1. IN GENERAL

We, the team of TheBermuda, Inc. and Bermuda process your personal data when you use our app (“Bermuda,” “us,” “we,” “our” or “app”) or website (“Website” and, together with the app, “Products”). The processing of your personal data takes place in compliance with the General Data Protection Regulation (“GDPR“) and the South Korean data protection act in its current form.

In this privacy policy (“Privacy Policy”) we want to provide you with information about us, the nature, scope and purposes of the data collection and use, giving you insights into the processing of your personal data.



2. CONTROLLER


3. COLLECT AND PROCESS

This Privacy Policy applies to websites, apps, and other services operated by us. We process personal data that you as a user of the Products make available to us, for example by using our Products, and that users provide to us (“Data”).

We can’t help you develop meaningful connections without some data about you, such as basic profile details and the types of people you’d like to meet. We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account. If you want additional info, we go into more detail below.


Data you give us

You choose to provide us with certain information when using our services. This includes:


Data from others

In addition to the information you provide us directly, we receive information about you from others, including:


Data collected when you use our services

When you use our services, we collect information about which features you’ve used, how you’ve used them, and the devices you use to access our services. See below for more details:


Cookies

The website uses 'cookies' – small text files that are placed on your computer, mobile device and/or stored by the browser. The basis for the processing of Data via cookies are our legitimate interests. We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s).




4. PURPOSE

We use your data to deliver our services and help keep you safe.


Operating the Products


Business Needs


Compliance and Enforcement



5. SHARING OF PERSONAL DATA


With other users

You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publically viewable since neither you nor we can control what others do with your information once you share it.

If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.


With our service providers and partners

We share your information to others, who help us provide and improve our Products (e.g., maintenance, analysis, audit, payments, fraud detection, marketing, and development). Service providers will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

We use processors such as Appsflyer, Google, Facebook, Amazon Web Services, Inc., or Zendesk, Inc.


For corporate transactions

We may transfer your data if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

When required by law

We may disclose your data if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

To enforce legal rights

We may also share data: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.


With your consent or at your request

We may ask for your consent to share your data with third parties. In any such case, we will make it clear why we want to share the information.

We may use and share non-personal data (meaning data that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances.

We may also share this information with other third parties (notably advertisers) to develop and deliver targeted advertising on our products or applications of third parties, and to analyze and report on advertising you see. We may combine this data with additional non-personal information or personal data in hashed, non-human readable form collected from other sources.


6. HOW LONG WE STORE DATA

A deletion request does not affect Data, if the storage is legally necessary, for example for accounting purposes.


7. WHICH RIGHTS YOU HAVE

We want you to be in control of your information, so we have provided you with the following tools:


We want you to be aware of your privacy rights. Here are a few key points to remember:


For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.

Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.



8. FURTHER IMPORTANT INFORMATION


We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately via our customer care.



9. HOW TO CONTACT US

Data Protection Officer

Company has designated the person in charge of personal data protection as below for inquiries and complaints about personal information of users.

If we make material changes to this policy, we will notify you by publishing a revised Privacy Policy or by means of a notice on our website, or as required by law. You agree to review the Privacy Policy periodically so that you are aware of any modifications. You agree that your continued use of the Service after we publish a revised Privacy Policy or provide a notice on our website constitutes your acceptance of the revised Privacy Policy. If you do not agree with the terms of the Privacy Policy, you should not use the Service.


Contact Information

If you have any questions about this Privacy Policy, please contact us at appbermuda@gmail.com. Any personally identifiable information provided in connection with inquiries related to this Privacy Policy will be used solely for the purpose of responding to the inquiry and consistent with our Privacy Policy.




10. PRIVACY POLICY CHANGES

Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.


Last Updated. This Privacy Policy was last modified on 18 July 2019