Masterkey Management Ltd. (“hereinafter Masterkey”) understands that your privacy is important to you and that you care about how your personal data is used and shared. We respect and value the privacy of everyone who visits Masterkey’s website, contacts Masterkey, and/or where your details are included on a database under our control. We will only collect and use personal data in ways that are described here, and in a manner that is consistent with Masterkey obligations and your rights under the law.
Please read this Privacy Notice carefully and ensure that you understand it. Your acceptance of this Privacy Notice is deemed to occur upon your first use of our website or when we request your details, and you are directed to this Privacy Notice. If you do not accept and agree with this Privacy Notice, you must stop using our website immediately and/or inform us that you do not wish for us to continue to use your details.
The Personal Information Protection Act 2016 (PIPA) provides individuals in Bermuda with protection of their rights in relation to their Personal Information. This Privacy Notice is not intended to override the terms of any agreement or other contract which you have with us or any rights you might have available under applicable data protection laws.
This Privacy Notice relates to the following types of individuals, where we hold your personal information:
1.1 Individuals who are clients, including prospective clients
1.2 Representatives and contacts associated with prospective, current, and former clients
1.3 Visitors to our websites or customer portals
1.4 Individuals who contact us with a query, concern, or complaint
1.5 Individuals who request information from us or permit us to contact them for marketing purposes
1.6 Employees, contractors, and third-party vendors
Any reference to “we”, “us” or “our” in this privacy notice means Masterkey, a limited company incorporated in Bermuda, and its related companies including without limitation holding companies, subsidiary companies, and sister companies under the control of the shareholders of Masterkey.
The Masterkey registered office is located at:
Barrington Services Ltd.,
Maxwell Roberts Building,
5th Floor, 1 Church Street,
City of Hamilton HM 11
Bermuda
If you have any questions about this Privacy Notice our Data Protection Officer can be contacted using the following details:
Masterkey Management Ltd.
82 South Road,
Warwick WK 08
Bermuda
privacy@masterkey.bm
(441) 234-7287
This Privacy Notice applies to your use of Masterkey’s website and customer portals and the storage and use of your personal data. Masterkey website may contain links to other websites. Please note that we have no direct control over how your data is collected, stored, or used by other websites and advise you to check the privacy notices of any such websites before providing any information to them.
As an individual, you have the following rights, which this Notice and Masterkey’s use of personal data has been designed to uphold:
4.1 The right to be informed about Masterkey’s collection and use of personal data
4.2 The right of access to the personal data Masterkey holds about you (see section 12)
4.3 The right to rectification if any personal data Masterkey holds about you is inaccurate or incomplete (please contact us using the details in section 14)
4.4 The right to be forgotten – i.e., the right to ask Masterkey to delete any personal data held about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like us to delete it sooner, please contact us using the details in section 14)
4.5 The right to restrict (i.e., prevent) the processing of your personal data
4.6 The right to object to Masterkey using your personal data for specific purposes
If you have any issue or complaint about Masterkey’s use of your personal information, please contact us using the details provided in section 14 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to file a complaint with the Office of the Privacy Commissioner.
For further information about your rights, please contact the Office of the Privacy Commissioner for Bermuda at:
Maxwell Roberts Building,
4th Floor, 1 Church Street,
City of Hamilton HM 11
Bermuda
(441)543-7748
privcom@privacy.bm
We may collect some or all the following personal and non-personal data:
5.1 identity documents
5.2 gender
5.3 contact details (address, telephone number and email address)
5.4 age, date of birth
5.5 business/company name, job title, profession
5.6 financial information such as bank account details, credit / debit card numbers
5.7 IP address, web browser type and version
5.8 operating system, a list of URLs starting with a referring site, your activity on our websites, and the site you exit to
5.9 usernames and passwords that are used for any system/software that you may interact with and property access codes and passwords to fulfill our services
5.10 correspondence data, personal references or criminal history
6.1 All personal data is processed and stored securely, for no longer than is necessary in accordance with the purpose(s) for which it was first collected. We will comply with Masterkey’s obligations and safeguard your rights under PIPA at all times. For more details on security see section 7, below.
6.2 Masterkey’s use of your personal data will always have a lawful basis/condition, either because it is necessary for our performance of a contract with you, for the performance of our services or because you have consented to our use of your personal data (e.g., by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
6.2.1 Providing and managing your access to our website or customer portals
6.2.2 Personalizing and tailoring your experience, our products and/or services
6.2.3 To enter into or perform a contract
6.2.4 To comply with legal obligations and to cooperate with regulatory bodies to which we are subject
6.2.5 Supplying Masterkey’s products and/or services to you (please note that we require your personal data to enter into a contract with you)
6.2.6 Replying to emails from you
6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by contacting privacy@masterkey.bm);
6.2.8 Conducting market research
6.2.9 Invoicing you for our products and/or services
6.2.10 Conducting data analysis, which helps us assess risks and price our services appropriately and improve our offerings to you
6.3 With your permission and/or where permitted by law, Masterkey may also use your data for marketing purposes which may include contacting you with information, news and offers on events and services. Masterkey will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure we fully protect your rights and comply with obligations under PIPA.
6.4 You have the right to withdraw your consent to Masterkey using your personal data at any time, and to request that we delete it.
7.1 Masterkey only keeps your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have a lawful basis/condition to keep it.
7.2 Some or all your data may be stored outside of Bermuda. You are deemed to accept and agree to this by using Masterkey’s website and/or submitting information to us. If Masterkey does store data outside Bermuda, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within Bermuda.
7.3 Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure all personal data collected by us.
7.4 We maintain a data retention policy which we apply to records in our care. Where your personal data is no longer required, we will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.
8.1 Masterkey may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing, search engine facilities, advertising, and marketing. In some cases, third parties may require access to some or all of your data. Where any of your data is required for such a purpose, Masterkey will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
8.2 We may compile statistics about the use of Masterkey’s Website including data on traffic, usage patterns, user numbers, sales, services and other information. All such data will be anonymized and will not include any personally identifying data, or any anonymized data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, artists and advertisers. Data will only be shared and used within the bounds of the law.
8.3 In certain circumstances, Masterkey may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.
9.1 Masterkey may expand or reduce our business, and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use that data only for the same purposes for which it was originally collected by Us.
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
10.1 In addition to your rights under PIPA, set out in section 4, when you submit personal data via Masterkey’s website or customer portal, you may be given options to restrict our use of your data. Further, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails).
11.1 You may access certain areas of Masterkey’s website without providing any data at all. However, to use all features and functions available on our website or customer portals you may be required to submit or allow for the collection of certain data.
11.2 You may restrict Masterkey’s use of cookies. For more information, see section 13.
You have the right to ask for a copy of any of your personal data held by Masterkey (where such data is held). Please contact privacy@masterkey.bm for more details or using the contact details below in section 14.
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Masterkey reserves the right to change this Privacy Notice from time to time (for example, if the law changes). Any changes will be immediately posted on our website, and you will be deemed to have accepted the terms of the Privacy Notice on your first use of our site following the alterations. We recommend that you check this page regularly to keep up to date on pertinent policies.
Version 1.0 – Published September 27, 2024
Masterkey Management Ltd, 2024
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