Our Privacy Policy
Island Trading Limited (“Island Trading”, “we,” “us,” or “our”), is committed to protecting the privacy of individuals whose personal information we collect and use. This Privacy Notice outlines how we collect, use, disclose, and safeguard personal information in compliance with Bermuda’s Personal Information Protection Act 2016 (PIPA).
1. Personal Information
Island Trading collects personal information from our customers, website visitors and other individuals. The information we collect and use varies depending on how you interact with us. We may collect, process, and retain the following types of personal information to deliver our services effectively and meet legal obligations:
• Identity Information: Name and username;
• Contact Information: Email address, home address and phone number(s);
• Order Details: Reference numbers and order information including billing address, shipping address and contact information;
• Account Information: Username, password, security questions;
• Shopping Information: Items you view, put in your cart or add to your wish list;
• Customer Support Information: Information you include in communications with us;
• Marketing and Communication Preferences: Direct marketing preferences;
• Photographs and Video Footage: Marketing and social media;
• Technical Information: IP address, browser type and version, time zone setting, location, operating system, and device information; and,
• Usage Data: Website analytics and browsing behaviour.
2. Data Collection
We collect personal information through:
• Direct interactions. We collect personal information when you:
• Correspond with us;
• Visit our premises;
• Visit our website;
• Make a purchase;
• Place an order;
• Engage with our employees; and,
• Sign up to receive email communications.
• Automated technologies. When you visit our website, we automatically collect technical data about your equipment, browsing actions and patterns. This information is collected using cookies, server logs and other similar technologies.
• Third party sources. We may collect personal information from various third parties such as:
• Companies who support our Site and Services, such as our ecommerce platform; and,
• Our payment processors, who collect payment information (e.g., bank account, credit or debit card information, billing address).
3. Purposes for Collecting Personal Information
We only use personal information for the purposes for which it was collected, including:
• Providing products and services;
• Processing and delivering orders;
• Communicating with you;
• Marketing and advertising;
• Business operations;
• Improving the efficiency of our operations; and,
• Improving our website.
4. Conditions for Processing Personal Information
We collect and use personal information in compliance with PIPA and where:
• It is necessary for our legitimate interests and these interests do not override your fundamental rights.
• We need to comply with a legal or regulatory obligation.
• You have given us consent.
• Processing is necessary for the performance of a contract to which you are a party or for taking steps at your request before entering into such a contract.
5. Third-Party Sharing
We require all third parties to respect the security of your personal information and process it in compliance with PIPA. We do not permit our third-party service providers to use your personal information for their own purposes. They are only authorised to process your personal information for specified purposes and in accordance with our instructions.
We may share your personal information with:
• Consultants, service providers, and other third parties engaged to support our business operations (e.g., IT support, payment processing, shipping and deliveries);
• Business and marketing partners including our ecommerce platform, to provide services and promote our products and services;
• Legal advisors, as needed to obtain professional advice or protect our legal interests;
• Auditors and financial institutions to comply with financial reporting obligations and ensure proper oversight;
• Any party for a purpose disclosed by us at the time you provide your personal information;
• Data storage providers; and,
• Law enforcement agencies as required to comply with legal obligations, court orders, or official requests.
6. Security of Information
We have put in place appropriate operational, technical and physical security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, any information you send to us may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.
7. Retention
We retain personal information as long as needed for its intended purpose or to meet regulatory requirements.
8. Closed-Circuit Television (CCTV)
We use CCTV to monitor our premises to help maintain a safe and secure environment for our customers and employees and in compliance with data privacy legislation.
• Cameras are in public areas.
• We do not use covert monitoring or surveillance.
• Signs are displayed at the entrance to our premises.
Purposes of our CCTV System
• The personal safety of our employees, customers and visitors;
• To support our health and safety measures;
• To support law enforcement in the prevention, detection and prosecution of crime; and,
• To protect our premises and assets (including personal information) and those of our employees, customers and visitors from damage, disruption, vandalism and other crime.
Conditions for Processing
• We will not process CCTV footage unless it captures criminal activity, a security matter or a health and safety incident.
• We may need to use this personal data to establish, exercise or defend against legal claims.
Access and Disclosure
• Access to recorded CCTV footage is restricted to approved members of staff whose role requires them to have access to such data.
• CCTV footage will only be accessed or disclosed if it is necessary to deal with an incident which falls within the purposes identified above or to respond to an individual request.
• CCTV data will only be disclosed to a third party where there is a lawful reason or where required by law.
• CCTV footage will not be accessed or used for any other purpose.
• Access to recorded CCTV footage may be accessed by Selectron in an emergency.
Retention and Security
• CCTV footage is kept for 30 days when it is automatically erased, unless required for a specific investigation (such as criminal damage when it will be kept only for the duration of that investigation).
• We have security measures in place to protect CCTV data.
9. Individual Rights
Every individual has the following data privacy rights:
• The right to be informed: You have the right to know the purposes for which we collect your personal information, how it will be used, and whether it will be shared with third parties.
• The right to access: You have the right to ask us for copies of the personal information we hold about you. This right always applies. We may charge a small fee for this service.
• The right to rectification: You have the right to ask us to correct and / or complete any information you think is inaccurate or incomplete.
• The right to restrict processing: You have the right to request that we restrict the processing of your personal information in certain circumstances (e.g. the accuracy of the information is contested).
• The right to make a complaint: You can file a complaint with Bermuda's Privacy Commissioner if you believe your rights have been violated or if we have failed to comply with PIPA.
10. Cookie Policy
Cookies
Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our website, we may collect information from you automatically through cookies or similar technology.
The Cookies We Use
Our website uses cookies and similar technologies to enhance your browsing experience, analyse website traffic, and enable secure online shopping.
• Essential Cookies: These cookies are fundamental for the website's operation. They manage functionalities like user logins, ensuring that once a customer logs in, they remain authenticated as they navigate the site. This prevents the need for repeated logins on each page.
• Performance and Experience-Related Cookies: These cookies enhance the user’s experience by remembering preferences and settings, providing a more personalised browsing session.
• Form-Related Cookies: When users submit information through forms—such as contact forms or newsletter sign-ups—these cookies may remember user details for future correspondence, streamlining the process for returning users.
• Analytics Cookies: To collect anonymous data on website traffic and user interactions, helping us improve website performance and user experience.
• Social Media Cookies: These are used to connect a website to a third-party social media platform.
• Session Cookies: These are temporary and are deleted once you close your browser. They are used for functions such as keeping items in a shopping cart while a user navigates a site.
• Secure Cookies: These securely transmit your card details to our payment gateway when you order through our website.
You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may impact website functionality.
11. Contact Us
If you have any questions about our Privacy Notice, the information we hold about you, or if you would like to exercise one of your data privacy rights, please contact our Privacy Officer:
Cindy Simmons
(441) 292-0400
info@islandtrading.bm
93 Reid Street
Hamilton HM 19
Bermuda
12. Privacy Commission of Bermuda
If you wish to make a complaint or if you feel we have not addressed your concern in a satisfactory manner, please contact the Privacy Commission of Bermuda at:
PrivCom@privacy.bm
www.privacy.bm
(441) 543 7748
Maxwell Roberts Building, 4th Floor
1 Church Street
Hamilton HM 11