Blewstream respects your privacy and is committed to protecting your personal data. This Privacy Policy (“Privacy Policy”) tells you how we handle personal data when you visit our website, when you submit an enquiry to us, and when you apply for a role with us. Our website is not intended for children and we do not knowingly collect personal data relating to children.
Where we deliver managed professional services to our clients, we generally act on their behalf as a data processor. That processing is governed by our engagement terms with the relevant client, not by this website Privacy Policy (see paragraph 2.6).
2.1 This Privacy Policy explains how Blewstream collects and processes personal data about people who visit our website, who contact or enquire with us, and who apply to work with us.
2.2 Please read this Privacy Policy alongside any other privacy notice or policy we may give you when we collect or process personal data about you, so that you are fully aware of how and why we use your data.
2.3 Blewstream Operations Limited is a company incorporated in Trinidad and Tobago, with its principal place of business at 74 Long Circular Road, Maraval, Trinidad and Tobago. In this Privacy Policy, “Blewstream”, “we”, “us” and “our” refer to Blewstream Operations Limited [and, where relevant, the entities within the Blewstream group responsible for processing your personal data].
2.4 The way we handle personal data depends on the role we play.
2.5 When you interact with us directly, for example by visiting our website, enquiring about our services, or applying for a role, we generally act as a data controller. This means we decide how and why your personal data is processed, and this Privacy Notice governs that processing.
2.6 When we deliver professional services to a client, we usually process personal data on that client’s behalf as a data processor, acting on their documented instructions. In those cases the client is the controller and their own privacy notice governs how the underlying personal data is used.
2.7 If you have any questions about this Privacy Policy or our privacy practices, or wish to exercise your rights, please contact us:
2.8 It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.
3.1 Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymised data).
3.2 We may collect, use, store and transfer different kinds of personal data, which we have grouped as follows:
(a) Identity Data includes full name and title, and, where relevant to an application or where required for verification, date of birth and identification details you provide.
(b) Contact Data includes name, home or business address, email address and telephone numbers.
(c) Recruitment Data includes, where you apply for a role with us, your CV or résumé, cover letter, employment history, education and qualifications, professional memberships, references, information about your eligibility and right to work in Trinidad and Tobago, and any other information you include in your application or that we collect during the recruitment process.
(d) Technical Data includes information collected from your device and your interactions with our website, such as IP address, browser type and version, time zone setting, operating system and platform, and other device identifiers, together with information from cookies and similar technologies (see section 5).
(e) Marketing and Communications Data includes your preferences in receiving marketing from us, your communication preferences, and information collected through your interactions with our marketing emails, for example whether an email has been opened or a link clicked.
(f) Third Party Sourced Data includes information from public sources such as company registries and from your professional online presence (for example a business website or LinkedIn profile), and, where you apply for a role, information provided by referees you nominate.
(g) Voice and Video Data includes recordings or transcripts of telephone calls, video conferences, interviews and similar communications made to or by us that relate to you.
3.3 Anonymised Data. We may also collect, use and share anonymised data such as statistical or aggregated data for any purpose. Anonymised data is not personal data in law because it does not directly or indirectly reveal your identity.
3.4 Special categories of personal data. We do not seek to collect special categories of personal data (such as information about health or biometric data), or information relating to criminal convictions and offences, through our website. If such information is included in an enquiry or application, we will process it only where we have an appropriate lawful basis and, where required, your explicit consent.
3.5 Where we need to collect personal data to respond to your enquiry, to process your application, or to comply with a legal obligation, and you do not provide that data when requested, we may be delayed in, or unable to, respond to you or progress your application.
3.6 Where the personal data you provide relates to other individuals, for example referees or emergency contacts you name in an application, you confirm that you are entitled to share that personal data with us and that those individuals have been informed of its use.
4.1 We use different methods to collect data from and about you, including:
Directly from you. You may give us your personal data when you communicate with us, complete forms (including online forms on our website), or correspond with us by post, phone, email, video conference or otherwise. This includes personal data you provide when you:
Automatically. As you interact with our website, we may automatically collect Technical Data using cookies and similar technologies (see section 5 and our Cookie Policy).
From third parties and public sources. We may receive personal data from referees you nominate, from publicly accessible sources such as company registries, and from your professional online presence.
5.1 Our website uses cookies and similar technologies. Some cookies are essential for the operation of the website and enable basic functions such as page navigation and access to secure areas. We may also use optional cookies, for example to help us understand how visitors use our website or to improve its functionality. Where required under applicable data protection or e-privacy laws, we will ask for your consent before using non-essential cookies. You can change your browser settings to block or manage cookies at any time. If you have any questions about our use of cookies, please contact us using the details in section 2, and see our Cookie Policy for further information.
