Privacy.

Who is responsible for your information

Roy Solomon Consultancy, based in Nassau, The Bahamas, is responsible for personal information under its control and acts as the data controller for the processing described in this policy. References to “we”, “our” or “us” mean Roy Solomon Consultancy.

This policy is intended to explain our practices under the Data Protection (Privacy of Personal Information) Act, 2003 (Chapter 324A) of The Bahamas, as amended or replaced from time to time, and any other data-protection law that applies to a particular activity.

Scope of this policy

This policy applies when you:

• visit this website;
• contact us by email, telephone or another agreed communication channel;
• make or receive a business, advisory, trade, infrastructure or venture-related enquiry;
• act for a client, supplier, service provider, professional adviser, commercial counterparty or connected venture; or
• otherwise provide personal information to us in the course of a prospective or established business relationship.

This policy concerns information relating to identifiable individuals. Information about a company is not necessarily personal information, but the names, positions, contact details and activities of its directors, owners, representatives and employees may be.

Information we may collect

Depending on the nature and stage of our relationship, we may collect:

• Identity and contact information, such as your name, business title, organisation, email address, telephone number and country or location.
• Professional and commercial information, including your role, authority, areas of interest, product or service requirements, transaction parameters and information concerning a proposed engagement or opportunity.
• Communications, including correspondence, meeting notes, documents and records of enquiries or instructions.
• Due-diligence information, where appropriate and requested through a suitable process, such as corporate registration information, ownership and control information, representative authority and identity-verification material.
• Relationship information, including how you were introduced to us, relevant advisers or counterparties, and a record of our work or dealings with you.
• Website and technical information, such as internet protocol address, device and browser type, date and time of access, requested pages, approximate location derived from network information, and security or diagnostic logs that may be generated by our hosting and technical service providers.

How information is obtained

We usually receive information directly from you or the organisation you represent. We may also receive it from introducers, connected ventures, transaction participants, professional advisers, service providers, publicly available company registries, sanctions or compliance databases, professional networks and other lawful public sources. Where you provide information about another person, you should be authorised to do so and should make this policy available to them where appropriate.

How and why we use information

We may use personal information where reasonably necessary to:

• respond to communications and manage our relationship with you;
• understand, assess and progress a prospective engagement, commercial opportunity or introduction;
• confirm identity, representative authority, ownership or counterparty status;
• conduct proportionate compliance, conflict, sanctions, fraud-prevention and reputational checks;
• prepare, negotiate, perform or administer an agreement or transaction;
• coordinate with relevant connected ventures, advisers, service providers and transaction participants;
• maintain accurate business, accounting, compliance and correspondence records;
• operate, secure, diagnose and improve the website and our communications systems;
• establish, exercise or defend legal rights and protect people, property and business interests; and
• comply with a legal, regulatory, court, law-enforcement or other binding obligation.

Our processing is based on the purpose for which the information was provided, our legitimate business and security needs, steps taken at your request before entering an agreement, performance of an agreement, compliance with legal obligations, and consent where consent is required. We will not use personal information for a materially incompatible purpose without an appropriate basis and, where required, notice to you.

Website data, cookies and similar technologies

This website does not currently use advertising cookies, behavioural advertising pixels or profiling tools. The website host and infrastructure providers may nevertheless use essential technical storage, network data and security logs to deliver pages, maintain availability, prevent abuse and diagnose faults.

Your browser may allow you to block or delete cookies and similar storage. Restricting essential technology may affect how the website operates. If we introduce analytics, marketing technology or other non-essential cookies in the future, we will update this policy and provide any consent controls required by applicable law.

