Bermuda Press (Holdings) Limited – General Privacy Notice
This privacy notice describes how the Bermuda Press (Holdings) Limited group of companies, including Bermuda.com Limited, Bermuda.com Guide Limited, Bermuda Directories Limited, Bermuda Press Ltd., BP Media Limited, E‐Moo (Bermuda) Ltd., Engravers Limited, Industrial Electrics & Controls Ltd., Island Press Limited, Office Solutions Limited, Royal Gazette Limited, Crown House Holdings Ltd. and Crown House Properties Limited (collectively, the “Bermuda Press (Holdings) Limited”, “we”, “our” or “us”) may collect, hold, use and disclose your personal information. This privacy notice explains how we collect, use and safeguard your personal information when you interact with our services. We have a separate privacy notice for our employees and other personnel. This privacy notice applies to all of our products, services and our Website.
Bermuda Press (Holdings) Limited is responsible for any personal information that is used by us in Bermuda. This privacy notice is intended to provide individuals with clear and easily accessible information about our practices and policies with respect to personal information, and is intended to comply with the requirements of the Personal Information Protection Act 2016 (“PIPA”).
This privacy notice does not form part of a contract (if any) with Bermuda Press (Holdings) Limited and does not confer any contractual right on you, or place any contractual obligation on us. The information in this privacy notice is an addition to any information provided to you at the point of collection. We may update or otherwise amend this notice at any time.
- “Personal information” means any information about an identified or identifiable natural person.
- “Use” or “using”, in relation to personal information, means carrying out any operation on personal information, including, but not limited to: collecting, holding, organising, altering, transferring, disclosing, combining, blocking, erasing or destroying it.
- “Sensitive personal information” means any personal information relating to an individual’s place of origin, race, colour, national or ethnic origin, sex, sexual orientation, sexual life, marital status, physical or mental disability, physical or mental health, family status, religious beliefs, political opinions, trade union membership, biometric information or genetic information.
- “Websites” means:www.royalgazette.com; www.emoo.com; www.emoo.bm; www.bermuda.com; www.jobsinbda.com; www.stationerystore.bm; www.islandpress.bm; www.officesolutions.bm; www.bpd.bm; www.bermudapress.bm; www.nothingtodobermuda.com; driveforchange.rg.bm; www.rgmags.com; royalgazettefeatures.com; bermudabiographies.bm.
Most of the personal information that we hold will have been provided by you (for example, when using our Website and signing up for a Royal Gazette user account or other Royal Gazette service or promotion that requires registration). For certain services we may also collect your personal information from various other sources including third parties (for example, our advertising programmes). We may also collect your personal information through our systems, including our IT and email systems, security and CCTV systems (as described later in this privacy notice). We may combine the information you submit under your user account with information from other Bermuda Press (Holdings) Limited services or third parties in order to provide you with a better experience and to improve the quality of our services.
If we use your personal information in a manner that is different than the purpose for which it was collected, then we will request your consent prior to such use. If we propose to use personal information for any purposes other than those described in this privacy notice and/or in a separate service notice, we will offer you an effective way to opt-out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this privacy notice and/or in a separate service notice, unless we have obtained your prior consent. You can decline to submit personal information to our Website or for any of our services, in which case we may not be able to provide our services to you.
Bermuda Press (Holdings) Limited may directly and indirectly collect and use the following types of personal information (including sensitive personal information):
- User account information (e.g. name, address, account password, email address, date of birth and certain demographic information, credit card or other payment account information (which we maintain in encrypted form on secure servers))
- User communications (e.g. when you e-mail or communicate with Bermuda Press (Holdings) Limited companies, we may retain those communications in order to process your inquiries, respond to your requests and improve our services)
- Website and log information (e.g. your web request, one or more cookies that may uniquely identify your browser, IP address, device type, browser type, browser language or the date and time of your request)
- Images or video recordings (e.g. images or videos of individual subjects for journalistic purposes, or where engaging in promotional activities)
- Links (e.g. our Website may present links in a format that enables us to keep track of whether these links have been followed)
- Security and monitoring information (e.g. CCTV footage)
It is important to us that we use your personal information in a lawful and fair manner.
We use or may use your personal information: (i) where it is necessary in the context of your present, past or potential employment relationship with us; (ii) to perform a contract with you (and/or to prepare to enter into a contract with you); (iii) where it is publicly available and will be used for a purpose that is consistent with the purpose of its public availability; (iv) to respond to an emergency that threatens the life, health or security of an individual or the public; and/or (v) where it is necessary in order for us to comply with a provision of law that authorises or requires such use.
