Commitment to Privacy

ASW Law Limited, and its affiliated entities including Compass Administration Services Ltd. (collectively “ASW”, “us” “our” and “we”), is committed to being a responsible custodian of the information you provide to us and the information we collect in the course of operating our business and providing legal services. This Privacy Policy documents our commitment to protecting your personal information.

“Personal Information” is any information that can be used to identify you or that we can link to you as an individual and may include:

  • full name, date of birth, passport, driving licence or other photographic identity details;
  • contact information including postal address, email address and telephone number(s);
  • demographic information such as postcode, preferences and interests;
  • information pertinent to fulfilling our legal services on an individual’s or organisation’s behalf; and
  • information we collect automatically through cookies and similar tracking technologies through our website.

Responsibility

ASW is responsible for personal information in its possession or control. We have designated an individual to be responsible for compliance with this Privacy Policy, contact details for whom are provided below, and have procedures to protect personal information, receive and respond to complaints and inquiries, train staff regarding policies and procedures and communicate our policies to you. We will monitor ongoing developments in privacy legislation and make changes to our Privacy Policy as required.

Purposes

ASW may come into the possession of personal information in order to provide professional services. Your personal information may be used for the following purposes:

  • To meet our regulatory, legal and professional obligations, including undertaking appropriate anti-money laundering checks;
  • To establish and manage our relationship with you;
  • To provide legal advice and services, including e-updates on law and regulation in Bermuda;
  • To monitor and manage the performance of our business operations;
  • To manage conflicts of interest and maintain our list of contacts;
  • To analyze performance, and generate internal reports;
  • To assess the effectiveness of our events, promotional campaigns and publications;
  • To assess risks including legal and financial risks;
  • To invoice and process payments;
  • To process applications for employment;
  • To monitor visitor traffic to and usage of the ASW website;
  • To market our services;
  • To engage in business transactions; and
  • For any other purposes for which we have your consent.

In delivering our services to you, your personal information may be transferred between our servers and affiliated entities. ASW may, from time to time, use third parties in which event ASW will use reasonable efforts to seek an agreement from third party vendors to be bound by the terms of this Privacy Policy or a similar policy.

Consent

By agreeing to the provision of services by ASW, you consent to ASW using your personal information for the purposes identified above and to making any necessary cross-border transfers of your personal information. Your personal information may be shared with third parties for the purposes described in this Privacy Policy.

Limits on Collection, Use, Retention and Disclosure of Personal Information

ASW collects and uses only that personal information which is required by ASW to perform its professional services and operate its business and as set out in this Privacy Policy.

We do not sell, rent, or otherwise share any information with unaffiliated entities except as expressly described in this Privacy Policy or with your prior permission. We may share anonymised information that does not reasonably identify you or your organization only as permitted by applicable law.

ASW does not retain any more of your personal information than we believe is necessary for any of the purposes set out in this Privacy Policy or which is dictated by legal or professional requirements. We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information or retention is no longer necessary for legal, business or professional purposes. We will take reasonable care when destroying personal information so as to prevent unauthorized access to the personal information.

Accuracy

You are required to advise us of any changes that may impact the services we are providing. From time to time, you may be asked to verify or update your personal information.

Safeguarding Personal Information

ASW protects the personal information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification or disposal. Confidentiality and security are not assured when information is transmitted through e-mail or other wireless communication. ASW will not be responsible for any loss or damage suffered as a result of a breach of security and/or confidentiality when information is transmitted by e-mail or wireless communication. We will take your use of a particular mode of communication to be implied consent for us to communicate with you using the same mode of communication unless otherwise instructed by you.

Cookies and Our Website

Our website uses cookies. Find out more about cookies, how we use them, and how to manage them below. By using our website, you agree that we can place these types of cookies on your device.

Cookies are small files that are downloaded onto your computer to help improve your browsing experience and enable us to evaluate how people use our website. We currently use a session cookie and a persistent cookie. The session cookie is temporary and stored on your computer only for as long as you visit our website. The persistent cookie is uploaded to your computer only after you check the “Remember Me” box and enables you to store information to more quickly access password protected portions of our website.

Our website may from time to time contain links to third party websites. ASW does not take responsibility for the privacy practices of any third party website. Please ensure you read the policies of any third party website you visit.

Third-party vendors, including Google, may use cookies to serve ads based on a user’s past visits to our website. Third-party advertising vendors, including Google, may show our ads on sites across the Internet based on your past browser history. This practice is commonly known as remarketing.

Most web browsers (Chrome, Internet Explorer, Safari) accept cookies and allow you to control your cookie settings on your computer or other device. To control the use of cookies on your device, including deleting and blocking the cookies any website uses, including ours, access your browser settings. Please note that any changes may affect your ability to properly use this website.

You can opt out of Google’s use of cookies by visiting Google’s Ads Settings. Alternatively, you can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page. You can also opt out of being tracked by Google Analytics across all websites by visiting http://tools.google.com/dlpage/gaoptout.

Compliance

ASW has procedures in place to receive and respond to inquiries about our policies and practices relating to the handling of personal information.

Providing Access

You have a right to access your personal information held by ASW. Your information will be provided upon written request and authentication of identity. We may charge a reasonable fee for providing information in response to a privacy access request and will provide an estimate of any such fee upon request.

If you have any further questions about this Privacy Policy or your personal information you may direct your inquiries in writing to Neil Horner, the Privacy Officer of ASW at neil.horner@aswlaw.com or write to us at 50 Cedar Avenue, Hamilton Bermuda HM11.

ASW reserves the right to amend this policy from time to time without prior notice to you. Please check our website periodically at www.aswlaw.com to see if any changes have been made.