Privacy Policy

Last modified October 28, 2020 

PLEASE REVIEW THIS POLICY CAREFULLY

The following describes how Transform (Bermuda) (“Transform,” “I,” “me” or “my”) uses and disseminates information you provide through www.transformbda.com and its sub-domains and affiliated sites (the “Website”), as well as Transform’s pages and accounts on Twitter®, Facebook®, LinkedIn®, Google Plus®, Instagram® and YouTube® (the “Sites). If you ever have questions about this Privacy Policy, please contact me at the information below. Please also review Transform’s full Terms and Conditions of Use, which also govern your use of the Website and Transform’s pages and accounts on the Sites. By using the Website and Transform’s pages and accounts on the Sites, you are consenting to this Privacy Policy.

 

COLLECTION OF YOUR PERSONAL INFORMATION

Unless expressly note otherwise, Transform does not collect personally identifiable information from users of its Website and its pages and accounts on the Sites. When you visit the Website and Transform’s pages and accounts on the Sites, some information about your computer hardware and software is automatically collected, such as your IP address, domain name, browser type, access time and referring website addresses. Transform typically does not use this information for any purpose, but an example of when Transform may use this information is in implementing improvements and analyzing its Website and pages and accounts on the Sites and for troubleshooting purposes. Transform also utilizes this information to monitor and improve services and to ensure that your use of the Website and Transform’s pages and accounts on the Sites is in compliance with its Terms & Conditions policy. Most of Transform’s services do not require any form of registration, allowing you to visit its Website and its pages and accounts on the Sites without telling us who you are. However, some services, such as email opt-ins may require you to provide us with your name, email address, contact number and reasons for the connection request (“Personal Data”). In such a case, you may choose to withhold any Personal Data requested by us, but it may not be possible for you to gain access to certain parts of the site or content. Transform requires only the information that is reasonably required to enter into a contract with you. We will not require you to provide consent for any unnecessary processing as a condition of entering into a contract with Transform.

  

INTERNATIONAL PRIVACY LAWS AND YOUR RIGHTS UNDER THE GDPR

If you are visiting the Site from outside the United States, please be aware that you are sending information to the United States where Transform’s servers are located. Information you submit may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by Transform. These countries (including the United States) may not necessarily have data protection laws as comprehensive protective as your country of residence; however, Transform’s collection, storage, and use of your data will at all times continue to be governed by this Privacy Policy.

If you are a member of the European Union (EU), you have special rights under the GDPR. Those include: You have the right to object to the processing of your data and the right to portability of your data. All complaints must be sent to pamela@transformbda.com. You also have the right to erasure, rectification, access, or to seek restrictions to the processing of your personal data in our system. To the extent you provide consent to Transform’s processing of your personal data, you have the right to withdraw that consent at any time. Any withdrawal of consent does not apply to data collected lawfully prior to such consent. You have the right to lodge a complaint with a supervisory authority containing jurisdiction over GDPR related issues.

 

COOKIES: WHAT THEY ARE, AND WHY THEY ARE NEEDED

A cookie is a data text file sent from a website to your browser, for the purpose of identifying the user and allows access to portions of the website, thus alleviating the need to continually log in with your username and password. Cookies may be stored within your system. To the extent Transform use cookies, Transform can only access information from a cookie sent by one of the Sites, not other websites. Transform may use cookies to personalize your visit to the Website or Transform’s pages and accounts on the Sites, because tracking usage allows Transform to best determine the needs of its customers and advertisers.

 

TRANSFORM’S POLICY WITH MINORS

Transform’s Website and pages and accounts on the Sites are not intended for individuals under the age of 18. If you are under 18, you may only use the Website and Transform’s pages and accounts on the Sites under the supervision of a parent or guardian. I do not collect or maintain information from anyone known to be under the age of 18, and no part of this Website is designed to attract anyone under the age of 18. I do not sell products or services intended for purchase by children. If Transform discover or are otherwise notified that it has received any such information from a child in violation of this policy, Transform will delete that information.

 

DATA RETENTION

Transform only retains Personal Data collected from Users for as long as the User’s account is active or otherwise for a limited period of time as long as Transform needs it to fulfill the purposes for which it initially collected it, unless otherwise required by law. Transform will retain and use information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements for a period of 10 years.

