1. Introduction

Ocean Tree Limited (“Ocean Tree”, "OTL", “we”, “us”, or “our”) is committed to protecting the privacy and security of your personal information. 
We collect, use, store, and share your personal data in accordance with the Personal Information Protection Act 2016 (PIPA) and other applicable laws. 
This Privacy Policy explains how we handle personal information obtained through our investment advisory, client onboarding, and related financial services.

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2. Who We Are

Ocean Tree Limited is authorised and regulated by the Bermuda Monetary Authority in the conduct of investment business under the Investment Business Act 2003.
We act as a Data Controller for the personal information you provide to us, determining how and why it is used.

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3. Contact Details

Privacy Officer / Head of Risk & Compliance - Stephen Otokpa
Email: stephen@oceantree.bm
Telephone: +1 441 543 8733

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4. Information We Collect

We collect and process personal information that you provide to us directly, or that we receive from third parties in the course of providing our services or meeting our legal obligations.

This includes, but is not limited to:

1. Personal identifiers: name, date of birth, gender, nationality, identification numbers (e.g. passport, driver’s licence).

2. Contact information: address, telephone number, email address.

3. Financial information: income, assets, investment history, payment details, bank accounts.

4. Employment and profile data: occupation, employer, role, source of wealth, marketing preferences.

5. Family or beneficiary information: dependants, beneficiaries, and related data relevant to investment or estate planning.

6. Regulatory data: sanctions, politically exposed person (PEP) checks, and compliance records.
   
   In limited circumstances, we may process sensitive personal information (e.g., health or criminal records) when required for legal compliance (AML/ATF, sanctions screening, or suitability assessment).

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5. Purpose and Legal Basis for Processing

We process your personal information for the following purposes:
• To understand your financial objectives and provide tailored investment advice.
• To facilitate account opening, product selection, and ongoing administration.
• To comply with legal and regulatory obligations (including AML/ATF and BMA reporting).
• To maintain accurate client records and manage our business relationship.
• To perform risk, compliance, and internal audit functions.
• To send you updates or information about our services (with your consent).

Our lawful bases for processing are: your knowing consent; performance of a contract; compliance with legal or regulatory obligations; legitimate business interests; or where required in the public interest or under applicable law.

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6. Change of Purpose

We will only use your personal data for the purposes stated above unless we reasonably consider another purpose to be compatible with the original one.

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7. Data Sharing and Transfers

We may share your personal data with third-party service providers, financial institutions, regulators, and advisers. Overseas transfers are safeguarded under PIPA-compliant agreements.

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8. Data Retention

We typically retain client records for five years after the end of our relationship, or three years where no relationship is established, in line with regulatory requirements.

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9. Rights of Individuals under PIPA

Under the Personal Information Protection Act 2016 (PIPA), clients (“data subjects”) have several rights concerning their personal information used by OTL. These rights are designed to ensure transparency, accountability, and fair use of personal data.

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9.1 Right to Be Informed

You have the right to receive clear and accessible information about how OTL collects, uses, stores, and shares your personal information.
This is provided through this Privacy Policy, client agreements, and other disclosures at the point of data collection.

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9.2 Right of Access (PIPA §17)

You may request confirmation of whether OTL holds personal information about you and, if so, obtain access to:

• The categories of personal information held;

• The purposes for which it has been and is being used; and

• The names or types of persons or organisations to whom it has been disclosed.

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Access may be refused only in limited circumstances, such as where disclosure would:

• Reveal confidential commercial information or third-party data;

• Endanger the safety of another person; or

• Be protected by legal privilege.

​​OTL will respond to all verified access requests within 45 days, extendable by 30 additional days where permitted by PIPA §20(6).

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9.3 Right to Rectification (PIPA §19)

You have the right to request correction or completion of any inaccurate or incomplete personal information held by OTL.
Upon verifying your request, we will:

• Correct the inaccurate information as soon as reasonably practicable; and

• Notify any third parties to whom the inaccurate data was disclosed, where reasonable.

​If the information represents a professional or expert opinion, OTL may annotate rather than alter the original record, as required by §19(4)–(5).

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9.4 Right to Erasure and Destruction (PIPA §19(10))

You may request that OTL erase or destroy your personal information if:

• It is no longer relevant for the purpose for which it was collected; or

• You withdraw consent and there is no other legal basis for processing.

​We will either delete the information securely or provide written justification if retention is required by law or regulatory obligation (e.g., anti-money laundering record-keeping).

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9.5 Right to Restrict Processing or Withdraw Consent (PIPA §19(6)–(9))

You may request OTL to cease or restrict the use of your personal information if:

• The information is being used for direct marketing;

• Its continued use causes, or is likely to cause, substantial damage or distress; or

• You believe the use is no longer justified.

Where consent is the basis of processing, you may withdraw consent at any time.
Withdrawal will not affect the lawfulness of processing that occurred before consent was withdrawn.

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9.6 Right to Object to Direct Marketing (PIPA §19(6))

OTL will not send marketing communications without your consent.
You may opt out of receiving marketing communications at any time by contacting us at privacy@oceantree.bmor using the unsubscribe option in any email.

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9.7 Right to Compensation (PIPA §21)

If you suffer financial loss or emotional distress because of OTL’s failure to comply with PIPA, you are entitled to seek compensation through the courts.
In such proceedings, OTL may defend the claim by proving that it took all reasonable care to comply with its obligations under the Act.

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10. Security and Safeguards

Ocean Tree employs encryption, access control, staff training, and breach notification procedures to protect your data.

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11. Cookies and Website Analytics

Our website may use cookies and analytics tools to enhance user experience. You can disable cookies in your browser settings.

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12. Children’s Data

We do not intentionally collect data from minors under 18 without guardian consent.

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13. Updates to This Policy

This Policy may be updated periodically. The latest version will be available at www.oceantree.bm

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14. Complaints, Contact and Redress Procedure

If you are concerned about how OTL uses your personal information or are dissatisfied with our response to a privacy-related request, you may make a formal complaint as follows:

 

Step 1 – Contact the Privacy Officer

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Please submit a written complaint to:

Privacy Officer
Ocean Tree Limited
Windsor Place, 1st Floor, 22 Queen Street
Hamilton HM 11, Bermuda

Email: privacy@oceantree.bm

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Your complaint should include:

• Your full name and contact details;

• A clear description of the issue; and

• Copies of any relevant correspondence or evidence.

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We will acknowledge receipt of your complaint within five (5) business days and provide a written response within 45 days, as per PIPA §20(4).

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Step 2 – Request a Review or Mediation (PIPA §39–41)

If you are not satisfied with OTL’s response, you may:

• Request that the Privacy Commissioner for Bermuda review the matter; or

• Request mediation facilitated by the Commissioner between you and OTL.

The Commissioner may inquire into the complaint, issue findings, or make recommendations to ensure compliance with the Act.

 

Step 3 – Further Recourse

If still unsatisfied after the Commissioner’s decision, you may:

• Seek judicial review or file an action for compensation before the Supreme Court of Bermuda (PIPA §21).

 

OTL Commitment

Ocean Tree Limited takes all complaints seriously and commits to:

• Maintaining a written Complaints Log;

• Cooperating fully with the Privacy Commissioner during any inquiry or mediation; and

• Implementing remedial or corrective measures promptly if required.

If you believe your data has been mishandled, contact us or the Office of the Privacy Commissioner for Bermuda (www.privacy.bm).