Personal Information Privacy Policy (PIPA)

Joshua Bate Trading Bermuda Ltd (“we,” “our,” or “us”) is committed to protecting the privacy and personal information of our customers, employees, and other stakeholders. This Privacy Policy outlines how we collect, use, disclose, and safeguard personal information in compliance with Bermuda’s Personal Information Protection Act (PIPA).

  1. Definitions
  • Personal Information: Information about an identified or identifiable individual.
  • Data Subject: The individual to whom the personal information relates.
  • Processing: Any operation performed on personal information, such as collection, storage, use, or disclosure.
  1. Collection of Personal Information

We collect personal information for the following purposes:

  • To provide products and services requested by our customers.
  • To communicate with you about your inquiries or transactions.
  • To comply with legal or regulatory obligations.
  • To document processes and procedures being followed on site.
  • For staffing and Human Resources functions for employees and Third Party contractors including recruitment, hiring, compensation pathways (like bank account info) and performance/due diligence information

The types of personal information we may collect include:

  • Name, address, email, and telephone number.
  • Payment information.
  • Pictures of site, products, product documentation, installation processes.
  • Other information necessary for the purposes described above. *Assume this covers notes like “so and so’s brother” or “contact property manager”

2.1: Sensitive Personal information:

Only in relation to Current and Prospective employees: To the extent permitted by applicable laws, we may also collect and process a limited amount of personal information falling into special categories, called “sensitive information”. For example, sensitive information may include, but is not limited to, the following types of information:

  • Drivers license and motor vehicle reports; bank account information; Health insurance info that is submitted to the current health insurance company, payroll and tax information; reports in relation to due diligence to be sure company policies and processes are being followed; immigration status to be compliance with regulatory groups
  1. Use of Personal Information

We process personal information only for legitimate purposes, including:

  • Fulfilling contractual obligations. To validate, confirm, verify, deliver, and track your order (including to process payment card transactions, arrange for delivery, handle returns and refunds, maintain a record of the purchases you make, and contact you about your orders, including by telephone and email)
  • Providing customer support.
  • Sending marketing communications, where consent has been given. Including but not limited to: information, newsletters, promotional materials and other offerings from Joshua Bate Trading Limited or its subsidiaries.
  • Improving our services and ensuring security.
  • To fulfill a legal obligation.
  1. Lawful Basis for Processing

We process personal information based on one or more of the following lawful bases:

  • Contract: To perform a contract we have with you or to take steps at your request before entering a contract.
  • Consent: When you directly provide this information to us provide products, services and communication about your
  • Legal Obligation: To comply with applicable laws or regulations.
  • Legitimate Interests: When processing is necessary for our legitimate interests, provided that such interests do not override your fundamental rights and freedoms.
  1. Disclosure of Personal Information

We may share your personal information with:

  • Service providers who assist us in delivering our services.
  • Regulatory authorities, if required by law.
  • Third Parties in relation to requirements from law enforcement and other governmental authorities in accordance with applicable law, and when we believe in good faith that the law requires or permits it. We also reserve the right to share information with legal authorities and other companies for fraud protection, debt collection, to enforce our Terms & Conditions or other applicable policies, or to otherwise protect the rights, property, safety, or security of Joshua Bate Trading Bda Ltd.
    • All third party processors are contractually obligated to comply with PIPA including Vireo which requires customer consent in dealing directly with that company which is outside of Joshua Bate Trading Bda Ltd.
  1. Cross-Border Data Transfers

If your personal information is transferred outside of Bermuda, we will ensure that adequate protections are in place to safeguard your information, as required by PIPA.

  1. Security of Personal Information

We implement reasonable technical, administrative, and physical safeguards to protect personal information from unauthorized access, loss, or misuse. These measures include:

  • Encryption of sensitive data. *do we have this?
  • Regular security assessments.
  • Restricting access to personal information to authorized personnel only. *Are we covered by FM log in requirements?
  1. Retention of Personal Information

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected or as required by law. When no longer needed, personal information will be securely destroyed or anonymized. *when would we “destroy” this?

  1. Your Rights

Under Bermuda’s Personal Information Protection Act 2016 (“PIPA”) you have the following rights:

  • Access: Request access to your personal information held by us.
  • Correction: Request correction of inaccurate or incomplete personal information.
  • Erasure: Request deletion of your personal information, subject to legal or contractual restrictions.
  • Objection: Object to the processing of your personal information in certain circumstances.
  • Withdrawal of Consent: Withdraw your consent where processing is based on your consent.

To exercise your rights, please email us using the information below. We may request certain personal information for purposes of verifying the identity of the individual seeking access and or changes to their personal information records.

  1. Updates to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any changes will be posted on our website with an updated effective date.

  1. Data Breach Notification

In the event of a data breach involving your personal information, we will make reasonable efforts to notify affected individuals as soon as possible, considering the nature and scope of the breach and our available resources. Notifications may include details about the breach, the data involved, and any recommended steps for protection.

  1. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights under PIPA, please contact us at:

Joshua Bate Trading Bda Ltd and subsidiaries: BATES and BQS
7 Marsh Lane, Devonshire DV08 Bermuda
Email: bda@joshbate.com
Phone: 441-236-7880

© 2025 Joshua Bate Trading Bermuda, Ltd.. All rights reserved.