Privacy Policy

This Privacy Notice details our use of your personal information. 

The Bermuda Government, Department of Public Transportation takes your privacy seriously and will only use your personal information to deliver the services you have requested or require.

Please read this document carefully and contact us if you have any questions.

1. Who are we?

We are the:

Government of Bermuda | Department of Public Transportation 
26 Palmetto Road | Devonshire, Bermuda, DV05 
T: 441-292-3851
E: info@dpt.bm

For any general query, please contact us at this address.

2. Our privacy officer?

For the purpose of the Personal Information Protection Act 2016 (the "Act"), the data controller is the Bermuda Government, Department of Public Transportation, 26 Palmetto Road, Devonshire, Bermuda, DV05.

If you have any general questions regarding this Privacy Notice or our use of your personal information, please contact our privacy officer at:

Department of Public Transportation | Government of Bermuda 
Phone: 441-292-3851
Email: dptprivacy@gov.bm

For any query relating to privacy compliance, please contact our privacy officer.

3. What personal information do we use and where does it come from?

Personal information can include things that can allow someone to identify you either directly, through your name or passport number (etc.), or indirectly, through your address, phone number, date of birth or IP address (etc.).

We obtain your personal information from -

You:

When you use Shorelink digital fare media, we collect various types of personal information. This includes your name, email address, transaction history, and details about your travel habits. 

We do not collect, view, or store credit or debit card information.

Additionally, we may gather other person-identifying information such as address, date of birth, and age from identification documents, such as your passport or driver's license, to verify your identity and determine eligibility for special passes. 

Information We Obtain Through the Shorelink App 

Anonymous users 

  • Shorelink Account Number
  • Email
  • Account Number
  • Purchase History
  • Usage History

Registered Users

  • Shorelink Account Number
  • Email
  • Name
  • Telephone Number
  • Address
  • Purchase History 
  • Usage History
  • IP Address
  • Geolocation

Registered Users Eligible for Special Passes or Fares (in addition to the above "registered users" information)

  • Government Issued Identity document
  • Biometric Information 
  • Date of Birth or Age
  • Proof of Bermuda Residency
  • Proof of overseas student status 

Information We May Obtain for Customer Service Assistance

  • When contacting our customer services team, we may request information listed above in order to assist you with queries

Third party individual:

The parent or legal guardian provides the following about a child (individuals under that age of 18)*:

  • Name*
  • Address*
  • Telephone number *
  • Government Issued Identity document (such as passport or driver's license)*
  • Date of Birth or Age*
  • Proof of Bermuda Residency*
  • Proof of student status *
  • Parent's email

[* Indicates sensitive personal information.]

4. Third-party personal information

You must not provide personal information about a third-party save when you are legally entitled to do so. If you are providing personal information about a third-party, you must state that you are doing so and provide proof of your legal entitlement to do this.

5. Children in the information society

This service is not available to individuals under the age of 14 years, unless consent has been provided by a legal guardian.

6. What is our legal condition for use?

Our legal conditions for use are:

  • Agrees
  • performance of a contract or steps with a view to entering into a contract

7. What is our purpose for use?

We use your personal information for the following purposes:

  • To Process Transactions: 
  • Our payment gateway provider (uses your credit/debit card information to process payments for digital fare media and other related transactions. We do not collect, view, or store your information
  • To Create and Manage Your Account: 
  • o We use your personal information to set up and maintain your user account on the Shorelink app.
  • To Verify Eligibility: 
  • o Identification documents, such as passports or driver's licenses, are used to verify your identity and determine eligibility for special passes. 
  • To Improve Our Services: 
  • o Information about your travel habits helps us enhance and tailor our services to better meet your needs and preferences.
  • To Communicate with You: 
  • Your contact details, such as your email address, are used to send important updates, notifications, and respond to your inquiries

8. Who has access to your personal information?

The following individuals and/or types have access to your personal information:

  • Relevant staff operating in the Department of Public Transportation system;
  • Managers and relevant Government Departments processing data for the Department of Public Transportation system;
  • Payment gateway provider (to process your payment);
  • Auditors for quality control purposes;
  • IT contractor staff supporting the software.
  • This service is provided by the Gov. of Bermuda but being delivered by contractors as subcontractors (or partners) on behalf of the Government of Bermuda.

These persons have access to only that personal information necessary for the discharge of their duties.

All persons with access are under contract and understand their obligation to maintain customer personal information subject to conditions of confidence.

9. Transfers in Bermuda / overseas?

In Bermuda:

Personal information transferred for purchase processing purposes. See additional information at https://www.globalpayments.com/en-bm/privacy-statement

Overseas: 

Personal information transferred for purchase and fare usage processing purposes –

  • Name
  • Address
  • Telephone number

Only authorized Paragon ID staff and partners are permitted access.

