Privacy Policy

This privacy policy sets out how Abacus Ltd uses and protects your personal data. 


Abacus Ltd is the controller and responsible for your personal data (collectively referred to as Abacus, “we”, “us” or “our” in this privacy policy).


Megan Nesbitt is the Privacy Officer and responsible for communicating with the Privacy Commissioner for Bermuda.

If you have any questions about this privacy policy, including any requests to exercise your legal rights please contact us using the information set out in the contact details section.


Personal information or data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
  • Marketing and Communications Data includes direct emails and newsletters.

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
  • Legitimate interests: We may use your personal data where it is necessary to perform a task in the public interest or exercise of official authority vested in the organization or in a third party to whom the personal information is disclosed.
  • Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
  • Consent: You have provided us with your consent, where that consent can be reasonably demonstrated.

Your personal information may be used for the following purposes:

  • To meet our regulatory, legal and professional obligations;
  • To establish and manage our relationship with you;
  • To provide legal advice and trust and corporate administration services;
  • To monitor and manage the performance of our business operations;
  • To manage conflicts of interest;
  • To analyse performance, and generate internal reports;
  • To assess risks including legal and financial risks;
  • To invoice and process payments;
  • To process applications for employment;
  • To monitor visitor traffic to and usage of the MJM group websites;
  • To market our services;
  • To engage in business transactions;
  • To prevent fraud;
  • To undertake network and information security activities; and
  • For any other purposes for which we have your consent, save where Abacus or its third parties have a legitimate interest.

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.


We may share your personal data where necessary with the parties set out below for the purposes set out above.

  • External Third Parties being Companies who we may use to be able to provide the Services as detailed in the Letter of Engagement.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


Whenever we transfer your personal data out of Bermuda to countries which have laws that do not provide the same level of data protection as Bermuda law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:

  • We will only transfer your personal data to countries that have been deemed by Bermuda to provide an adequate level of protection for personal data;
  • We may use specific standard contractual terms which give the transferred personal data the same protection as it has in Bermuda.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data as detailed more fully below.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.


You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to erase or destroy personal data where there is that personal data is no longer relevant for the purposes of its use. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing that data on this ground if doing so is causing or is likely to cause substantial damage or substantial distress to you. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.


We may charge a fee for any request for your personal data. In the event of non-payment, we could refuse to comply with your request in these circumstances.


We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways: