Privacy Notice
Introduction
The Neptune Group Ltd. and its subsidiaries (collectively, the “Company”) are committed to maintaining the accuracy, confidentiality and security of your personal information that we process in Bermuda. Our business office is at Par-La-Ville Place, 14 Par-La-Ville Road, Hamilton, HM 08, Bermuda.
The Company is a group of companies with operations both inside and outside of Bermuda. It is the Company’s policy to ensure compliance with the privacy laws of each jurisdiction in which it operates. It is important to be aware that privacy laws and an individual’s right to privacy may differ from one jurisdiction to another.
This Privacy Notice sets out:
What Personal Information Do We Collect?
We collect and maintain various types of personal information in respect of individuals depending on the purposes for which such personal information is required:
- Information relating to any request to provide goods or services to you, including your name, address, and contact details.
- Details of your visits to our website and information collected through automated cookies and, including, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, usage information and the resources that you access.
- Information you supply when you directly interact with us.
Sensitive personal information we collect may include:
- information relating to any criminal or fraudulent activities provided to us by you or third parties (such as anti-money laundering agencies, government bodies or insurers);
- information used in fraud prevention or sanctions checking against public lists
How is Your Personal Information Collected?
In most cases, the Company collects personal information directly from you. However, should we be required to collect your personal information from a third party, we will obtain your permission prior to requesting this information (such permission may be given directly by you or, in certain circumstances, implied from your actions).
From time to time, we may utilize the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have the authority to disclose your personal information to us.
Where permitted or required by applicable law or regulatory requirements, we may collect personal information without your knowledge or consent. We may also obtain personal information from publicly available sources.
Why Do We Collect Personal Information?
The personal information collected by the Company is used and disclosed for our business purposes, including establishing, managing or conducting customer or supplier relationships such as fulfilling contracts for the transport, shipping, import and delivery of goods or services.
We may also be required under various reporting or regulatory regimes to collect personal information to comply with Bermuda law, for example to comply with “Know Your Client” rules under the anti-money laundering and anti-terrorist financing regulations.
How Do We Use Your Personal Information?
We may use your personal information:
- for the purposes described in this Privacy Notice or any other privacy notice issued by the Company; or
- for any additional purposes that we advise you of and, where your consent is required by law, we have obtained your consent in respect of the use or disclosure of your personal information.
Where we are permitted or required by applicable law or regulatory requirements, may use your personal information without your knowledge or consent.
Disclosure of Personal Information
We may share your personal information with our employees, contractors, consultants and other third parties who require such information to assist us with establishing, managing or conducting the Company’s business, including:
- persons that provide products or services to us or on our behalf;
- persons that collaborate with us in the provision of our products or services; and
- persons that provide information technology and data processing services to us to operate our business.
In addition, personal information may be disclosed or transferred to another party in the event of a change in ownership of, or a grant of a security interest in, all or a part of the Company through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Notice, unless you consent otherwise.
Further, your personal information may be disclosed:
- as permitted or required by applicable law or regulatory requirements. In such a case, we will endeavor to not disclose more personal information than is required under the circumstances;
- to comply with valid legal processes such as search warrants, subpoenas or court orders;
- as part of the Company’s regular reporting activities (including to meet reporting requirements outside of Bermuda);
- to protect the rights and property of the Company;
- during emergency situations or where necessary to protect the safety of a person or group of persons;
- where the personal information is publicly available; or
- with your consent where such consent is required by law.
When we share personal information with such persons, we require that they only use or disclose such personal information in a manner consistent with the use and disclosure provisions of this Privacy Notice.
There may be circumstances where third parties are located outside of Bermuda, and as a result, your personal information may be collected, used, processed, stored or disclosed in another jurisdiction. Personal information is only transferred by us to an overseas third party, if the transfer meets the requirements of PIPA in respect of overseas transfers. Where the jurisdiction is not a reciprocal jurisdiction assigned by the Privacy Commissioner or the Company is not satisfied that the overseas third party provides an adequate level of protection for the personal information to meet the requirements of PIPA, we will implement additional safeguarding measures, such as contractual mechanisms or encryption to protect the information or we may, if possible to still meet the purposes, anonymise the information so that it is no longer personal information.
Rights of Individuals
Under PIPA, you have rights when it comes to our use of your personal information, which include:
- the right to access personal information belonging to you which is in the custody or under the control of the Company;
- the right to be informed about the purposes for which your personal information has been and is being used by the Company;
- the right to know the names of the persons or types of persons to whom and circumstances in which your personal information has been and is being disclosed;
- the right to access personal information about you of a medical or psychiatric nature;
- the right to make a written request to the Company to correct an error or omission in any of the personal information which is under the control of the Company;
- the right to request that the Company refrains from using your personal information for the purposes of advertising, marketing or public relations or where the use of personal information is likely to cause substantial damage or substantial distress to you or another individual;
- the right to request that the Company erases or destroys your personal information where that personal information is no longer relevant for the purposes of its use;
- the right to restrict the processing of your personal information;
- the right to be informed of a personal information breach (unless the breach is unlikely to be prejudicial); and
- the right to complain to the Privacy Commissioner.
Notification and Consent
PIPA does not place a general requirement on the Company to obtain your consent for the collection, use or disclosure of personal information. However, to the extent that your consent is required, in relation to us collecting, using and disclosing your personal information for the purposes stated in this Privacy Notice, we may imply your consent from your actions unless you advise us otherwise.
Where your consent is required for our collection, use or disclosure of your personal information, you may, at any time, subject to legal or contractual restrictions and reasonable notice, withdraw your consent. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.
In addition, you are advised that, where we are permitted or required by applicable law or regulatory requirements to do so, we may collect, use or disclose your personal information without your knowledge or consent.
How is Your Personal Information Protected?
The Company endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.
For more information on the specific safeguards implemented by the Company, please contact our Privacy Officer.
How Long is Your Personal Information Retained?
Except as otherwise permitted or required by applicable law or regulatory requirements, the Company endeavors to retain your personal information only for as long as it is necessary to fulfill the purposes for which the personal information is collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations). We may, instead of destroying or erasing your personal information, make it anonymous such that it cannot be used to identify you as an individual.
Access to and Updating Your Personal Information
You may request access to the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact the office of our Privacy Officer using the contact information set out below.
It is important that the information contained in our records is both accurate and current. If your personal information happens to change, please keep us informed of such changes so that we can ensure the personal information we hold for you is up to date.
All requests for access or updates to your personal information must be made in writing addressed to the Privacy Officer. When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you.
Your right to access and the personal information that we hold about you is not absolute. There may be circumstances where we may not be able to fulfill your request to change your personal information and will instead append an alternative text to the record in question. There may also be instances where applicable law or regulatory requirements allow or require us to refuse to provide access to some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or anonymized in accordance with our record retention obligations and practices.
In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.
Inquiries or Concerns?
If you have any questions about this Privacy Notice or concerns about how we manage your personal information, please contact our Privacy Officer at privacy@ngl.bm or write us at 14 Par-La-Ville Road, 1st Floor, Hamilton HM 08, Bermuda.
We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are not satisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner.
Revisions to this Privacy Notice
The Company may from time to time update this Privacy Notice to reflect changes in its legal or regulatory obligations or a change in how we deal with or the purposes for which we collect your personal information.
Any changes to this Privacy Notice will be effective from the time they are posted on our website. Please check our website periodically at www.neptunebermuda.com to see if any changes have been made.
Last updated November 2024