Privacy Policy

1. Who We Are

apps.bm is operated by IELAI Limited, a company registered in Bermuda ("we", "us", or "our"). We are the organisation responsible for the personal information collected through the www.apps.bm website and the applications accessible from it (the "Services").

Contact us at: privacy@apps.bm

2. What Personal Information We Collect

Under PIPA, "personal information" means any information about an identifiable individual. We may collect the following categories of personal information:

Information You Provide Directly

• Name, email address, and contact details when you register or enquire
• Billing and payment information (processed through a PCI-DSS compliant third party)
• Business name, role, and organisation details
• Information you enter into our applications (e.g., employee records in Payroll)
• Support requests and correspondence with us

Information Collected Automatically

• Log data: IP address, browser type, pages visited, referring URL, and timestamps
• Device information: operating system, screen resolution, and device identifiers
• Cookies and similar technologies (see Section 7)
• Usage data: features used, session duration, and error reports

Information from Third Parties

• Payment processors (for subscription verification)
• QuickBooks Online API data (only when you authorise QB Online Connect)

3. Legal Basis and Purposes for Processing

PIPA requires that personal information is collected and used only for purposes that a reasonable person would consider appropriate in the circumstances. We process your personal information on the following bases:

• Contractual necessity: To provide the Services you have subscribed to, process payments, and manage your account.
• Legitimate interests: To improve our Services, prevent fraud, maintain security, and send service-related communications.
• Consent: For marketing communications (where you have opted in) and for the use of non-essential cookies.
• Legal obligation: To comply with Bermuda law and regulatory requirements, including PIPA and tax legislation.

4. How We Share Personal Information

We do not sell your personal information. We may share it with:

• Service providers acting on our behalf (e.g., cloud hosting, payment processing, email delivery) who are contractually bound to protect your information to a standard equivalent to or higher than PIPA.
• Other users of shared applications where you have permitted collaboration (e.g., sharing a Team Management workspace).
• Regulators and law enforcement when required by Bermuda law or a valid legal process.
• Successors in interest in the event of a merger, acquisition, or sale of assets, subject to the acquiring party assuming obligations under this policy.

5. International Transfers

Where personal information is transferred outside Bermuda, we ensure that the receiving jurisdiction or recipient provides protection that is substantially similar to PIPA, or we obtain appropriate contractual safeguards.

6. Data Retention

We retain personal information for as long as necessary to fulfil the purposes described in this policy, and thereafter only as required by applicable law or for legitimate business record-keeping. When personal information is no longer required, we delete or anonymise it securely. Specific retention periods are available on request.

7. Cookies

We use cookies and similar technologies to operate our Services and improve your experience. Cookies we use include:

• Essential cookies: Required for authentication and session management.
• Analytical cookies: To understand how the Services are used (with your consent).
• Preference cookies: To remember your settings and preferences.

You can manage cookies through your browser settings. Disabling essential cookies will impair your ability to use the Services.

8. Your Rights Under PIPA

As a data subject under PIPA, you have the following rights:

• Right of access: To request a copy of the personal information we hold about you.
• Right of correction: To require us to correct inaccurate or incomplete personal information.
• Right to withdraw consent: Where processing is based on consent, to withdraw it at any time without affecting the lawfulness of prior processing.
• Right to complain: To lodge a complaint with the Office of the Privacy Commissioner for Bermuda (OPC) if you believe we have not handled your information in accordance with PIPA.

To exercise your rights, contact us at privacy@apps.bm. We will respond within 45 days as required by PIPA.

9. Security

We implement appropriate technical and organisational measures to protect personal information against unauthorised access, disclosure, alteration, or destruction. These measures include encryption in transit and at rest, access controls, and regular security reviews. In the event of a privacy breach that creates a real risk of significant harm, we will notify affected individuals and the OPC as required by PIPA.

10. Children's Privacy

Our Services are not directed to children under the age of 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected such information, please contact us immediately.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify registered users of material changes by email or in-app notification at least 14 days before the changes take effect. Your continued use of the Services after that date constitutes acceptance of the updated policy.

12. Contact and Complaints

For privacy enquiries, to exercise your rights, or to make a complaint:

• Email: privacy@apps.bm
• Post: Privacy Officer, IELAI Limited, Bermuda

You also have the right to lodge a complaint with the Office of the Privacy Commissioner for Bermuda (OPC). For more information, visit www.privacy.bm.