Introduction & Scope

The Bermuda Foundation (“BF,” “Foundation”, “we,” “our,” or “us”) is committed to protecting the privacy of individuals who interact with us. This Privacy Policy explains how we collect, use, and safeguard your personal information when you use our website (the “Site”), our grantmaking (“GLM”) and scholarship (“SLM”) management software, as well as the GiveBermuda.org (“Giving Portal”) platform in compliance with the Personal Information Protection Act 2016 (PIPA) of Bermuda.

Data Protection Principles

BF adheres to the principles relating to the use of personal information as set out in PIPA, which requires personal information to be:

• • Used lawfully, fairly, and in a transparent way;
  • Collected only for specified, explicit, and legitimate purposes that we have clearly explained and not used in any way that is incompatible with those purposes;
  • Relevant and limited only to those purposes;
  • Accurate and kept up to date;
  • Kept only as long as necessary and kept securely.

BF follows the Data Minimization Principle, ensuring that we collect only the minimum amount of personal data necessary to fulfil the purpose for which it was obtained. We do not collect excessive or irrelevant information, and data is reviewed regularly to ensure its continued necessity.

The Type of Information We Hold

We collect personal information necessary for our operations, including:

• • Identity Information: Name, title, organisation affiliation.
  • Contact Information: Email address, phone number, mailing address.
  • Education and Employment Information: Transcripts and letters of recommendation, education history and employment history, student ID numbers.
  • Financial Information: A record of transactions is kept when you use our Gift Intention Forms to make donations. We also capture Anti-Money Laundering (“AML”) / Anti-Terrorist Financing (“ATF”) and Know Your Client (“KYC”) information such as but not limited to source of wealth and source of funds. Transaction details for fund management.
  • Technology Use Data: IP address, browser type, and cookies when you visit our website or service platforms.
  • Grantee/Awardee Information: Name, title, organisation affiliation, email address, phone number and mailing address of organisation employees, directors, trustees and officers. Bank account information to facilitate payment of grants and/or scholarships to organisations and/or scholarship recipients.

We use cookies to enhance user experience, track donations, and remember preferences. You may disable cookies, but this may affect site functionality.

How We Use Your Information

We use the information collected to:

• • Process transactions and manage your donations and grants.
  • Facilitate fund transactions and reporting.
  • Communicate with donors, fundholders, fund advisory committees, grant applicants, grantees, scholarship applicants/recipients and stakeholders.
  • Process grant and scholarship applications for review by advisory committees.
  • Process grant and scholarship reports for review by advisory committees, and to report on the impact of these programmes.
  • Provide secure access to the C-Suite platform and communicate updates related to fund performance and management.
  • Provide updates on Bermuda Foundation activities, events, and impact.
  • Improve our services and website functionality.
  • Comply with legal and regulatory requirements.

Information Sharing & Third Parties

We do not sell, rent, or trade your personal information. However, we may share information with:

• • Service providers (e.g., payment processors, email communication services) strictly for operational purposes.
  • Legal authorities if required to comply with Bermuda laws.
  • Partner organizations only with your explicit consent.

In addition, we may also use personal information if we have been given consent to do so. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.

Your Rights Under PIPA

You have the right to:

• • Access your personal information held by us.
  • Request corrections to your data.
  • Withdraw consent for certain types of data processing.
  • Request deletion of your personal information, subject to legal obligations.

By submitting your information via forms, donations, grant and scholarship applications, agreements and reports, you consent to our collection and processing of your personal information in accordance with this policy.

Cookies & Website Data

Our website and giving portal use cookies to enhance user experience and analyse website traffic. By using our website and portal, you agree to our use of cookies. You may adjust browser settings to disable cookies.

Data Security & Retention

Your data is stored on secure servers in Bermuda and the U.S. and protected using industry-standard encryption (SSL). While we take all reasonable measures to protect your information, no online transaction is completely secure. We implement appropriate security measures to protect personal information from unauthorised access, use, or disclosure. Your data is retained only as long as necessary for the purpose collected, unless a longer retention period is required by law.

Third-Party Links & Data Transfers

Our website may contain links to third-party sites, which have their own privacy policies. We are not responsible for their privacy practices. Personal data may be transferred to and stored in jurisdictions outside Bermuda with appropriate safeguards in place.

Financial Transactions

Financial data collected during donations or on grant/scholarship agreements, is used to process payments securely. Website payments are handled by third-party processors, and BF does not store full credit card details.

Legal Compliance

BF may disclose your personal data when required by law, to assist law enforcement, or to protect our rights and users.

Contact Us

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

Policy Updates: We may update this Privacy Policy periodically. Any changes will be posted on our website with the revised effective date.