This policy is designed to comply with the Data Protection Act of Trinidad and Tobago and general international best practices such as the General Data Protection Regulation (GDPR) principles.
1. Introduction
Sunshine ("we", "us", "our") is committed to protecting your personal data and your privacy. This Data Privacy Policy outlines how we collect, use, store, share, and protect your information when you use our digital assets services. We operate in compliance with the Data Protection Act, 2011 (Act No. 13 of 2011) of Trinidad and Tobago and applicable international standards.
2. Scope
This policy applies to all users of our services, including customers, website visitors, and other individuals whose personal data we collect during the provision of our digital assets services.
3. Information We Collect
We collect the following types of personal information:
a. Identifying Information
Full name
Date of birth
National ID, passport, or driver’s license
b. Contact Information
Email address
Phone number
Residential and/or mailing address
c. Financial and Transactional Information
Bank account details
Payment card information
Transaction history with Sunshine
Wallet addresses (e.g., for Digital Asset Transactions)
d. Technical Information
IP address
Device identifiers
Browser type and version
Location data
e. KYC/AML Compliance Data
Source of funds
Proof of address (e.g., utility bill)
Enhanced due diligence information (as required)
4. How We Use Your Information
We use your personal data for the following purposes:
To verify your identity and comply with KYC/AML regulations
To process transactions and provide you with our digital assets services
To detect, investigate, and prevent fraud and unauthorized access
To communicate with you regarding your account, services, and support requests
To comply with legal obligations under the laws of Trinidad and Tobago and applicable jurisdictions
To improve our platform, website, and user experience
5. Legal Basis for Processing
We process your personal data based on one or more of the following legal grounds:
Consent
Performance of a contract
Compliance with legal obligations
Legitimate interests (e.g., fraud prevention, service improvement)
6. Data Sharing and Disclosure
We do not sell your personal information. However, we may share your data with:
Regulatory and law enforcement agencies as required by law
Financial institutions and payment service providers
Third-party service providers (e.g., identity verification, hosting, analytics), under binding agreements
Affiliates and subsidiaries of Sunshine
All third parties are contractually obligated to protect your data in accordance with this policy.
7. Data Retention
We retain personal data for as long as necessary to:
Fulfill the purposes for which it was collected
Comply with legal, regulatory, or contractual obligations
Resolve disputes and enforce agreements
Typically, this may be up to 7 years after the end of your relationship with us, unless a longer period is required by law.
8. Your Rights
Under the Data Protection Act and other applicable laws, you have the right to:
Access your personal data
Request correction or deletion of inaccurate or outdated data
Object to processing in certain circumstances
Withdraw consent at any time (where processing is based on consent)
To exercise your rights, contact us at:
9. Data Security
We employ appropriate technical and organizational measures to safeguard your personal data, including:
Encryption of sensitive data
Secure data storage and restricted access
Regular vulnerability assessments and penetration testing, via software providers
Employee training on data protection and cybersecurity
10. International Data Transfers
Where necessary, your data may be transferred to and processed in jurisdictions outside of Trinidad and Tobago. In such cases, we ensure that appropriate safeguards (e.g., contractual clauses) are in place to protect your data.
11. Cookies and Tracking
Our website may use cookies and similar technologies to improve functionality and user experience. You can manage your cookie preferences through your browser settings.
12. Changes to This Policy
We may update this policy from time to time. Any changes will be posted on our website, and, where appropriate, notified to you via email or other communication channels.
13. Contact Us
If you have questions or concerns about this policy or our data practices, please contact:
Sunshine
1-868-305-7213
