Effective Date: January 1, 2025

Last Updated: June 11, 2025

Bermuda Sloop Foundation (“the Foundation”, “BSF”, “we”, “us”, or “our”), Registered Charity #545, is committed to protecting the privacy of individuals whose personal information we collect and process to support our objectives. This Privacy Notice outlines how we collect, use, disclose, and safeguard personal information in compliance with the Personal Information Protection Act 2016 (PIPA) of Bermuda.

1.       Personal Information

Bermuda Sloop Foundation collects personal information from various individuals, including students, trainee crew, donors, supporters, and website visitors. We may collect, process, and retain the following types of personal information to deliver our services effectively and meet legal obligations:

  • Identity Information: Name;
  • Contact Information: Email address, mailing address, and phone number(s);
  • Transaction Information: Donations, charters and voyage/programme payment details;
  • Photographs and Video: Voyages and events;
  • Programme and Voyage Information: Registration and waiver forms, photo and video release form, emergency contact information, feedback surveys;
  • Charter Information: Charter agreement form;
  • Correspondence: Emails and letters;
  • Technical Information: IP address, browser type and version, time zone setting, location, operating system, and device information;
  • Usage Information: Website analytics and browsing behaviour; and,
  • Marketing & Communication Preferences: Direct marketing preferences.

Sensitive Information

We collect the following additional information from trainee crew when undertaking overseas voyages, some of which is considered sensitive:

  • Age;
  • Gender;
  • Passport and visa information;
  • Medical and dietary information including physician name and location, physical or health limitations; and,
  • Emergency waiver form.

Personal Information about Children

Bermuda Sloop Foundation youth programmes and voyages necessitate the collection of personal data about children, including the following additional information, some of which is considered sensitive:

  • Age;
  • Gender;
  • Race;
  • School information;
  • Health related information (allergies, dietary requirements, mental and physical disabilities); and,
  • Observation notes.

Bermuda Sloop Foundation does not collect personal information about children without the consent of a parent or guardian.

2.       Data Collection

We use different methods to collect personal information including through:

  • Direct interactions. We collect personal information when you:
    • Contact us via our website, email or phone;
    • Make a donation;
    • Interact with one of our employees or consultants;
    • Book a charter;
    • Attend an event;
    • Register for a programme or voyage; and,
    • Meet with us.
  • 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 parties or publicly available sources. We may collect personal information from various third parties such as:
    • Bermuda schools and teachers
    • Programme and outreach partners;
    • Social media platforms; and,
    • Technical data from analytics providers.

3.       Purposes for using your personal information

We only use personal information for the purposes for which it was collected, including:

  • The administration and management of the Foundation;
  • Delivering our programmes and voyages;
  • Communicating with you;
  • Processing and administering donations, voyages, charters, and payments;
  • Ensuring the safety of trainee crew, passengers and visitors onboard Spirit of Bermuda;
  • Promoting our programmes, fundraising campaigns, and activities;
  • Improving our programmes;
  • Fundraising initiatives and applications;
  • Research and analysis purposes;
  • Distributing event invitations and related communications;
  • Student awards and recognition;
  • Improving and enhancing the functionality and user experience of our website; and,
  • Maintaining proper records for internal governance and financial oversight.

4.       Conditions for Processing Personal Information

We collect and use personal information to achieve our charitable objectives. This information is only used in compliance with PIPA and where:

  • It is necessary for our legitimate interests, and these interests do not override your fundamental rights;
  • 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;
  • We need to comply with a legal or regulatory obligation; and/or
  • You have given us consent.

5.       Third-Party Sharing

We require all third parties to respect the security of your personal information and to process it in compliance with PIPA. We do not permit our third-party service providers to use your personal information for their own purposes. Third-parties 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 operations and objectives;
  • Volunteers and partner organisations, if they assist with Bermuda Sloop Foundation voyages, charters, events, and activities;
  • Our Board Members, where necessary for governance and decision-making purposes;
  • Supporters and donors, when fundraising and promoting our programmes;
  • 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;
  • The public, through our website, marketing materials and social media platforms;
  • Our data storage providers;
  • Government authorities and regulatory bodies; and,
  • Law enforcement agencies when required to comply with legal obligations, court orders, or official requests.

Bermuda Sloop Foundation does not sell personal information.

6.       Security of Information

We have implemented appropriate operational, technical, and physical security measures to protect your personal information from loss, unauthorised access, alteration, or disclosure. These measures include:

  • Secure premises
  • Secure IT systems and data storage
  • Implementing data processing agreements with third parties
  • Regular security reviews
  • Employee training
  • Access controls

7.       Retention

We retain personal information as long as needed for its intended purpose or to meet regulatory requirements.

8.       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 lodge 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.

9.       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 and analyse website traffic.

  • Essential Cookies: These cookies are fundamental for the website’s operation.
  • 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.
  • Session Cookies: These are temporary and are deleted once you close your browser.
  • Secure Cookies: These securely transmit your card details to our payment gateway when you make a donation through our website. 

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may impact website functionality.

10.    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:

Erica Martin: (441) 537 4614 | privacy@bermudasloop.org

International Center, Suite 505, 26 Bermudiana Road, Hamilton HM 11, Bermuda 

11.    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, Bermuda