Some examples of how we use your personal information include:
- To provide our products and services to users
- To manage users accounts
- To display customized content and advertising to you
- To improve the quality of our search technology, customized content and advertising
- To communicate with you about your orders, products, services and promotions
- To audit, research and analyse our Website, products and services in order to maintain, protect and improve our Website, products and services
- To provide to our advertising partners
- To develop new services
- To ensure the technical functioning and security of our IT network and communications systems
- To comply with legal and regulatory requirements
- Where otherwise reasonably necessary for Bermuda Press (Holdings) Limited legitimate business purposes
We may ask for your consent to certain uses which are not otherwise justified under one of the above bases. We shall provide clear, prominent, easily understandable, accessible mechanisms for you to give consent in relation to the use of your personal information, unless it can be implied from your conduct that you consent to the use of your personal information (excluding sensitive personal information) for the intended purposes that we have notified you of. Where consent is given, it may be withdrawn by you at any time, but this will not impact on any other lawful basis for use relied on by Bermuda Press (Holdings) Limited. In some cases your refusal may mean that we are unable to provide our services to you as Bermuda Press (Holdings) Limited will not have the personal information we believe necessary for the effective and efficient management of our relationship with you.
Where you provide to us personal information of a third party (e.g. friends or relatives), you must be authorised to share such personal information with us and we presume that you have obtained the individual’s consent where applicable.
We will keep your personal information no longer than is necessary for the purpose of its use, including in accordance with any statutory or regulatory requirements and our record retention policies . A limited and reasonable amount of information may be kept for archiving purposes.
Your personal information will only be used and disclosed as permitted by applicable law. Generally any personal information collected by Bermuda Press (Holdings) Limited will remain under our custody and control, and will only be accessed and used internally by appropriate individuals in accordance with our access protocols. Externally we may share your personal information with the following:
- Our subsidiaries and affiliated companies
- Our employees (where there is a legitimate reason for sharing your personal information in accordance with our policies and procedures and in light of their role) and systems administrators
- Our service providers (e.g. Google and other third parties (e.g. Naviga with which we have a business relationship for their use or use on our behalf. Here is a list of third parties:
- Naviga Engage
- Listrak
- Adperfect
- Mailchimp
- Trumba
- ipublishmedia
- tecnavia
- Meta
- Disqus
- WordPress
- Other third parties, where directed by you
- Our legal counsel, banks and financial institutions, auditors, consultants and other professional advisors
- Government, regulatory authorities or law enforcement if required by applicable law
Your personal information may also be accessed by third parties whom we work together with in connection with IT services (e.g. hosting, supporting and maintaining our IT systems). Your personal information may also be shared with certain interconnecting systems (for example, our CRM system). Data contained in such systems may be accessible by providers of those systems, their associated companies and sub-contractors.
Bermuda Press (Holdings) Limited uses personal information on our servers in the U.S. and in Bermuda. In some cases, we use personal information on a server outside our user’s own jurisdiction. Where your personal information is transferred to a third party located outside of Bermuda, we will take steps to ensure that your personal information is adequately protected and transferred in accordance with any applicable data transfer requirements.
We will take reasonable steps and adopt appropriate safeguards against risk (including physical and IT based security measures and controls) proportional to the potential harm, sensitivity and context of the personal information which comply with applicable laws to protect your personal information against loss, unauthorized access, destruction, use, modification, disclosure or other misuse. Access to your personal information is also restricted to authorised employees, contractors and agents who require access for a permitted purpose to perform their employment functions, and whom have been advised as to its proper handling. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
When you use our Website we use cookies and other similar technologies to enhance your browsing experience, analyse site traffic and personalize content. Cookies are small data files stored on your device that allow us to recognize your preferences, improve user experience and track user trends, such as how people search. Most browsers are initially set up to accept cookies, and you can control your cookie preferences through your browser settings (e.g. you can reset your browser to refuse all cookies or to indicate when a cookie is being sent). However, some Website features and services may not function properly if your cookies are disabled. To learn more about cookies and links to manage their use on your browser please see our Cookie Notice.
This privacy notice applies to our Website and services that are owned, operated or provided by Bermuda Press (Holdings) Limited. We do not exercise control over the websites displayed as search results or links from within our various services. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. We are not responsible for the privacy practices or content of these external sites, and we encourage you to review the privacy notices or policies of any third party sites that you visit.
Some of the advertisements and other services that appear on our Website are delivered to you by internet advertising companies. These companies utilize certain technologies including cookies to deliver advertisements and marketing messages and to collect anonymous information about your visit to our Website and other websites.
Google may place or recognize a unique cookie on your browser. Ads by Google are keyword-targeted advertisements provided through the Google AdWords program. Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to your website. These listings are administered, sorted and maintained by Google. For information about these Google ads, please visit:
The DoubleClick DART cookie is used by Google in the ads served on the websites of its partners, such as websites displaying AdSense ads or participating in Google certified ad networks. When users visit a partner’s website and either view or click on an ad, a cookie may be dropped on that user’s browser. The data gathered from these cookies will be used to help better serve and manage ads on the publisher’s site(s) and across the internet. Information from this cookie may be used by Google to help provide advertisers with targeted advertising opportunities. Users may opt-out of the use of the DART cookie by visiting the advertising opt-out page.
