Privacy Notice

Welcome to Bermuda Business Development Agency (hereafter referred to as “BDA”, “we”, “our” or “us”). 

This Privacy Notice describes how we process your personal information. “Process” means carrying out any operation on personal information, including collecting, recording, holding, storing, organizing, adapting, altering, retrieving, transferring, securing, consulting, disclosing, disseminating or otherwise making available, blocking, deleting/destroying or erasing it. This includes personal information that is being processed via our website or through other means. Your personal information can include any information associated with you (such as your name, address, phone number, title, email address, identification information such as passport number, etc.) that is supplied to us 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. 

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

 Information that we process- The BDA collects certain personal information through various means such as when you visit our physical location, attend our events, participate in surveys, interact with any of our representatives in person or over the phone as well as when you visit our website, interact with us via email or social media etc. This also includes personal information you provide to the BDA in order to request additional information, for press inquiries or for other purposes. 

We may collect the following types of personal information: 

We use this information to provide you with any specific services that you have requested, communication of updates, newsletters, to administer promotional materials, surveys, responding to your direct queries, to improve our services, to comply with our legal obligations and to operate our Website. 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 process your personal information for as long as the purpose for which it was collected remains relevant, active or as needed to provide you with the services 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 process your personal information based on the following lawful bases: 

Consent 

Consent is one of the primary conditions for processing personal information under PIPA. We must obtain clear, explicit consent from individuals before using your personal information. This means that individuals must be fully informed about how their information will be used and must agree to it voluntarily. 

Legitimate Interest 

Legitimate interest is another condition under which personal information can be processed. This principle allows us to process personal information if it is necessary for the legitimate interests of the BDA or a third party, provided that these interests are not overridden by your rights and freedoms.  

Automatically 

Using cookies and other tracking software, we automatically collect personal information about you when you access and use our 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: 

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. 

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 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 on 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 Notice, 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.  

Aggregated Data 

We also collect, use and share aggregated data such as statistical or demographic data. 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 your  explicit consent , 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 you may withdraw your consent. To withdraw your consent, you may opt-out of any future mailing and/or promotional messages from us, you should send an unsubscribe request to us at info@bda.bm. We will process your request within 45 days of receiving your request. Please note that if you opt out in this manner, certain aspects of our Website may no longer be available to you and you will no longer receive any form of promotional materials.  

If you do not want us to retain or use your personal information, you may withdraw your consent by contacting us at info@bda.bm. 

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 your Personal Information? 

We have put in place appropriate security safeguards to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered, disclosed or any other misuse. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know and access to your personal information. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Other security safeguards that we employ include encryption, password protection, multifactor authentication and role-based access control.  

We have put in place procedures to deal with any suspected personal data breach and will notify you and the Privacy Commissioner for Bermuda of the relevant details of such breach.   

What about transferring your  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 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 PIPA by ensuring that the transfer of your personal information is governed by adequacy of the receiving country and contract including standard data protection clauses approved by the Privacy Commissioner. 

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 consent. 

How long will we retain your 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 your 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. Once the determined retention period expires, your personal information will be securely deleted.  

What rights do you have about the use of your Personal Information? 

Under PIPA you have the following rights in relation to your Personal Information:  

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 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 you contact the BDA about this Privacy Notice?”). 

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

How will you  be notified of changes to this Privacy Notice? 

From time to time, we may change and/or update this Privacy Notice in order to reflect any changes to the way in which we process your Personal Information or any change  in legal requirements. Any changes we may make in the future will be posted on this page as or where appropriate, notifying you via email or other means. We recommend you regularly review this page to see any updates or changes. This Privacy Notice was last updated in December 2024. 

How can you contact the BDA about this Privacy Notice ? 

If you have  questions or would like to make a complaint about this Privacy Notice and/or our information practices, please contact us by email at privacy@bda.bm. 

You may also contact our Privacy Officer at: 

One Church Street 

A. Maxwell Roberts Building 

6th Floor 

Hamilton HM 11 

Bermuda 

You  also have the right to complain to the local Regulatory body, the Privacy Commissioner for Bermuda. You can find additional details on the Privacy Commissioner of Bermuda through this link The Office of the Privacy Commissioner for Bermuda.  

Updated December 31, 2024