1.INTRODUCTION

Somers Medical Services Ltd (referred to as “we,” “our,” or “us”) is committed to protecting your personal information in accordance with the Bermuda Personal Information Protection Act (PIPA).

This privacy notice explains how we collect, use, disclose, and protect your personal information, as well as your rights under PIPA.

Please read this notice carefully to understand how we handle your personal data.

Visit our website at www.somersmed.com, or any website of ours that links to this privacy notice

2. PERSONAL INFORMATION WE COLLECT:

We may collect personal information from you in the following ways:

  • Directly from you: Information you provide to us through forms, applications, contracts, or other interactions with our company.
  • Automatically: Data we collect through our website (Cookies) or other digital platforms.
  • From Third-Parties: Information provided to us by third party service providers, partners, or publicly available sources.

TYPES OF INFORMATION WE COLLECT:

  • Name, date of birth, address, telephone number, and email address
  • Health history, allergies, medications, medical records (including results and correspondence), photographs
  • Where appropriate, we collect sex/gender, race, religious practice.
  • Legal consents (including but not limited to health care proxies, advanced directives and powers of attorney)
  • Financial and payment information
  • Medical insurance policy information
  • Identification documents (including but not limited to official Government issued ID)
  • Any other information required for our business operations and services

HOW WE USE YOUR PERSONAL INFORMATION:

We collect and use your personal information for purposes that include:

  • Providing medical care and services and products you have requested
  • Processing payments and transactions including submitting insurance claims
  • Communication with you about updates, offers, or changes to our services
  • Meeting legal, regulatory, or contractual obligations
  • Conducting internal analysis for business and audit purposes
  • Enhancing user experience and improving our services
  • Liaising with outside medical agencies (e.g. local and overseas hospitals, labs, pharmacies and physicians)

3. COOKIE POLICY

We may use cookies and other tracking technologies to collect and store your information. At this time, we only collect the following data on our website: IP address, browser type, and other device-level information to differentiate humans from bots.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice on our website www.somersmed.com.

SHARING YOUR PERSONAL INFORMATION:

We may share your personal information with:

  • Service Providers: Companies who help us operate our business, such as payment processors, IT service providers (Oxygen), customer support services, and other health care providers (TriMed, DermEngine), and cloud-based hosts (e.g. Amazon AWS).
  • Business Partners: When necessary to fulfill joint services or initiatives (e.g. Bermuda Hospitals Board, local laboratories, overseas hospitals/healthcare providers).
  • Legal Authorities: Where required by law or the compliance with legal obligations (e.g. Bermuda’s Department of Health, Medical Protection Society)
  • Others: With your explicit consent or as otherwise authorized by PIPA

4. RETENTION AND DELETION

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Once the information is no longer needed, we securely delete or anonymize it in accordance with applicable laws.

We implement reasonable physical, technical, and organizational measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. We work closely with our partners, including IT support, to adequately maintain Data Protection and Security, Compliance and Documentation and appropriate back-up.

Disclaimer: Electronic transmission over the internet or information storage technology cannot be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

5. YOUR RIGHTS

Under PIPA, you have the following rights regarding your personal information:

  • Right to be informed: If we are processing your personal data
  • Right to access: You have the right to request access to your personal information
  • Right to correction: You may request that we correct or update inaccurate personal information
  • Right to deletion: You may request the deletion of your personal data, that is subject to legal and contractual obligations
  • Right to obtain a copy: of the personal data you previously shared with us
  • Right to opt in or opt out: You may object to the processing of your personal information for certain purposes
  • Right to withdrawal of consent: You can withdraw your consent at any time where we rely on your consent for processing

If you wish to exercise any of these rights, please contact us at the details provided below:

PRIVACY OFFICER
Somers Medical Services Ltd
9 Victoria Street, Hamilton HM 11, Bermuda
(441) 295-1110
privacy@somersmed.com

6. CHANGES TO PRIVACY NOTICE

We reserve the right to update or amend this Privacy Notice at any time.

Any changes will be posted on our website, and we will notify you of significant changes in how we handle your personal information.

We encourage you to review this notice regularly for updates.

Significant changes will be incorporated in the consent form all patients are required to review and sign and will be facilitated by requiring an updated consent form on the patient’s file.

7. COMPLAINTS

PRIVACY COMPLAINTS WE CAN ASSIST

We accept written complaints about:

  • How we collect or use personal information
  • How, when, and with whom we share personal information
  • The type(s) and/or amount of personal information we collect
  • Any other concern(s) you may have about how we handle personal information and/or its impact(s) on personal privacy

Complaints about the privacy of Somers Medical Services Ltd, a corporation, or any entity other than a person are not covered by our privacy complaint procedures.

Please keep in mind that requests for access, amendment, or correction are not privacy complaints – filing a complaint does not negate or replace your right to seek judicial relief under the PIPA or other privacy laws for violations of individual privacy rights.

Submit a privacy complaint

To submit a complaint, you can write a letter or email that includes:

  • Your name
  • A summary of your complaint or a written description of the specific circumstances
  • A summary of other steps taken, if any, to resolve this complaint
  • A preferred method of contact about your complaint – a mailing address, telephone number, email address or fax number

Your request will be reviewed, and a response will be sent within 45 days.

Send us the letter by email, phone or email

If you have questions or comments about this notice, you may contact our Data Privacy Officer (DPO), by email at privacy@somersmed.com by phone at (441) 295-1110

MAIL
Somers Medical Services Ltd
Privacy Officer
9 Victoria Street
Hamilton HM 11
Bermuda

Evaluation procedure

  • We will send you an acknowledgement letter within 5 business days of our receipt of your complaint.
  • We will review and categorize the complaint as: Process and procedural, redress, operational or referral (we will refer it to the Privacy Commissioner’s Office if we’re not the right ones to address the issue)
  • The Privacy Officer will recommend any necessary actions in response to the complaint. We’ll let you know once your complaint is closed and, in general, include what, if any, action we’re taking in response to the complaint
    Our goal is to review and close complaints within 20 business days. For complaints that we’ll need more than the normal time to close, we’ll contact you to give a status update

Your request will be reviewed, and a response will be sent within 45 days

If you believe we have not complied with PIPA or you are dissatisfied with how we have handled your personal information, you have the right to lodge a complaint with our office or the Office of the Privacy Commissioner for Bermuda.

PRIVACY OFFICER
Somers Medical Services Ltd
9 Victoria Street
Hamilton HM 11
Bermuda

THIS PRIVACY NOTICE IS PROVIDED IN ACCORDANCE WITH THE BERMUDA PERSONAL INFORMATION PROTECTION ACT (PIPA) AND APPLIES TO ALL PERSONAL INFORMATION COLLECTED AND PROCESSED BY SOMERS MEDICAL SERVICES LTD

8. CONTACT US

Under PIPA it is a requirement for a company to inform individuals of who is responsible for processing their data. This includes any Third Party business support, and systems. If you have any questions, concerns, or requests related to this Privacy Notice or your personal information, please contact:

PRIVACY OFFICER
Somers Medical Services Ltd
9 Victoria Street
Hamilton HM 11
Bermuda