The Information We Collect

The personal information we collect will depend on the nature of our relationship with you and the services we provide. We may collect and use the following types of personal information, where relevant:

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• your name, address, email address, telephone number and other contact information;

• your date and place of birth, nationality and other identification information;

• copies of identification documents, such as a passport, driver's licence or other government-issued identification;

• information about your occupation, employment, professional qualifications, directorships or other professional roles;

• financial and accounting information, including bank account details, transaction information, remuneration and other financial information relevant to the services we provide;

• tax, payroll and employment-related information;

• information concerning your relationship with a client, supplier, employee or other person or organisation with whom we deal;

• information required for client acceptance, due diligence, legal or regulatory compliance purposes, including information required to comply with applicable anti-money laundering and anti-terrorist financing requirements;

• correspondence and other information you provide to us in connection with our services or your relationship with ASK Bermuda; and

• other personal information that is reasonably required in connection with the purposes for which it is collected.

 

Depending on the circumstances, some of the personal information we collect may constitute sensitive personal information under PIPA. Where we use sensitive personal information, we will do so in accordance with the requirements of PIPA.​

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Information about other individuals

In providing our services, we may receive personal information about individuals connected with our clients or other parties, including employees, directors, shareholders, customers, suppliers, professional advisers and family members. Where you provide us with personal information about another individual, you should ensure that you are authorised to provide that information to us where necessary.

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Recruitment

If you apply for a position with ASK Bermuda, we may collect information relevant to your application and our recruitment process, including your employment history, education and professional qualifications, contact information, references, and information concerning your eligibility to work in Bermuda. We may also collect other information that is reasonably necessary to assess your application.

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We may obtain personal information directly from you, from our clients or other persons with whom we interact, from service providers, regulatory or governmental bodies, and from publicly available sources, where permitted by law.

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The categories above are not exhaustive. We will only collect and use personal information that is reasonably necessary and proportionate to the purposes for which it is required and in accordance with PIPA.

Where We Obtain Your Personal Information

We may obtain personal information from a variety of sources, depending on the nature of our relationship with you and the services we provide.

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We may collect personal information directly from you, including:

• when you communicate or correspond with us, whether by email, telephone, through our website or otherwise;

• when you complete forms, provide documents or otherwise provide information in connection with our services;

• when you engage us, or we undertake client acceptance, due diligence or other compliance procedures; and

• through meetings, discussions and other interactions with us.

 

We may also receive personal information from other sources, including:

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• our clients, where they provide personal information about their employees, directors, shareholders, customers, suppliers or other individuals in connection with the services we provide;

• your employer or an organisation with which you are associated;

• professional advisers, financial institutions and other third parties with whom we or our clients interact;

• service providers that support our business and the delivery of our services;

• government departments, regulatory bodies and other public authorities, where appropriate;

• publicly available sources, including public registers and other information lawfully available to the public; and

• other third parties where you have authorised the disclosure or where the collection of the information is otherwise permitted by law.

 

Where we obtain personal information from a source other than you, we will use that information only for purposes that are appropriate in the circumstances and in accordance with PIPA.

Information That We Collect Through Our Website

You are not required to provide personal information simply to access the public areas of our website. However, you may choose to provide personal information to us when you complete a form, subscribe to receive communications, contact us or otherwise interact with us through the website.

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When you visit our website, we may automatically collect certain technical information about your visit, such as your Internet Protocol (IP) address, browser and device information, and information about how you interact with our website. We may use this information to operate and improve our website, understand how it is used, maintain its security and improve our services.

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We may also use cookies and similar technologies in connection with our website. Further information about the cookies we use and the choices available to you is set out in our Cookies Policy.

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If you contact us by email, telephone or through our website, we may collect and use the personal information you provide in order to respond to your enquiry and, where appropriate, provide our services to you.

How We Use Your Personal Information

ASK Bermuda uses personal information for purposes that are appropriate in the circumstances and related to the operation of our business and the services we provide. We will use personal information in accordance with PIPA and, where required, with the consent of the individual concerned.

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We may use personal information for the following purposes:

• to provide accounting, advisory and other agreed services to our clients;

• to establish, manage and administer our relationships with clients and other parties with whom we do business;

• to communicate with you and respond to requests, enquiries or complaints;

• to undertake client acceptance, due diligence and other compliance procedures;

• to provide payroll, accounting, financial reporting and related services on behalf of our clients, where applicable;

• to administer and operate our business, including billing, record keeping, quality control and internal management;

• to comply with applicable legal, regulatory, professional and reporting obligations, including applicable anti-money laundering and anti-terrorist financing requirements;

• to cooperate with, respond to or report to regulatory bodies, government departments, tax authorities, law enforcement agencies or other public authorities where required or permitted by law;

• to establish, exercise or defend our legal rights and to manage disputes or legal proceedings;

• to manage and improve our services, systems, website and business processes;

• to manage our relationships with suppliers, contractors and other service providers;

• to consider and process applications for employment or other opportunities with ASK Bermuda; and

• for other purposes that are reasonably related to the purposes described above, or otherwise permitted by PIPA.

 

We will not use personal information for purposes that are unreasonable or unrelated to the purposes for which the information was collected, except with your consent or where otherwise permitted by law.

How and Why We Share Your Personal Information

Within ASK Bermuda

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We may share personal information with our directors, officers, employees and independent contractors where access to that information is reasonably necessary for them to perform their duties or provide services on behalf of ASK Bermuda.

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Access to personal information is limited to those who require it to perform their duties or provide services on behalf of ASK Bermuda. We require persons who have access to personal information to maintain its confidentiality and to comply with our privacy and information security requirements.

