Gateway Systems Limited

Privacy Notice & Cookies Policy

Privacy Notice Effective Date: November 20th, 2024

This privacy notice sets out how Gateway Systems Limited ("we," "our," or "us") use your personal information when you visit the Gateway Website. Please read this page carefully and contact us if you have any questions. By using this Website, you are agreeing that you have both read this document and have understood its contents.

The purpose of the Personal Information Protection Act 2016 (PIPA) is to provide individuals in Bermuda with the right of informational privacy protection.


1. Contact Us

Gateway Systems Limited is a limited liability company. 
The registered Office is located at:
Gateway Systems Limited
Thistle House, 4 Burnaby Street
Hamilton HM11, Bermuda
Tel: +1 (441) 292-0341

Our Privacy Officer can be contacted at:privacy@gateway.bm 
Gateway Systems Limited
Hamilton House, 10 Queen Street
Hamilton HM11, Bermuda
Tel: +1 (441) 292-0341


2. Your Rights 

We will do all we reasonably can to assist you with any issue arising from our use of your personal information. 
When the PIPA comes into force on January 1, 2025, your full legal rights will consist of the following.

You have the right to:
- request access to personal information we have collected about you (further referred to as “your PI”);
- request that we correct any inaccuracies within your PI;
- request that we erase and destroy your PI;
- request that your PI shall not be used for the purposes of advertising, marketing or public relations;
- request that usage of your PI that is causing or is likely to cause substantial damage or distress ceases.

Please note that not all privacy rights are absolute rights.
They may be subject to specific conditions and exemptions.
You will also be required to provide proof of identity to access these rights.
Please contact our privacy Officer for further information at privacy@gateway.bm

From January 1, 2025, if you are not satisfied to the extent that these rights apply to you, you are entitled to complain directly to the Privacy Commissioner for Bermuda at PrivCom@privacy.bm or call 1-441-543-PRIV [-7748]


3. Personal Information We May Collect: 

-
Cookies (see section 10);
- Personal information that you may provide to us in an email.


4. The Legal Basis For Our Use 

PIPA requires us to identify the legal basis for our use of your personal information.
Our legal basis for use is:
- inferred consent though your accessing of our Website; and/or 
- that you would not reasonably request us to “not begin or cease” using your personal information;
- For the steps taken at the request of the individual with a view to entering into a contract, or the performance of a contract.


5. How We Use Your Personal Information

We may use your personal information for the following purposes: 
- to enable enhanced functionality of our Website;
- to conduct business with you or to provide you with the services you have requested, including responding to your enquiries and requests and providing you with support;
- To serve you more efficiently.


6. Who Has Access To Your Personal Information  

Your personal information is used by the relevant areas:
- in order to provide your requested services or respond to queries;
- to improve your Website experience.

All our staff understand their obligation to maintain customer personal information subject to conditions of confidence.
Only relevant staff are permitted access to customer personal information. We disclose only the personal information that is necessary to deliver the services you require to those staff members relevant to the task.


7. Transfer Of Your Personal Information To Organisations In Bermuda And Overseas 

We may transfer your personal information to third parties within Bermuda and overseas for the purposes of completing tasks relating to our Website and/or the delivery of our services. 

Before any information is shared overseas all third parties are thoroughly vetted to ensure that they comply with security requirements to protect your personal information that meet the requirements of the PIPA. If any organisation does not meet these requirements, additional reasonable measures are employed to protect your personal information when dealing with relevant third parties.

When we use third party service providers overseas, we disclose only the personal information that is necessary to those organisations and individuals relevant to the task. 
- We will not share your personal information with third parties for marketing purposes.
- We will not sell or rent your personal information.


8. Retention Period Of Personal Information

We are legally required to hold some types of personal information to fulfil our statutory obligations. We will hold your personal information only for so long as it is necessary for the relevant activity, or for internal audit and quality control purposes. We review our retention periods for personal information on a regular basis. 


9. Security 

We constantly monitor the security of our systems, and we review our policies and procedures on a regular basis.
Information transmitted normally over the internet can never be guaranteed as 100% secure.
As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us. Once we receive your personal information, we make all reasonable and appropriate efforts to ensure its security on our systems. 


10. Cookies, and Website Analytics 

Information regarding how you access this Site (e.g., browser type, access times and IP address) and your hardware and software can automatically be collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools.

This information is typically used to improve Site performance and for our business purposes, including to help provide you with a better experience when you browse the Site. 

We collect necessary cookies and personal information, such as your session ID, IP address, authentication information, time of login (time stamp), etc.

This personal information allows us to relate the visitor's session to server-side information. The cookies act as a reference to the session created. Whenever an activity is performed on our Website, our server recognises your session ID and validates that activity.We do not collect any non-essential Cookies.

Typically, you may opt-in to accept cookies automatically by changing the settings on your browser. You also may at any time withdraw your consent to the use of cookies at any time by deactivating the cookies. If you use that option for the necessary/essential cookies, some functions of this Website may not work.

You can find out more about our cookies on www.allaboutcookies.org.

You can delete cookies on these browsers:
- Microsoft Edge
-
Chrome
-
Safari
-
Firefox


11. Privacy Notice Administrative Details

Privacy notice No:
4
Effective Date: November 2024

On occasion we will update this privacy notice. Any amended privacy notice becomes effective once published.