 

USE OF YOUR PERSONAL INFORMATION

If you do choose to provide your personal information, Transform will not willingly share your information with companies outside its organization, except as described in this Privacy Policy.  You may at times receive communications from Transform related to products and services that Transform believes might interest you. While Transform believes these services may enhance your time spent on its Website and pages and accounts on the Sites, you will at all times have the option and ability to opt out from receiving these communications by specifically choosing to do so via a link which will be provided within emails that are sent to you. Transform may disclose total aggregated user statistics in order to describe its services to potential advertisers, other third parties, affiliate companies, and for other lawful purposes.

The information Transform gathers from you may be used in several ways, either now or in the future, to gain a better understanding of the Website and its pages and accounts on the Sites.  Transform may want to understand the users and their usage pattern as a whole for site administration and troubleshooting, to process transactions, contest entries and other matters you initiate, to identify preferences in content and advertising, to target editorial, advertising or other content (such as promotions, special offers or other content) Transform thinks might be of interest to you. Transform may also use information gathered from you to communicate changes and improvements to the Website or any registration you have made.

You have the right to request access to the information we have for you. You can do this by contacting us at pamela@transformbda.com We will make sure to provide you with a copy of the data we process about you In order to comply with your request, we may ask you to verify your identity. We will fulfill your request by sending your copy electronically unless the request specifies a different method. If you believe that the information we have about it is incorrect, or if you wish to remove your private information (such as an email address provided in an opt-in), you may contact us at pamela@transformbda.com. Any data that is no longer needed for the purposes specified herein will be deleted.

Transform does not give away, sell, rent, or lease any users’ personally identifiable information to any merchant, advertiser or web publisher. However, non-personally identifiable user information (such as usage pattern, browser type and your computer) may be shared with third-party businesses or advertisers with which Transform has a business or contractual relationship. Transform reserves the right to disclose personal information when needed to comply with the law or a legal process, cooperate with investigations of purported unlawful activities, to identify persons violating the law, in connection with the sale of part or all of Transform or its affiliates’ assets, or to enforce Transform’s Terms & Conditions policy.

Please keep in mind that if you disclose personally identifiable information in a public manner through the Website or Transform’s pages and accounts on the Sites, this information may be collected and used by others accessing those portions of the Website and the Sites. Transform does not monitor information you disclose on the Website and the Sites nor does Transform accept any liability associated with your voluntary disclosure of the same.

You are responsible for reviewing the privacy statements and policies of other websites you choose to link to or from the Website and Transform’s pages and accounts on the Sites, so that you may understand how those sites collect, use and store your information. Transform is not responsible for the privacy statements, policies, or content of any other websites. Websites containing co-branding (referencing Transform’s name and a third-party’s name) contain content delivered by the third party and not me.

  

NOTICE OF PRIVACY RIGHTS TO CALIFORNIA RESIDENTS

California law requires that I provide you with a summary of your privacy rights under the California Online Privacy Protection Act (the “Act”) and the California Business and Professions Code. As required by the Act, I will provide you with the categories of personally identifiable information that I collect through this website and the categories of third-party persons or entities with whom such personally identifiable information may be shared for direct marketing purposes at your request. California law requires me to inform you, at your request: (1) the categories of personally identifiable information I collect and what third parties I share that information with; (2) the names and addresses of those third parties; and (3) examples of the products marketed by those companies. The Act further requires me to allow you to control who I can and cannot share that information with. To obtain this information, please send a request by email or standard mail to the address found below. When contacting me please indicate your name, address, email address, and what personally identifiable information you do not want me to share with third parties. Please allow thirty (30) days for a response. Also, please note that there is no charge for controlling the sharing of your personally identifiable information or requesting this notice.

 

LIMITATIONS

By using the Website and Transform’s pages and accounts on the Sites you agree that I am not responsible for: (i) any disclosure of your personal information made by you to a third party through your use of the Website and Transform’s pages and accounts on the Sites; (ii) any disclosure of your personal information obtained illegally from Transform; or (iii) any accidental disclosure of your personal information made by Transform.

 

POLICY CHANGES

Transform may modify this Privacy Policy from time to time. Any modifications will be effective immediately when they are posted. Transform will take steps to notify users of any modifications, however, you are responsible for reviewing any modified terms. When Transform updates its Policy, I will note the date of revisions at the top of the Policy. Your continued use of a Site following any changes means you accept and agree to any changes. For your convenience and future reference, the date of the Privacy Policy is included so that you can compare any different versions of the Privacy Policy to determine any changes made to the Privacy Policy.

YOUR COMMENTS AND CONCERNS

This website is operated by Transform (Bermuda), Gatehouse, 26 Lover’s Lane Paget Bermuda. All other feedback, comments, requests for technical support and other communications relating to the Sites should be directed to: pamela@transformbda.com.

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