Privacy Notice
How we collect, use, and protect your personal information
This Privacy Notice explains how AssetBase collects, uses, and protects your personal information in connection with investment transactions and the use of this investor portal. This notice complies with the Personal Information Protection Act (PIPA) of Bermuda.
Information We Collect
We collect the following categories of personal information:
- Contact Information: Email address, full name
- Investment Information: Holding amounts, shareholder details
- Location Information: Country of residence
- Technical Information: IP address, browser type, access timestamps
- Transaction Information: Document acceptance records, signature activity
How We Use Your Information
We use your personal information for the following purposes:
- Transaction Processing: To facilitate transactions and obtain your consent to required agreements
- Legal Compliance: To comply with regulatory requirements and maintain audit trails for document execution
- Record-Keeping: To maintain accurate records of shareholder decisions and document signatures
- Security: To verify your identity and prevent unauthorized access to confidential information
- Communication: To send you important updates about transactions and your document status
Overseas Transfers
Your personal information may be transferred to and processed by service providers located outside of Bermuda, specifically in the United States. These transfers are necessary for the operation of this portal. The service providers we use include:
- •Supabase (USA): Database and authentication services
- •Vercel (USA): Web hosting and application infrastructure
- •DocuSign (USA): Electronic signature services
- •Postmark (USA): Email delivery services
These service providers are required to maintain appropriate security measures to protect your information and process it only as instructed by us.
Your Rights Under PIPA
Under the Personal Information Protection Act (PIPA) of Bermuda, you have the following rights:
- Right to Access: You may request a copy of the personal information we hold about you
- Right to Correction: You may request that we correct any inaccurate or incomplete personal information
- Right to Deletion: You may request deletion of your personal information, subject to legal retention requirements
- Right to Object: You may object to the processing of your personal information in certain circumstances
- Right to Complain: You may lodge a complaint with the Privacy Commissioner of Bermuda if you believe your privacy rights have been violated
Please note that some rights may be limited where we are legally required to retain information for regulatory or legal purposes, such as maintaining records of signed transaction documents.
Data Security
We implement industry-standard security measures to protect your personal information, including:
- •Encryption of data in transit and at rest
- •Secure authentication using magic links
- •Role-based access controls
- •Comprehensive audit logging of all access and actions
- •Regular security assessments and updates
Data Retention
We retain your personal information for as long as necessary to fulfill the purposes outlined in this notice, comply with legal obligations, resolve disputes, and enforce our agreements. Transaction records and signed documents will be retained in accordance with applicable legal and regulatory retention requirements.
Privacy Inquiries and Requests
If you have questions about this Privacy Notice, wish to exercise your privacy rights, or have concerns about how your personal information is handled, please contact us:
We will respond to your privacy requests within 30 days of receipt.
Last updated: December 2025