.
  • Compliance to enforce our terms and conditions and to comply with our legal obligations as these derive from applicable laws or any and all regulators.
  • In any other way we may describe when you provide the information or any other purpose with your consent provided separately from this privacy policy.

How We Will Use Information About You

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  • Affiliates We share the above categories of Personal Information with our subsidiaries and affiliates to the extent that is necessary for the purposes of provision of services, customer management, customization of content, advertising (if you have consented (and security and compliance, or to the extent you have provided your consent provided separately from this privacy policy.
  • Consent Where we have your consent.
  • Service Providers To our authorized service providers and third parties that perform certain services on our behalf, including for the purposes of provision of the services you requested, customer management and security which includes but is not limited to IT service providers, auditors, professional advisors, and other agents and sub-contractors acting on our behalf. These services may include but are not limited to  fulfilling orders, processing credit card payments, risk and fraud prevention and mitigation, providing customer service and marketing assistance and conducting general business analysis. These service providers may have access to Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes.
  • Where required for compliance with applicable law or regulation or a court order or similar requirement, which includes sharing Customs information with Customs
  • An anonymized form as part of statistics or other aggregated data shared with third parties.
  • Where it is otherwise permitted by law or necessary for our legitimate interests or those of third parties and not inconsistent with the purposes listed above

 We may transfer your personal information to organizations outside of the Cayman Islands including to countries where data protection may be less stringent than they are in the Cayman Islands however we make every effort possible to verify and audit that the processor and sub-processor provide the best level of protection of personal data.      

Retention of Your Personal Data

We will retain your Personal Information only as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example if we are required to retain your data to comply with applicable laws) resolve disputes and enforce our legal agreements and policies. We will retain Usage Data for internal analysis purposes. Usage Data is generally retained for shorter periods of time, except when this data is used to strengthen the security or to improve functionality or Our service or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data    

TRC will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your Personal Information

Disclosure of Your Personal Information

Law Enforcement

Under certain circumstances, TRC may be required to disclose your Personal information if required to do so by law or in response to valid requests by public authorities (e.g a court or a government agency) 

Other Legal Requirements

TRC may disclose Your Personal Information in the good faith belief that such action is necessary to:

  • Comply with a legal obligation.
  • To protect and defend the right or property of TRC.
  • Protect the personal safety of Users of the Service or the public.
  • Protect against legal liability.

Business Transactions and Due Diligence

If the Company is involved in a merger, acquisition or asset sale, Your Personal Information may be transferred. In the event this occurs We provide notice before Your personal Information is transferred and subject to a different Privacy Policy

Your Rights Related to Your Personal Information

Under Cayman data protection law, you have rights over personal information that we hold about you. We’ve summarized some of these below, but for more information read this helpful information on the website of the Ombudsman at

Right to Access your Personal Information You have a right to request access to a copy of the personal data and information that we hold about you. These are known as a “subject access request”. If you want to access a copy of your information, please tell us your name and one other unique way to identify you (so we can send you your data only) please let us know what type of information you want to know about, and please make sure you tell us where we should send the information. We will respond to all access requests within one (1) calendar month or more complex requests within three (3) months.  

  • Rectification To rectify inaccurate Personal information concerning you (right to data rectification) Please provide us with details and we will investigate and correct any inaccuracies
  • Right to restrict use of personal information You have a right to ask us to restrict the processing of some or all of your personal information in the following situations: (i) if some of the information we hold on You isn’t right,  (ii) we’re not lawfully allowed to use it (iii)  You need us to retain your information in order for you to establish, exercise or defend a legal claim, (iv)  You believe your privacy rights outweigh our legitimate interests to use Your information for a particular purpose and you have objected to it
  • Right of Erasure You may ask us to delete some or all of Your Personal Information and in some cases, and subject to some exceptions, You have the right for this to be done. Please note that where we completely delete Your records, we will no longer have information about Your marketing preferences, including instructions not to contact You or not to contact You in to delete/erase Your Personal information (right to erasure/deletion)
  • Right to Stop Direct Marketing If we are processing Your Personal Information for direct marketing purposes and You wish to object, we will stop processing Your information for those purposes as soon as is reasonably possible

Changes to Our privacy policy We may modify or revise our privacy policy from time to time. You are expected to periodically review the most up to date version found on our Website.

Enforcement Cooperation We regularly review our compliance with this privacy policy. Please feel free to direct any questions or concerns regarding this piracy policy or our treatment of Personal Information by contacting us at . When we receive a formal complaint, it is our policy to contact the complaining party regarding his or her concerns. We will cooperate with the appropriate regulatory authorities including local data protection authorities to resolve any complaints regarding the collection, use and disclosure of Personal Information that cannot be resolved by an individual and Us.

Jurisdiction; All terms and conditions in this Notice are subject to the laws of the Cayman Islands and all parties submit to the jurisdiction of the Cayman Courts in the event of any dispute arising from the terms hereof.