For more information about Google’s privacy policy, including how to opt out of this tracking, please visit:
www.google.com/ads/preferences
By clicking on a link in these advertisements, you will leave our Website, and the website you will go to is not endorsed by Bermuda Press (Holdings) Limited.
Any usage of Bermuda Press (Holdings) Limited systems, including telephones, email and internet facilities may be subject to monitoring in compliance with applicable law and best practice. For example, we may monitor your usage: to prevent, detect or investigate suspected misconduct, illegal conduct, wrongdoing or other misuse; to ensure that enquiries and other communications are being appropriately responded to; to comply with legal obligations; or to locate and retrieve lost messages or files.
Bermuda Press (Holdings) Limited uses CCTV, internally and externally, and you may be recorded when at or around our premises. We use the CCTV footage for security purposes, and to prevent, detect or investigate suspected misconduct, illegal conduct, wrongdoing or other misuse.
Bermuda Press (Holdings) Limited will use your contact details to keep you updated by sending email updates and advertisements with information about our products, services, promotional events and special offers and to conduct market research and surveys to improve our offerings. You always have the right to withdraw consent, where given, or otherwise object to direct advertising or marketing. However, Bermuda Press (Holdings) Limited is nonetheless likely to retain some of your details (not least to ensure that no more communications are sent to that particular address, email or telephone number). We do not share personal information that we collect about you with unaffiliated third parties for their use in marketing their products and services.
Bermuda Press (Holdings) Limited may interact or provide experiences on social media platforms (e.g. Facebook and Instagram) that enable online sharing and collaboration among registered users. We may collect and use information that you provide by interacting with us through social media (e.g. photographs, opinions or a social media handle or account). Any content you post, such as photographs, opinions or any personal information that you make available to other participants on these social media platforms, is also subject to the terms of use and privacy policies of those platforms. Please refer to such terms and policies to understand your rights and obligations with regard to such content.
You have certain rights with respect to your personal information, and you may submit a reasonable written request to Bermuda Press (Holdings) Limited to:
- Access (i) your personal information that is in Bermuda Press (Holdings) Limited custody or control; (ii) the purposes for which Bermuda Press (Holdings) Limited has been or is using your personal information; and (iii) the names of persons or types of persons and circumstances for which your personal information has or is being disclosed
- Correct an error or omission in any of your personal information which is under Bermuda Press (Holdings) Limited control
- Block which is to cease, or not to begin, using your personal information for the purposes of advertising, marketing, or public relations, or where the use of that personal information is causing or is likely to cause substantial damage or substantial distress to you or another individual
- Erase or destroy personal information about you where that personal information is no longer relevant for the purposes of its use (however, there may be circumstances where Bermuda Press (Holdings) Limited will be legally entitled to retain it)
Any request must be in writing and provide sufficient detail to enable us to identify the personal information to which the request relates. In certain circumstances (described below), we may not be obligated to comply with a rights request, and you can request a review by the Privacy Commissioner of our decision, action or failure to act, and you may initiate a complaint against us with the Privacy Commissioner.
Bermuda Press (Holdings) Limited may refuse to access to personal information in, but not limited to, the following circumstances:
- Personal information is protected by legal privilege
- Disclosure of the personal information would reveal Bermuda Press (Holdings) Limited confidential information or of a third party that is of a commercial nature and it is not unreasonable to withhold that information
- Personal information is being used for a current disciplinary or criminal investigation or legal proceedings, and refusal does not prejudice the right of the individual to receive a fair hearing
- Personal information was used by a mediator or arbitrator, or was created in the conduct of a mediation or arbitration for which the mediator or arbitrator was appointed to act under an agreement or by a court
- Disclosure of the personal information would reveal the intentions of Bermuda Press (Holdings) Limited in relation to any negotiations with the individual to the extent that the provision of access would be likely to prejudice those negotiations.
Our offices are located at 2 Par-La-Ville Rd, Hamilton Bermuda HM08.
If you have any questions about this privacy notice or to request more details about your rights and how we collect, use and disclose your personal information, please contact our Privacy Officer at:
Email: privacyofficer@bphl.bm
If we receive a complaint at our address or via our Website, our policy to contact the complaining individual regarding their concerns within a reasonable timeframe. We will cooperate with regulatory authorities, including the Office of the Privacy Commissioner for Bermuda, to resolve any complaints regarding personal information that cannot be resolved between us and an individual.
Bermuda Press (Holdings) Limited regularly reviews its compliance with this privacy notice, which is subject to change in accordance with changes to applicable laws or our internal policies and procedures. The date below indicates when this privacy notice was last revised.
Any changes to this privacy notice will be effective upon publication of the revised privacy notice.
Publication December 30th, 2024