Privacy Policy

Welcome to Bermuda Business Development Agency located at https://www.bda.bm/ (the “Website”). This Website is maintained and operated by the Bermuda Business Development Agency (“BDA” “we”, “our” or “us”).

This privacy policy (the “Privacy Policy”) describes how we treat information you provide to us or that we collect, including how we use such information, how we protect the security of such information and how you may change or request that we amend such information from our systems. This includes any information associated with you (such as your name, title, or email address) that is supplied to us in conjunction with your use or potential use of the Website or when you request information from us as well as information we generate regarding your use of the Website, in either case, information that does, or can be used to, identify you (“Personal Information”).

This Website is not intended for children and we do not knowingly collect data relating to children.

Click a link below for our policy on each topic:

Who is responsible for your personal information?

For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the data controller for the Personal Information you provide or that we collect in connection with the Website is the BDA.

What information does the BDA collect through its public website, or other interactions, and how is this information used?

Anyone Who Contacts Us through Our Website

The BDA collects certain Personal Information through the Website when you choose to submit such information to us through an online form, email or other method (such as contacting us through “Contact BDA”). This includes Personal Information you provide to the BDA in order to request additional information, for press inquiries or for other purposes.

We use this information to operate the Website and to provide you with any specific services that you have requested. We also use this information to respond to your direct inquiries, to administer promotions, surveys or other site features, to add you to our mailing lists and to send you emails from time to time. We may permit our vendors and subcontractors to access your Personal Information, but they are only permitted to do so in connection with performing services for us. They are not authorised by us to use the information for their own benefit.

We will keep this information for as long as your inquiry is active or as needed to provide you with the services and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements.

Automatically

Using cookies and other tracking software, we automatically collect Personal Information about you when you access and use the Website, mobile sites, applications, sponsored content on social media sites (the “Online Information”), and information about the device you use to access the Online Information.

For example, we may collect:

  • Information about how you view the Online Information (such as the pages you view, the links you click)
  • Information about your browser and usage patterns (e.g. your IP address, browser type and language)
  • Information about the device you use to access the Online Information
  • Your access via a social media site

We use this information to determine news, alerts, and other products and services that may be of interest to you for marketing purposes; to monitor and improve our Online Information; and to help us develop new products and services. We also use this information to determine how much time visitors spend on websites, how visitors navigate throughout websites and how we may tailor our Website to better meet consumer needs.

For further information about Cookies, please see our “Cookies” section below.

Aggregated Data

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your Personal Information but it is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data (i.e. information about how you use the Website) to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your Personal Information so that it can be used directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Private Policy.

Marketing

If we have collected your Personal Information through the Website or through other channels (such as if you have exchanged contact information with a member of our team, or have included your Personal Information in an event registration form), and we have a permission to do so, we will use your Personal Information to inform you about other BDA services and products that might be of interest to you and to gather feedback from you on our Website and our service. We also use this information to operate the Website and may, with third party vendors, use this information to deliver targeted advertising to you when you visit other sites or our Website. For example, if you are searching for information on a particular product, we or our vendor may cause an advertisement to appear on other websites you view with information on that product. We believe that such advertising is helpful because you will see advertisements that are relevant to your interests and lets us understand how people use our service and the impact of any marketing offers that we make. However, if you would like to opt out of these interest-based advertisements, please follow the opt-out process described below under “How can I Opt-Out?”.

Legal Requirements

We will disclose Personal Information (1) in response to lawful requests by public authorities (including to meet national security or law enforcement requirements), and (2) in our sole discretion if we believe that such disclosure is appropriate in connection with an official government or regulatory.

We may also process your Personal Information if necessary in the defence of a legal claim. We will not delete Personal Information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

How does the BDA protect the security of my Personal Information?

We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other this parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

What about transfer of my Personal Information to other countries?