Google

Personal information transferred to and from, and used within, computer systems hosted under a cloud services contract:

  • Name
  • Address
  • Email Address
  • Telephone number
  • Date of Birth
  • IP Address
  • Geolocation
  • Biometric Information

Only authorized Government of Bermuda staff and partners have access. All data is encrypted, both at rest and in transit.

Amazon

Personal information transferred to and from, and used within, computer systems hosted under a cloud services contract:

  • Name
  • Address
  • Email Address
  • Telephone number
  • Date of Birth
  • IP Address
  • Geolocation
  • Biometric Information

Only authorized Government of Bermuda staff and partners have access. All data is encrypted, both at rest and in transit.

We will not sell or rent your personal information.

10. Where is your personal information stored?

Your personal information is stored:

· Hard copy forms are kept in secure offices in Devonshire, Bermuda;
· Electronic data created after inputting the data form, the hard copy forms is maintained in computer systems in Bermuda and cloud servers based in Bermuda and North America.

11. How long do we keep your personal information?

We retain your personal information for the following periods:

  • For the length of the provision of the services until you terminate, and/or 
  • For a period of 6 years for audit, legal liability, quality and other lawful purposes.

Information retained may include:

Anonymous users 

  • Shorelink Account Number
  • Email
  • Account Number
  • Purchase History
  • Usage History

Registered Users

  • Shorelink Account Number
  • Email
  • Name
  • Telephone Number
  • Address
  • Purchase History 
  • Usage History
  • IP Address
  • Geolocation

Registered Users Eligible for Special Passes or Fares (in addition to the above "registered users" information)

  • Government Issued Identity document
  • Biometric Information 
  • Date of Birth or Age
  • Proof of Bermuda Residency
  • Proof of overseas student status 

12. What are your rights?

We will do all we reasonably can to assist you with any issue arising from our use of your personal information.
Please contact our Privacy Officer (paragraph 2) if you have any questions.
When the PIPA comes into force, this section will be amended to detail your full legal rights under the Act.

You have the right to access your personal information and to right of rectification, blocking, erasure. and destruction (in limited and specific circumstances). For more information on how to manage or remove your information provided to Shorelink, please go to www.shorelink.bm.

For further details concerning your rights, please contact us www.shorelink.bm/contact. Please also see the website of the Privacy Commissioner at www.privacy.bm/guide-to-pipa.

13. Security

We constantly monitor the security of our systems and we review our policies and procedures on a regular basis.
Information transmitted normally over the Internet can never be guaranteed as 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us. Once we receive your personal information, we make all reasonable (and appropriate) efforts to ensure its security on our systems.

14. Links, Social media plug-ins, cookies and website analytics

For a list of the social media plug-ins, cookies and website analytics we use see below.

General information:

Links and social media

  • Our website contains links to other sites, particularly to other public entities' sites or to social media sites. These websites have their own privacy policies that are different from the one stated here. If you choose to follow those links, please remember to check the Privacy Notices at those sites

Social Media Plug-Ins

  • We may include a limited number of social media plug-ins that you may use that allow you to directly obtain information or post links on the relevant network.
  • The respective social network provider uses your personal information for its own purposes.
  • The legal condition for the use of your personal information (if any) is consent though your accessing and continuing to use our website.
  • The social media plug-in connects to a network outside Bermuda. Please see the privacy notice of the relevant social media provider.
  • The social media plug-ins used are:
  • Service: Facebook - www.facebook.com
  • Privacy Details: www.facebook.com/privacy/explanation
  • Details: The Shorelink App utilizes a 'log in with Facebook' option to make it easier for you to create an account so you can use the app right away. We have a text below this login features stating: By connecting with the third party service, you agree to our Terms of Use and Privacy Policy.

Cookies: General

  • Our website uses cookies.
  • Cookies are small files that are stored on your computer. They are designed to hold information specific to a particular client and website and can be accessed either by the web server or the client computer.
  • Cookies help us optimise your access to and use of our website and enables the correct functioning of those parts of our site that you access. You can find out more about our cookies on www.allaboutcookies.org.
  • The legal condition for the use of your personal information (if any) is consent though your accessing and continuing to use our website.
  • You may at any time deactivate the cookies which may affect access to or the performance of the website.
  • Cookie personal information is used by our own servers as well as the servers of third parties based outside Bermuda.
  • The cookies used are:
  • Name: Google Analytics Service: website statistics
  • Privacy Details: https://policies.google.com/privacy?hl=en
  • Details: Tracks the number of times a visitor has been to our site, when their first visit was, and when their last visit occurred. Google Analytics uses the information to calculate visitor statistics.

15. Privacy Notice (administrative details)

Privacy Notice No. 135 v1.0
Effective Date: 24 June 2024

This Privacy Notice may be updated from time to time. Any amended Privacy Notice becomes effective and replaces the previous version once published.

 
Privacy Policy