Bermuda Economic Development Corporation (BEDC)
Effective date: December, 2020
Bermuda Economic Development Corporation is committed to protecting and managing personally identifiable information you share with us. The BEDC website can be visited without revealing who you are or any personal information about yourself. To protect your privacy, we have adopted the following principles:
● When we collect personal information from you, it is our intent to inform you first. If you choose not to provide the information we request, you can still visit and benefit from the content on bedc.bm, but you may be unable to take advantage of certain options, offers, and services.
● We will take appropriate steps to protect the information you share with us from unauthorized access or disclosure.
● We will never share, sell, or rent individual personal information with anyone
without your permission or unless ordered by a court of law.
● We will only use the information you provide us as you request, unless
ordered by a court of law or to fulfil a contract or service.
● Personal information will only be processed fairly and lawfully.
● We do not collect any more personal data than is necessary to provide a full
response to your inquiry or to provide services you have purchased.
● We only use your personal information for the purposes we specify in this
Privacy Notice, unless you agree otherwise.
● We do not keep your personal information if it is no longer needed.
● You can have your data updated at any time.
● You can remove your data at any time.
● You can request a copy of the data we store on you at any time.
● Personal data is securely stored and managed.
Service is the www.bedc.bm website operated by Bermuda Economic Development Corporation
facts provided or learned about something or someone.
“Personal information” is any digital or non-digital information relating to an identified or identifiable person. Personal information includes personal identifiers such as an individual’s name, address and phone number.
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.
You can enable or disable location services when you use our Service at any time, through your device settings.
Tracking & Cookies Data
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.
Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
BEDC collects and maintains personal information that customers, employees, board members, and company shareholders voluntarily provided to us when expressing interest in obtaining information about our products and services, to complete a project, assist with client management, coordinate BEDC events, and when posting comments to our social media platforms.
The personal information that we collect depends on the context of your interactions with us, the choices you make and the features you use and may be publicly accessible information via Bermuda’s Public Access to Information Act (PATI).The personal information we collect can include the following:
● Personal identification information (name, email address, mailing address, location, phone number, date of birth, credit card information, and education &employment information as necessary)
● Any additional personal information necessary to track your inquiry.
● Business Information: If you choose to submit an inquiry related to your business on our Website, we may ask specific information related to your business in order to create the inquiry.
● Financial Information: If we need to process a funding application or guarantee a business loan application.
Your interest in connecting with us
Throughout the Website there may be forms to request information, products and services. These forms typically ask for personally-identifying information (such as your phone, postal address or e-mail address). Contact information from these forms is used to send the information that you request.
In order to communicate with us or to use our services, you may be prompted to provide certain personal data in the following ways:
● By filling in forms (i.e. an “Email Sign Up” form) on our website or anywhere else where we conduct business (i.e. at a seminar)
● By subscribing to our newsletters or commenting on our blog posts
● By interacting with us via social media
● By corresponding with us by phone, e-mail or otherwise using our contact details
You acknowledge and consent to the application of Bermuda laws to the information and documents.
You also consent to BEDC’s use of processors who, under the direction of BEDC, may receive your information in order to assist BEDC in providing information or services requested by you. BEDC will work with external processors that provide sufficient guarantees to implement the appropriate technical and organizational measures that will meet legal requirements necessary to ensure the protection of your rights.
WHAT THIS MEANS:
You agree that information and documents provided to BEDC are subject to the laws of Bermuda.
The BEDC website is managed by Lead X Design and the personally identifiable information collected via the site are personal mailing, email address and telephone number, and IP addresses, in order to track your transactions by storing records of payments and for online security purposes.
We collect no personal information about you unless you voluntarily provide information (i.e. sending an email or participating in a survey). If you choose not to participate in these activities, your choice will in no way affect your ability to use any other feature of BEDC website.
WHAT THIS MEANS:
You can use BEDC’s website without providing any personal information.
Information Automatically Collected
Bermuda Economic Development Corporation automatically collects information when you visit, click on external links or download information, use or navigate the website and social media platforms. This non-personally identifying information, collected through the use of Google Analytics, does not reveal your specific identity but may include:
● The Internet Protocol Address and domain name used but not the email address (The Internet Protocol Address is a numerical identifier assigned either to your Internet service provider or directly to your computer. We use the Internet Protocol Address to direct Internet traffic to you).
