Privacy Policy

Privacy Policy

1. INTRODUCTION
Gnosis Limited hereafter referred to as “Gnosis” is committed to protecting your personal information in accordance with the Bermuda Personal Information Protection Act (PIPA) and other laws applicable to Gnosis. This Privacy Notice explains how we collect, use, disclose, and protect your personal information. This Privacy Notice also tells you about the rights and choices you may have under PIPA when it comes to your personal information. The terms “personal information,” “sensitive personal information,” and “use” have the meaning ascribed to them under PIPA.

PLEASE READ THIS PRIVACY NOTICE CAREFULLY TO UNDERSTAND HOW WE USE YOUR PERSONAL INFORMATION.

This Privacy Notice applies when you:
- Receive or use our products and services
- Visit our website at https://gnosis.bm or any of our other websites that link to this Privacy Notice

2. HOW WE COLLECT PERSONAL INFORMATION
We may collect personal information from you in the following ways:

- Directly from you: Information you provide to us through forms, applications, contracts, or other interactions with us.

- Automatically: Data we collect through the services we provide, our websites, our applications, and other digital platforms.

- From Third Parties: Information provided to us by third party service providers, partners, or publicly available sources.

3. TYPES OF INFORMATION WE COLLECT
Depending on the products and services you recieve from us and the applications, websites, and systems you use, we may collect the following information:

- Contact information, such as your full name, home address, telephone number, and email address.

- Billing information, such as billing addresses, financial and payment information, and financial transactions information.

- Identification information, used to identify who you are, such as birth date and government issued identification.

- Service information, such as types of services, subscriptions, service activity, device information, IP address, geographic location, and call detail records.

- Any other information you provide to us with your consent that we require for our business operations and services.

COOKIES
We use cookies (small files placed on your computer or device) and other common tracking technologies, which may include HTTP cookies, HTML5 and Flash local storage/flash cookies, web beacons/GIFs, embedded scripts, ETags/cache browsers, and software development kits (referred to together from this point forward as “Cookies,” unless otherwise stated)

You may opt out of certain cookies by setting your choice in the Cookie Preference Center that is available to you in our Cookie banner when you first access our website.  To change your preferences, use your browser settings to clear cookies and you will be presented with our Cookie banner where you can access the Cookie Preference Center.

We categorize our Cookies as either Essential, Advertising, Analytics & Customization or Performance & Functionality.

- Essential Cookies: These Cookies are required for site functionality, including for system administration, security, and fraud prevention, and to enable any purchasing capabilities. You cannot opt out of Essential Cookies.  If you block Essential Cookies with your browser settings, some parts of the site may not function properly.

- Advertising Cookies:
These Cookies collect data about your website visits, your use of the site, your preferences, and your interaction with advertisements across platforms and devices for the purpose of delivering personalized advertising content on and off the site. Third-party sites and services also use personalized advertising Cookies to deliver content, including advertisements relevant to your interests. If you reject these Cookies, you will still see advertising, but it may be less relevant.

- Analytics & Customization Cookies:
These Cookies collect data regarding your usage of and performance of the site. We and our vendors use these Cookies to perform analytics, to improve the content and user experience, for statistical purposes, to improve the site, and develop new services. They are also used to recognize your device across platforms and devices for the above purposes.  You may opt out of these Cookies, but it may impact your experience on our sites.

- Performance & Functionality Cookies:
These Cookies enable us to provide certain features, such as determining if you are a first-time visitor, remembering choices you have made, and assisting you with logging in after registration. Data collected under this category can also be used to select and deliver personalized content and measure the delivery and effectiveness of that content.  You may opt out of these Cookies, but it may impact your experience on our site.
4. HOW WE USE YOUR PERSONAL INFORMATION
It is important to us that we use your personal information in a lawful and fair manner. We will only use your information where we have a lawful basis for doing so. For example, we collect and use your personal information for a variety of reasons, depending on how you interact with us, including:

- To provide and manage our products and services.

- To communicate with you, including sending service updates, completing service requests and/or marketing communications (where permitted with consent).

- To improve our services and enhance our user and customer experiences.

- To prevent fraud and ensure security of information and data.

- To comply with legal and regulatory requirements. We may use your information when necessary to meet our legal and regulatory obligations.

5. SHARING YOUR PERSONAL INFORMATION
We share personal information with others when it is needed to provide you with our products and services. We also share personal information with others:

- When you direct us to do so, including fulfilling orders of third-party products and services that you purchase through use and authorizing other users on your account.

- When required by law or to respond to legal process such as a subpoena or warrant.

- To protect our property and rights or the safety of our employees, our customers, or other individuals

We may share your personal information with:

- Third party service providers and vendors who may assist us in our operational processes and/or deliver our products and services.

- Government authorities, law firms or regulators comply with legal obligations.

- Other third parties with your explicit consent.

We ensure all third parties with whom we share data and information adhere to data protection laws and implement adequate safeguards.

6. RETENTION AND DELETION
We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Once the information is no longer needed, we securely delete or anonymize it in accordance with applicable laws or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We implement reasonable physical, technical, and organizational measures to protect the personal information we collect from unauthorized access, alteration, disclosure, or destruction.  This includes, as applicable, measures including, but not limited to, access control lists, multi-factor authentication, firewalls, vulnerability scanning, encryption and network authentication.  These measures may vary depending on the type and sensitivity of the information.

Note that electronic transmission over the internet and electronic information storage technology cannot be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

7. YOUR RIGHTS
Under PIPA, you have the following rights regarding your personal information:

- Right to request access: You have the right to request access to your personal information and the right to know the purposes for which we hold your personal information and the organizations to whom your information has been shared

- Right to rectification/correction: You may request that we correct or update inaccurate personal information.

- Right to erasure: You may request that we erase or destroy your personal information where it is no longer relevant for the purposes of its use.

- Right to object or withdraw consent: You may object to the processing of your personal information for purposes of advertising, marketing or public relations, or where the use of that personal information is causing or is likely to cause substantial damage or substantial distress to you or to another individual

Please note that in some circumstances we may not be required to fully comply with your request, for example, if your request jeopardizes the privacy, life or security rights of others, or if it is not required by law.  In those circumstances, we will still respond to notify you of such a decision.

If you wish to exercise any of these rights, please contact us using the details provided below:

Privacy Officer
Gnosis Limited
99 Front St
Hamilton HM 11
441.405.9900
Privacy@gnosis.bm

We reserve the right to request authentication of identity in the event of such a request.

8. CHANGES TO PRIVACY NOTICE
We reserve the right to update or amend this Privacy Notice at any time. Any changes will be posted on our website.  We encourage you to review this Privacy Notice regularly for updates.

9. CONTACT US
If you have questions or comments about this notice, you may contact us by one of the following means:
- Send an email to Privacy@gnosis.bm
- Call us on 441.405.9900
- Mail us to the address below:
Privacy Officer
Gnosis Limited
99 Front Street
Hamilton HM 11