Privacy Policy

First Bermuda Group Ltd., First Bermuda Savings & Loan, First Bermuda Securities (BVI) Ltd, First Bermuda Capital, First Bermuda Asset Management and affiliated Group Companies (collectively, "FBG") are committed to protecting your privacy, and support a general policy of openness about how we collect, use and disclose personal information relating to you.

The purpose of this Privacy Policy is to inform you about FBG's practices relating to the collection, use and disclosure of personal information (including financial information) that may be provided through use of its services, related products or websites or that may otherwise be collected by it. By using FBG's services, related products or websites, you consent to the collection, use and disclosure of personal information relating to you (as defined below) in accordance with the following terms and conditions.

This Privacy Policy also explains how you can contact FBG if you have a question about, want to make a change to or delete any personal information that FBG may be holding about you. We strongly recommend that you take the time to read this Privacy Policy and retain it for future reference.

Personal Information

For the purpose of this Privacy Policy, "personal information" means information about an identifiable individual or legal entity, but does not include the name, title or business address or telephone number of an employee of an organization, unless such employee represents an authorized signatory, or principal of an organization.

Personal Information Collected by FBG and How it is Used

General Purposes

If you choose to establish an account with FBG, FBG collects personal information in order to establish and administer your account(s), to fulfill its usual business requirements, to develop and maintain its relationship with you and to communicate with you. FBG also may collect and utilize personal information in order to fulfill its legal, regulatory and self-regulatory obligations in those jurisdictions in which it operates. Unless you advise us otherwise, personal information may be used by FBG in order to advise you about new services and related products that may be of interest to you. Please see below for additional detail regarding the specific purposes for collecting personal information should you choose to establish an account.

In addition, if you voluntarily choose to contact us with a question or comment via our website or by telephone, facsimile or mail, we may use or disclose this information, which may include your personal information, in order to respond to your request.

Specific Purposes

Financial Information

If you wish to establish an account, FBG collects information about your income, financial needs, net worth, investment knowledge and personal transaction and trading information in order to assess credit applications, investment goals, risk tolerance suitability for various investment opportunities, as well as your banking information in order to comply with the requirements of anti-money laundering legislation. For the purposes of requests for debt financing, the extent of information required may not be limited to the foregoing.

Proof of Identity

FBG is required to verify your identify in order to comply with the requirements of anti-money laundering legislation. This will require the provision of appropriate documentation duly certified (certification must be undertaken by a suitable person, such as: a police officer, a chartered or certified public accountant, a practicing solicitor, a notary public, a commissioner for oaths) or otherwise, as the requirements dictate.

Date of Birth

If you wish to establish an account, FBG collects information about your age in order to assess your financial and investment goals, risk tolerance and suitability for various financial products and services. We also require your date of birth as a routine compliance requirement. FBG also requires this information when establishing an account in order to confirm that you are not a minor.

Citizenship and Country of Residence

FBG collects information about your citizenship and country of residence in order to fulfill certain of its regulatory obligations.

Family Status/Employment

If you wish to establish an account, FBG collects information about your marital status, number of dependants and employment in order to assess your financial objectives, risk tolerance and suitability for various financial products and services. As required by pertinent securities laws, FBG also asks whether or not you are an employee or principal of an investment or insurance undertaking.

Sharing of Personal Information with Service Providers

FBG may share personal information with third parties contractually engaged to assist it in providing services and related products to you and to conduct its usual business requirements. These service providers are prohibited from using personal information for any purpose other than to provide this assistance and are required to protect personal information disclosed by FBG and to comply with the general privacy principles described in this Privacy Policy.

Disclosure of Personal Information

Except with your written consent, FBG will not sell, license, trade or rent your personal information to or with others. FBG reserves the right to disclose personal information to a third party if a law, regulation, search warrant, subpoena or court order legally requires or authorizes it to do so.

FBG reserves the right to disclose and/or transfer personal information to a third party, or their agents, in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of FBG or of any of the business or assets or shares of FBG or a division thereof in order for you to continue to receive the same services and related products from the third party, or their agents.

Consent

FBG collects personal information about you only when you voluntarily provide it.

You may withdraw your consent to the use and disclosure of personal information in connection with the services and related products that you have requested at any time subject to legal or contractual restrictions and reasonable notice. If you wish to withdraw your consent at any time, please contact FBG as outlined below. We will inform you of the implications of withdrawing consent.

Use or Disclosure of Personal Information Usual Business Purposes

Within the scope of financial services provided by FBG, from time to time personal information may be used for purposes across the group of companies and affiliates to fulfill policy, regulatory, corporate, operational, verification, legal and other such requirements.

Use or Disclosure of Personal Information for Marketing Purposes

Within the boundaries of FBG's regulatory environment, from time to time FBG may make use of personal information relating to you, in order to communicate and market FBG's services and related products to you. You will be given an opportunity to opt-out of receiving such correspondence when you meet with your FBG representative and enter into an agreement with FBG. Please advise your FBG Representative if you do not wish to receive further correspondence or contact us in the manner provided below.

Cookies

Cookies are small text files containing certain pieces of information that a website creates when you visit the site. Cookies can track your browser as you navigate a website, showing how and when you use the site. The www.fbg.bm website utilizes cookies to support our internal site management processes. Most browsers allow you to decline cookies. If you elect to set your browser to decline cookies, your experience of this site will not be affected in any way.

How FBG Protects Personal Information

FBG makes commercially reasonable efforts to ensure personal information is protected against loss and unauthorized access. This protection applies in relation to information stored in both electronic and hard copy form. Access to personal information is restricted to selected employees or representatives on a need-to-know basis. FBG educates its employees regarding its privacy policy and their role and responsibilities in keeping personal information private. In addition, FBG employs generally accepted information security techniques, such as firewalls and access control procedures in order to protect personal information against loss and unauthorized access.

Links to Third Party Sites

FBG's website may offer links to other third party websites. You should be aware that operators of linked websites may also collect personal information relating to you (including information generated through the use of cookies) when you link to their websites. FBG is not responsible for how such third parties collect, use or disclose your personal information, so it is important to familiarize yourself with their privacy policies before providing them with personal information.

Retention of Personal Information

FBG retains personal information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws and regulations, and your consent to such purposes(s) remains valid after termination of FBG's relationship with you.

Changes to this Privacy Policy

FBG reserves the right to modify this Privacy Policy at anytime without notice. The Privacy Policy distributed from time to time or posted via FBG's websites shall be deemed to be the Privacy Policy then in effect.

Contacting Us

You can help FBG maintain the accuracy of personal information relating to you by notifying FBG of any changes to this information. You may contact FBG in any one of the following ways to request access to, correction or update of personal information or in the event that you have any questions about FBG's Privacy Policy or if you have reason to believe that FBG may have failed to adhere to this Privacy Policy:

First Bermuda Group Ltd.
Maxwell R. Roberts Building
1 Church Street
Hamilton HM 11
Bermuda

Attention: Mr. Jeffrey Conyers, Chief Executive Officer or Mr. Douglas Selley, Chief Operating Officer (Compliance)

Alternatively, you can call us at 1-441-295-1330 or send an email to fbs@fbs.bm