● The type of browser and operating system you used and your connection speed
● The date and time you visited this site
● The Web pages or services you accessed at this site and the time you spent on each page
● The links you have clicked to access external sites
● The website you visited prior to coming to this site
● Your location by country
● Search terms used to find this site
You directly provide BEDC with most of the data we collect. We collect data and process data when you:
● Register online or place an order for any of our products or services.
● Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.
● When you use our portal
● Use or view our website via your browser’s cookies.
WHAT THIS MEANS:
We receive information from you directly via forms, appointments and consultations, or from your devices and networks, including location data.
● We need to perform a contract with you
● You have given us permission to do so
● The processing is in our legitimate interests and it’s not overridden by your rights
● For payment processing purposes
● To comply with the law
The information we automatically collect or store is used to respond to your inquiry, provide consultation, deliver a service, improve the content of our Web services and to help us understand how people are using our services. Most devices allow you to prevent location data from being sent to us and we honor your settings. We analyze our website logs to continually improve the value of the materials available on our site.
If during your visit to the BEDC Internet site or social media profiles, you voluntarily provide information through an online-submitted form, direct message, online post, survey or email, the following additional information will be collected:
● Your mail address, your name and/or screen name (if provided) and contents of the message
● Any information you volunteered in response to a survey, message or form
● The information collected is not limited to text characters and may include audio, video and graphic information formats you send us.
WHAT THIS MEANS:
We use the data to deliver services and understand how people use our website so we can make improvements.
BEDC collects and uses personal information only as necessary for the purposes for which it was obtained. BEDC may use data for some or all of the following purposes:
● To process your inquiry
● To offer services you requested or to get you actively engaged with our services
● To allow you to participate in interactive features of our Service when you choose to do so
● To provide customer support and/or account maintenance
● To notify you about changes to our Service
● To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
● To gather analysis or valuable information so that we can improve our Service
● To monitor the usage of our Service
● To detect, prevent and address technical issues
We use the data to understand how people use our website so we can make improvements.
How we use your personal information will depend on which Services you request, how you use those Services and the choices you make in your settings. We use your email to respond appropriately. This may be to respond to you, to address issues you identify, to further improve our website and/or social media, to provide relevant newsletters, marketing messages or certain email notifications, or to forward the message to another agency for appropriate action. Survey information is used for the purpose designated, though contact information associated with surveys may be used for the aforementioned purposes as authorized by you.
Legal Basis for Processing Personal Data under European General Data Protection Regulation (GDPR)
WHAT THIS MEANS:
BEDC uses information provided by you to respond to your request and improve our overall services and messaging.
Your information, including Personal Data, may be transferred or shared with our cloud, hosting company, and software companies used to manage the website and payment transactions located in the United States of America. If you are located outside Bermuda and choose to provide information to us, please note that we transfer the data, including Personal Data, to (USA) and process it there.
We may employ or work alongside third party companies and individuals in Bermuda or the United States to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. The third party companies that we work with are government departments, short and long term contractors, marketing & event organisations, and our IT provider.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
See the details below of the companies and purpose of information-sharing. Note that BEDC tailors services to support client needs, so there are occasions that additional third parties may receive client information and BEDC will ensure that those organisations have adequate safeguards in place to protect client information.
- WordPress – Website
- WPEngine – Website/Hosting
- Cloudflare – DNS
- Economic Development Department – Government support; dependant on purpose of client engagement
- Workforce Development – Government support; dependant on purpose of client engagement
- Bermuda Tourism Authority – Dependant on purpose of client engagement
- Bermuda Business Development Agency – Dependant on purpose of client engagement
- Bermuda Monetary Authority – Dependant on purpose of client engagement
- Inter-Island Communications – Radio/TV; dependant on purpose of client engagement
- Bermuda Broadcasting Company (BBC) – Radio/TV; dependant on purpose of client engagement
- Crimson Media/Channel 82 – TV; dependant on purpose of client engagement
We may provide paid products, courses, and/or services. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
You consent to BEDCs use of third party processors who, under the direction of BEDC, may receive your information in order to assist BEDC in providing information or services requested by you.
BEDC will work with external processors that provide sufficient guarantees to implement the appropriate technical and organizational measures that will meet legal requirements necessary to ensure the protection of your rights.
We will never share your personal data, or otherwise make your personal data available to any third parties for the purposes of marketing or targeting you. We will not sell, rent, or exchange your personal data with any third-parties. If, for whatever reason this needs to change in the future, we would never do so without your express permission.
Disclosure Of Data
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to
- investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies;
- enforce our agreements with you,
- investigate and defend ourselves against any third-party claims or allegations,
- protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or
- exercise or protect the rights and safety of BEDC, our Members, personnel, or others.