6.1 We will only use your personal data where we have a lawful basis to do so. Most commonly, we rely on one or more of the following:
(a) Performance of a contract, or steps to enter into one, where we need to perform an engagement we have entered into with you, or to take steps at your request before entering into a contract — for example, to process your job application;
(b) Legitimate interests, where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. These interests include managing our relationships with clients and prospective clients, responding to enquiries, assessing applications, running events, maintaining appropriate standards and compliance, and improving and developing our services and website;
(c) Legal or regulatory obligation, where we need to comply with an obligation to which Blewstream is subject, for example tax, employment or record-keeping requirements; and
(d) Consent, where we ask for and you give consent to a specific use, for example certain marketing, retaining your application for future opportunities, or the processing of special category data. You may withdraw consent at any time.
6.3 We are an AI-enabled firm, and we use technology, including automated and AI-assisted tools, to help deliver our services accurately and efficiently. These tools operate under human oversight, and personal data processed through them is subject to the same protections described in this Privacy Policy. We do not make decisions producing legal or similarly significant effects about you based solely on automated processing without a lawful basis and, where required, appropriate safeguards.
6.4 We may use your personal data to tell you by email about services and updates we think you may find valuable, such as newsletters and event invitations. Unless the law requires your consent, we rely on our legitimate interests to do so.
6.5 You can ask us to stop sending you marketing at any time by following the opt-out link in any marketing message or by contacting us.
6.6 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for a compatible purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the lawful basis that allows us to do so.
7.1 We may share your personal data with the following parties for the purposes set out above, or where required by law:
(a) our directors, officers, personnel and consultants, as necessary;
(b) other entities within the Blewstream group, and joint venture partners, where relevant to the services being provided;
(c) third party service providers and sub-processors we use to run our business efficiently, including providers of IT, cloud hosting, technology and AI tooling, communications and call recording, transcription, data storage and backup, and marketing;
(d) professional advisers, including legal advisers, technology consultants, auditors and insurers;
(e) governmental, regulatory or professional bodies, and law enforcement or other authorities, where we consider disclosure is required by law. In certain circumstances we may be prohibited from telling you that a disclosure has been made; and
(f) a buyer or successor, together with their advisers, if we sell, transfer or merge parts of our business or assets, or acquire or merge with another business. If a change happens to our business, we will notify you, and the new owners may use your personal data as set out in this Privacy Policy.
7.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Where a third party processes personal data on our behalf, we seek to ensure they provide sufficient guarantees to implement appropriate technical and organisational measures so that the processing meets the requirements of applicable data protection laws.
8.1 Blewstream is based in Trinidad and Tobago and provides nearshore services to clients located in North America and elsewhere. Because of this, personal data will routinely be transferred, accessed, and stored across borders, including between Trinidad and Tobago, the United States, Canada, and the locations of our service providers.
8.2 Where personal data is transferred across borders, we take steps to provide appropriate safeguards to protect it in accordance with applicable data protection laws, which may include:
(a) transferring personal data to a country or organisation that the relevant authority has determined provides an adequate level of protection;
(b) putting in place contractual protections, such as standard contractual clauses or equivalent terms, that oblige the recipient to protect your personal data; or
(c) relying on another mechanism permitted under applicable data protection laws.
9.1 We have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those who have a genuine need to know, and they are subject to a duty of confidentiality.
9.2 We have procedures to deal with any suspected personal data breach, and we will notify you and any applicable regulator of a breach where we are legally required to do so.
10.1 Our website may include links to third-party websites, plug-ins and applications. Clicking those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices or practices. We encourage you to read the privacy notice of every website you visit.
11.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including to satisfy any legal, regulatory, accounting or reporting requirements. We may retain your personal data for longer where the circumstances justify it, for example in the event of a complaint or where we reasonably believe there is a prospect of litigation.
11.2 In some circumstances we will anonymise your personal data so that it can no longer be associated with you, in which case we may use that information indefinitely without further notice.
12.1 Depending on where you are located and the laws that apply, you may have rights in relation to your personal data, including the right to:
(a) request access to your personal data, so you can receive a copy of the personal data we hold about you;
(b) request correction of personal data that is incomplete or inaccurate;
(c) request erasure of your personal data where there is no good reason for us to continue processing it;
(d) request restriction of processing of your personal data in certain circumstances;
(e) request transfer of your personal data to you or a third party in a structured, commonly used, machine-readable format, where this right applies;
(f) withdraw consent at any time where we rely on consent to process your personal data, without affecting the lawfulness of processing carried out before you withdraw; and
(g) object to processing where we rely on legitimate interests, and to object at any time to processing for direct marketing purposes.
12.3 You can exercise your rights by contacting us using the details in section 2.
12.4 You will not usually have to pay a fee. However, we may charge a reasonable fee, or refuse to act, if your request is manifestly unfounded, repetitive or excessive.
12.5 We may need to request specific information from you to confirm your identity before responding, as a security measure to ensure personal data is not disclosed to anyone who has no right to receive it. It helps us if you clearly state which right you wish to exercise and what personal data your request concerns.
13.1 If you have a concern about how we handle your personal data, please contact us first using the details in section 2 so that we have the opportunity to address it.
14.1 We keep this Privacy Policy under review and may change it from time to time. When we make a material change, we will update the “last updated” date below.
This version was last updated on 27th July, 2026.