When information may be shared

We may disclose information, only where relevant and proportionate, to:

• technology, hosting, communications, storage and cybersecurity providers;
• lawyers, accountants, auditors, insurers, compliance specialists and other professional advisers;
• connected ventures and their authorised personnel where an enquiry or opportunity properly concerns them;
• prospective or actual clients, suppliers, principals, logistics providers, financial institutions and other transaction participants where needed to evaluate or perform a legitimate business activity;
• government, regulatory, judicial, law-enforcement or other competent authorities where required or lawfully requested; and
• a successor, purchaser or adviser in connection with a proposed restructuring, transfer or sale of all or part of the relevant business, subject to appropriate confidentiality measures.

Service providers are expected to use information only for the services they provide to us and to apply appropriate confidentiality and security protections. We do not sell or rent personal information, and we do not disclose it to third parties for their independent direct marketing.

International transfers

Our work may involve people, counterparties and service providers in The Bahamas and other jurisdictions. Personal information may therefore be accessed, processed or stored outside the country in which it was collected. Privacy laws and regulatory protections may differ between jurisdictions.

Where an international transfer requires protection under applicable law, we will take reasonable and appropriate measures having regard to the information, purpose, recipient and destination. These measures may include limiting the information transferred, confirming the recipient’s need and authority, contractual confidentiality or data-protection terms, secure transfer methods and other legally recognised safeguards.

Retention and deletion

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including to manage a relationship, evaluate an opportunity, complete an engagement, maintain required business or compliance records, resolve disputes and meet legal, tax, accounting or reporting obligations.

Retention periods vary according to the nature and sensitivity of the information, the status of the enquiry or relationship, the risk of harm from unauthorised use or disclosure, and applicable limitation or record-keeping requirements. When information is no longer required, we will take reasonable steps to delete it, anonymise it or place it beyond ordinary use, subject to lawful archival and backup cycles.

Information security

We use administrative, organisational and technical measures designed to protect personal information against accidental or unlawful loss, misuse, alteration, unauthorised access or disclosure. Measures are selected according to the nature of the information and may include access controls, restricted disclosure, secure transfer methods, provider due diligence and record-management procedures.

No internet transmission, email system or electronic storage method can be guaranteed to be completely secure. Please verify unexpected instructions, requests for credentials or changes to payment information using a known contact method. If you believe information connected with us has been compromised, contact us promptly.

Your privacy rights

Subject to applicable law and any lawful exemptions, you may have the right to:

• ask whether we hold personal information about you and request access to it;
• request correction of information that is inaccurate or incomplete;
• request deletion where there is no valid reason for continued retention;
• object to or request restriction of particular processing;
• ask us to stop using your information for direct marketing;
• withdraw consent where processing relies on consent, without affecting earlier lawful processing;
• request information about applicable safeguards for an international transfer; and
• make a complaint to the competent data-protection authority or seek another remedy available under law.

To protect information from unauthorised disclosure, we may need to verify your identity and clarify the scope of a request. Rights are not absolute: for example, we may be required or permitted to retain information for legal compliance, the rights of others, confidential business records or the establishment, exercise or defence of legal claims. We will explain our position where a request cannot be fulfilled in full.

Direct marketing

We may occasionally send relevant professional or business communications to existing contacts where permitted. You may ask us to stop at any time by replying to the message or contacting us using the details below. We may retain a minimal suppression record so that we can respect your preference.

Automated decisions

We do not currently make decisions producing legal or similarly significant effects about individuals solely through automated processing, and we do not use personal information for behavioural profiling.

Third-party websites and communications

This website may link to websites or services operated by other organisations. Their privacy practices are governed by their own notices, and we are not responsible for their content or handling of information. Business communications conducted through a third-party platform may also be subject to that provider’s privacy terms.

Children

This website and our services are intended for business and professional audiences and are not directed to children. We do not knowingly seek or collect personal information from children. If you believe a child has provided information to us, please contact us so that appropriate action can be taken.

Changes to this policy

We may update this policy to reflect changes in our activities, website features, service providers, legal obligations or data-protection practices. The effective date at the top of the policy will be revised when a change is published. Material changes may also be communicated through the website or directly where appropriate.