Our website is maintained in the United States and we store your Personal Information on cloud servers located in the United States. The Personal Information we collect may therefore be collected, transferred to and stored outside the jurisdiction you are in. We will ensure that your Personal Information is protected and transferred in a manner consistent with applicable data protection law, including by ensuring that the transfer of your Personal Information is governed by a contract including standard data protection clauses approved by the European Commission.

We may share your Personal Information with certain third parties including the Bermuda Tourism Authority and the Bermuda Government. We do not sell, rent or otherwise make Personal Information commercially available to any third party (other than those third parties mentioned in the preceding sentence), except with your prior permission.

How long will you use my Personal Information for?

We will only retain your Personal Information for as long as your account or inquiry is active or as needed to provide you with the services requested and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, or other requirements.
In some circumstances you can ask us to delete your Personal Information: see “What rights do I have about the use of my Personal Information” below for further information.

In some circumstances we will anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

What rights do I have about the use of my Personal Information?

Under certain circumstances, you may have rights under data protection laws in relation to your Personal Information, including:

  • To request details of the information we hold about you and how we process it;
  • To have the Personal Information we hold rectified or deleted, to restrict our processing of that information, to stop unauthorised transfers of your Personal Information to a third party and, in some circumstances, to have Personal Information relating to you transferred to another organisation; and
  • To lodge a complaint in relation to the BDA’s processing of your Personal Information with a local supervisory authority.

You can learn more about these rights at ec.europa.eu.

If you object to the processing of your Personal Information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations however, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent you may not be able to make use of the services and products offered by the BDA. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your Personal Information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.

If you would like to exercise, or discuss, any of these rights, please contact us as described below (see “How can I contact the BDA about this Privacy Policy?”).

It is important that the Personal Information we hold about is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.

Does the BDA use “cookies”?

Our website uses cookies to distinguish you from other users of our website and to collect information about your online preferences. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We may store some information on your device or device hard drive as a “cookie” or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Website and for the purpose of facilitating and enhancing your communication and interaction with the Website. Such data may include, without limitation, the address of the websites you visited before and after you visited the Website, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Website you visit and what links you clicked on, and the geolocation of your device.

We and our affiliates and/or third party contractors (such as Google Analytics) may use cookies, web beacons, clear gifs and similar technologies on this Website to customize your use of the Website and for other purposes to make your access more convenient or to enable us to enhance and monitor the Website. We may use cookie data for the purposes described in this Privacy Policy, such as to serve targeted advertising to you. However, some of the information we collect may include data, such as the identifiers associated with your device that are unique to your computer or device (e.g., IDFA for iOS and Android ID for Android).

For information on how Google process and collects your information and how you can opt-out, please see here.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

You may stop or restrict the placement of cookies and similar technologies on your device or flush them from your browser by adjusting your browser or device preferences, in which case you may still use our Website, but it may interfere with some of its functionality. Cookies and similar items are not used by us to automatically retrieve Personal Information from your device without your knowledge.

How can I ‘opt-out’?

To opt-out of any future mailing and/or promotional messages from us, you should send an unsubscribe request to us at [email address]. We will process your request within a reasonable time after receipt. However, we are not responsible for removing your Personal Information from the lists of any third party who has previously been provided with your information in accordance with this Privacy Policy or your consent. Please note that if you opt out in this manner, certain aspects of the Website may no longer be available to you.

If you do not want us to retain or use your Personal Information, you may withdraw your consent by contacting us at [email address].

How will I be notified of changes to this Privacy Policy?

From time to time, we may change and/or update this Privacy Policy in order to reflect any changes to the way in which we process your Personal Information or changing legal requirements. Any changes we may make in the future will be posted in this page. We recommend you regularly review this page to see any updates or changes. This Privacy Policy was last updated [[•] December 2019].

How can I contact the BDA about this Privacy Policy?

If you have questions, or would like to complain about this Privacy Policy and our information practices, please contact us by email at [email address].

You may also have the right to complain to the local data protection authority within the European Economic Area (“DPA”). You can find the details of your local DPA here.

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