Bermuda Economic Development Corporation may disclose your Personal Data in the good faith belief that such action is necessary to:
● To comply with a legal obligation
● To protect and defend the rights or property of Bermuda Economic Development Corporation
● To prevent or investigate possible wrongdoing in connection with the Service
● To protect the personal safety of users of the Service or the public
● To protect against legal liability
Security of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure.
THIRD PARTY WEBSITES
Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information.
We use Constant Contact, Survey Monkey, and other email marketing service providers.
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
WHAT THIS MEANS:
● We may need to share your data when we believe it’s required by law or to protect your rights and security and our rights and security.
● You consent to BEDCs use of third parties to provide information and services requested by you.
● For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
● For as long as we provide services to you
● For as long as we are legally required by applicable laws
● If none of these criteria apply, we commit to purging any Personal Data no later than 24 months following your latest interaction/exchange with our services.
BEDC may retain data for differing periods of time for different purposes as required by statute or best practices. Other statutory obligations, legal processes and enquiries may also necessitate the retention of certain data. When data held in accordance with this policy is destroyed, it will be destroyed securely in accordance with best practice at the time of destruction.
How do we keep your information safe?
All of your Personal Data remains private and confidential. We follow generally accepted standards to protect personal data submitted to us, both during transmission and once we receive it. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our website is at your own risk. You should only access the services within a secure environment.
Lead X Design, as developer and manager of the BEDC websites, have taken steps to safeguard the integrity of its telecommunications and computing infrastructure.
Security measures have been integrated into the design, implementation and day-to-day practices of the entire operating environment as part of its continuing commitment to risk management. This information should not be construed in any way as giving business, legal or other advice. This information should not be construed as warranting as fail-proof the security of information provided through (site developer) websites and online profiles.
Fort Knox designed the CRM platform for BEDC, and information added to the CRM is stored on their cloud platform. BEDC provides directives to Fort Knox regarding any amendments, destruction and disposal of information stored with Fort Knox.
Disclaimer: the BEDC Internet site and social media accounts have links to other websites. These include links to websites operated by other government agencies, nonprofit organizations and private businesses. These links are being provided for informational purposes only; they do not constitute an endorsement or an approval by BEDC of any of the products, services or expressed opinions. When you link to another site, you are no longer on the BEDC Internet site and/or profiles, and this Privacy Notice will not apply. BEDC bears no responsibility for the accuracy, legality or content of the external site. Contact the external site with questions regarding its content.
WHAT THIS MEANS:
We monitor for and try to prevent security breaches
BEDC would like to make sure you are fully aware of all of your data protection rights. You are entitled to the following:
★ The right to access – You have the right to request BEDC for copies of your personal data.We may charge you a small fee for this service.
★ The right to rectification – You have the right to request that BEDC correct any information you believe is inaccurate. You also have the right to request BEDC to complete information you believe is incomplete.
★ The right to erasure – You have the right to request that BEDC erase your personal data, under certain conditions.
★ The right to restrict processing – You have the right to request that BEDC restrict the processing of your personal data, under certain conditions.
★ The right to object to processing – You have the right to object to BEDC’s processing of your personal data, under certain conditions.
★ The right to data portability – You have the right to request that BEDC transfer the data that we have collected to another organization, or directly to you, under certain conditions.
Opting Out of Email Marketing
You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send, by updating your communications preferences via our email service provider, or by contacting us at email@example.com.
You will then be removed from the marketing email list.
In all cases, we will take reasonable steps to verify your identity before granting access or making corrections. You can contact us through the form on this page.
If you make a request, we have 45-days under PIPA to respond to you, but we will aim to follow the global strictest standard by replying within 30-days, wherever possible.
WHAT THIS MEANS:
You can access or request changes to your personal data and the way we process your personal data. We will consider your requests and balance your rights with Conditions of processing (PIPA part 2.6). If you would like to exercise any of your data protection rights, please contact us at our email: firstname.lastname@example.org Call us at: (441) 292 5570
Write to us:
Bermuda Economic Development Corporation (BEDC)
48 Church Street
Call: (441) 292 5570
Bermuda Economic Development Corporation (BEDC)
48 Church Street
Should you wish to report a complaint or if you feel that BEDC has not addressed your concern in a satisfactory manner, you may contact the Office of the Privacy Commissioner (PCO). You can visit the website here: www.privacy.bm