Privacy Policy
Last updated: 01 August 2026
Effective Date
Information pending confirmation
This Privacy Policy explains how the Government of Sint Maarten collects, uses, shares and protects personal data when you use the D2.2D Interoperability Platform.
1. Who We Are
The Interoperability Platform (D2.2D) is operated by the Government of Sint Maarten as part of the Digital Government Transformation Project, in coordination with the National Recovery Programme Bureau (NRPB) and the Digital Leadership Team (DLT).
2. What Information We Collect
Identity Data. Information confirmed through your eID when you sign in, such as your Unique Identification Number and verified name.
Service-Specific Data. Information required to process the particular Service you request, such as address information for an Address Change or business information for a Sole Proprietorship registration.
Registry Data. Information retrieved from the responsible government Registry, such as the Civil Registry, strictly for verification and completion of your request.
Transaction and Payment Data. Information showing that a payment was made and its status. Full payment card and payment credentials are processed and held by the connected payment provider rather than D2.2D.
Technical Data. Standard web, device, browser, session and access information used for security monitoring, service reliability and platform improvement.
3. How We Use Your Information
Your information may be used to:
- verify your identity and authorize access to the Service you request;
- retrieve, display and, where required by the Service, update your record with the responsible Registry;
- process applicable Service fees through the connected payment provider;
- maintain an audit trail for security, dispute resolution and legal compliance; and
- improve the reliability, security and usability of the Platform.
4. Legal Basis for Processing
The Government processes personal data on the basis of applicable legal grounds, which may include:
- performance of a public task or exercise of official authority delegated to the Government of Sint Maarten;
- consent, where explicitly requested;
- compliance with a legal obligation; and
- performance of the transaction requested by the User, where applicable.
The precise legal basis wording is pending confirmation against applicable Sint Maarten data protection legislation.
5. How We Share Your Information
Government Registries. Information may be shared with government Registries responsible for the Service you use, including the Civil Registry, strictly for verification and record-keeping purposes.
Payment Provider. Information necessary to complete a payment may be shared with the connected payment provider.
Authorized Government Personnel. Authorized government personnel may access information on a need-to-know basis for service delivery, auditing and support.
Legal and Regulatory Bodies. Information may be disclosed where required by law, court order, or to protect the rights, safety or security of the public or the Platform.
D2.2D does not sell personal data or share it with third parties for their own marketing purposes.
6. Data Security
D2.2D is built on the security foundation of the Government of Sint Maarten's Digital Identity Programme.
The platform applies privacy-by-default principles and is designed so that connected Registries and services receive only the minimum information required to complete a request.
Access and transactions are logged and monitored for security, audit and operational purposes.
7. Data Retention
D2.2D retains transaction and Service data for as long as necessary to fulfil the purposes described in this Policy, meet applicable legal and record-keeping obligations, and support audits and dispute resolution.
Data held directly by a government Registry is retained according to the rules governing that Registry.
Specific retention periods are pending confirmation.
8. Your Rights
Depending on applicable law, you may have rights to:
- request access to personal data held about you;
- request correction of inaccurate information; and
- ask questions about how your information is collected and used.
Because some underlying information is held by government Registries rather than D2.2D itself, certain requests may need to be directed to, or fulfilled in coordination with, the relevant Registry.
9. Minors and Guardian-Linked Records
Consistent with the Digital Identity Programme's eID policy, citizens below the eligible enrollment age do not hold a personal D2.2D login.
Where a Service concerns a minor — such as certain Life Events or Certificate requests — it may be accessed and managed through the parent's or legal guardian's authenticated eID session.
10. Cookies and Website Analytics
D2.2D may use essential cookies required for the Platform to function, including maintaining secure sessions.
Where enabled, analytics cookies may also be used to understand how the Platform is used and to improve its reliability and usability.
The final cookie policy details and consent mechanism are pending confirmation.
11. International Data Transfers
Information about international data transfers is subject to confirmation. The final policy will identify whether any data processing occurs outside Sint Maarten — including through cloud infrastructure or payment services — and describe the applicable safeguards once confirmed.
International transfer arrangements are pending Government confirmation.
12. Changes to This Policy
This Privacy Policy may be updated from time to time to reflect changes to the Platform, applicable law or data practices.
Material changes will be notified on this page together with an updated effective date.