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Outside ASK Bermuda

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We may disclose personal information to third parties where reasonably necessary to provide our services, operate our business, comply with our legal and regulatory obligations, or otherwise where permitted by PIPA.

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Depending on the circumstances, these third parties may include:

• service providers that support our business and the delivery of our services, including information technology, cloud, software, communications and other technology providers;

• professional advisers, including legal advisers, accountants, auditors and other consultants;

• banks, financial institutions and other parties involved in transactions or services undertaken on behalf of our clients;

• other professional service providers with whom we or our clients work in connection with our services;

• government departments, regulatory bodies, tax authorities and other public authorities;

• law enforcement agencies, courts and tribunals, where required or permitted by law; and

• other third parties where you have authorised the disclosure or where the disclosure is otherwise reasonably necessary and permitted by law.

 

Where we engage a third-party service provider to use personal information on our behalf, we take reasonable steps to ensure that appropriate privacy, confidentiality and security safeguards are in place.

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We may also disclose personal information where necessary to establish, exercise or defend legal rights, comply with a legal or regulatory obligation, respond to a lawful request or court order, or protect the rights and interests of ASK Bermuda or others.

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If you apply for employment or another position with ASK Bermuda, we may disclose or obtain personal information as reasonably necessary to verify information provided by you, obtain references and administer the recruitment process.

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International Transfers

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In providing our services and operating our business, we may transfer personal information to service providers or other third parties located outside Bermuda, including where we use cloud-based technology and other service providers whose systems or infrastructure are located overseas.

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Where personal information is transferred to an overseas third party, ASK Bermuda remains responsible for complying with PIPA in relation to that personal information and will assess the level of protection provided by the overseas third party.

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We will take appropriate steps to ensure that personal information transferred overseas receives a level of protection comparable to that required under PIPA. Depending on the circumstances, this may include considering the protections provided by the laws applicable to the overseas third party, recognised certification mechanisms, contractual safeguards or other appropriate measures.

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Where permitted by PIPA, we may also transfer personal information overseas in other circumstances, including where the transfer is necessary for the establishment, exercise or defence of legal rights or where another applicable exception under PIPA applies.

 

For further information about how we protect personal information transferred outside Bermuda, please contact our Privacy Officer using the details set out below.

Retention and Security of Personal Information

 

We retain personal information only for as long as is reasonably necessary for the purposes for which it was collected or used, or as required to meet our legal, regulatory, professional, accounting or reporting obligations.

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The period for which we retain personal information will depend on the nature of the information, the purposes for which it is used and any applicable legal, regulatory or contractual requirements. When personal information is no longer required, we will securely delete, destroy or anonymise it, as appropriate.

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We take reasonable and appropriate measures to protect personal information against risks including loss, unauthorised access, collection, use, disclosure, copying, modification or disposal. Our safeguards include administrative, technical and physical measures appropriate to the nature and sensitivity of the personal information we hold and the risks associated with its use.

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We also take reasonable steps to ensure that employees, contractors and service providers who have access to personal information understand and comply with applicable confidentiality, privacy and information security requirements.

Access to and Control of Your Personal Information

 

PIPA provides individuals with certain rights in relation to their personal information. Subject to applicable exceptions, these include the right to:

• request access to personal information that we hold about you;

• request the correction of personal information that is inaccurate or incomplete;

• request that we cease, or do not begin, using your personal information for advertising, marketing or public relations purposes;

• request that we cease, or do not begin, using personal information where its use is causing, or is likely to cause, substantial damage or substantial distress; and

• request the erasure or destruction of personal information where it is no longer relevant for the purposes for which it is being used.

 

These rights are subject to the provisions of PIPA and may not apply in all circumstances.

Where we rely on your consent to use personal information, you may withdraw or vary that consent, subject to applicable legal or contractual restrictions and reasonable notice.

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If you wish to exercise any of your rights under PIPA, or have a question or concern about how we use your personal information, please contact our Privacy Officer using the contact details set out below. We may ask you to provide sufficient information to enable us to identify you and the personal information concerned.

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If you are not satisfied with our response, you may have the right to make a complaint to the Office of the Privacy Commissioner for Bermuda.

We take reasonable steps to ensure that the personal information we use is accurate and up to date to the extent necessary for the purposes for which it is used.

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Please let us know if you believe that any personal information we hold about you is inaccurate or incomplete, or if your personal information changes. Keeping your information up to date helps us provide our services effectively and maintain accurate records.

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You may request the correction of inaccurate or incomplete personal information in accordance with your rights under PIPA, as described above.

Questions, Rights and Complaints

 

If you have any questions about this Privacy Statement, our privacy practices or the use of your personal information, or if you wish to exercise any of your rights under PIPA, please contact our Privacy Officer:

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Stephen Caton

Privacy Officer

ASK Bermuda Limited

Office 416 | Washington Mall Phase II

22 Church Street

Hamilton HM 11

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stephencaton@ask.bm

+1-441-601-2275

 

We encourage you to contact us in the first instance if you have any questions or concerns about how we use your personal information so that we have an opportunity to address them.

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If you believe that your privacy rights have not been appropriately addressed, you may also contact the Office of the Privacy Commissioner for Bermuda:

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Office of the Privacy Commissioner for Bermuda

Maxwell Roberts Building, 4th Floor

1 Church Street

Hamilton HM 11

BERMUDA

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Investigations@privacy.bm​

www.privacy.bm

+1-441-543-7748

Changes to This Privacy Statement

 

We may update this Privacy Statement from time to time to reflect changes in our business, services, legal or regulatory requirements, or privacy practices. Any updates will be published on our website, and the date of the most recent update will be shown above.