Privacy Notice

Effective Date: December 5, 2024

Juniper Medical LLC (“Juniper Medical”, "we", "us", "our") values your privacy and is committed to protecting your personal information. This Privacy Notice explains how we collect, use, disclose, and safeguard your personal data in compliance with the Bermuda Personal Information Protection Act 2016 (PIPA). It also outlines your rights to access, manage and delete your information.

PLEASE READ THIS PRIVACY POLICY (THE “POLICY”) CAREFULLY BEFORE USING OUR WEBSITE OR CLIENT PORTAL. BY ACCESSING AND USING OUR WEBSITE OR CLIENT PORTAL, YOU INDICATE YOUR ACCEPTANCE OF THIS POLICY.

1. Introduction and Purpose

We recognise the importance of your personal information and are dedicated to maintaining its confidentiality. This Privacy Notice, together with our website’s Terms of Use, explains how we collect and process your data when you use our services, visit our website, or interact with us.

2. Commitment to Privacy

We are committed to:

• Using your data lawfully, fairly, and transparently.
• Collecting data for specific, legitimate purposes.
• Ensuring data accuracy and relevance.
• Protecting your data with appropriate security measures.
• Retaining your data only as long as necessary for the specified purposes.

3. Collection of Information

We collect personal data from:

• Direct interactions: When you provide personal data by filling in forms or corresponding with us. You are not required to provide any personal information on the public areas of our website; however, you may choose to do so by completing any of the forms which are available onsite.
• Automated technologies: When you interact with our website (e.g., cookies, IP addresses, usage data).
• Indirectly from healthcare and related providers such as another doctor (including your previous GP) or specialist, laboratories, hospitals and health insurance providers.
• Other third parties such as regulatory bodies.

Types of personal data include:

• Identification details (name, gender, date of birth, employment details, contact information).
• Health information (medical history, treatment plans).
• Financial information (insurance details, billing).
• Technical data (IP address, browser type).

4. Use of Information

We use your personal data for:

• Providing and managing your healthcare services.
• Communicating about your care, appointments and treatments.
• Billing, processing payments and managing accounts.
• Complying with legal and regulatory obligations.
• Enhancing our services and website functionality.

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with the law.

5. Sharing of Information

We may share your personal data with:

• Healthcare or related service providers (laboratories, pharmacies) involved in your care.
• Insurance companies for billing purposes.
• Regulatory authorities, as required by law.
• Other third-party service providers in alignment with PIPA and under strict confidentiality agreements.

6. Data Retention

We retain your personal information as long as necessary for the purposes outlined or as required by law, to comply with healthcare regulations.

In summary:

• Juniper Medical securely stores limited physical data at 27 Point Finger Road, Paget DV04, where our premises are monitored.
• All personal data is stored digitally in a HIPAA-compliant and PIPA-equivalent, password protected database and password protected files and we manage the access to such files as noted under Security of Information.
• We retain data for 7 years after a patient has left the practice or has died and confidential information is deleted from the server at that juncture. Any physical records of personal information are shredded and securely disposed.

7. Security of Information

We employ robust security measures, including:

• Secure IT systems and data storage.
• Regular security reviews and employee training.
• Encryption and controlled access to sensitive data.

8. Your Rights

Under PIPA, you have the right to:

• Access your data.

o Under PIPA, individuals have the right to request access to their medical records. Medical records or other health-related information is sensitive personal information.
o Section 18, Access to Medical Records, states:

On the request of an individual for access to—

(a) personal information of a medical or psychiatric nature relating to the individual; or
(b) personal information kept for the purposes of, or obtained in the course of, the carrying out of social work in relation to the individual, an organization may refuse to provide access to personal information if disclosure of the personal information to the individual would be likely to prejudice the physical or mental health of the individual.

Where, under subsection (1), an organisation refuses to grant a request, the organization shall, if requested to do so by the individual, provide access to personal information referred to in that subsection to a health professional, within the meaning of section 2 of the Bermuda Health Council Act 2004, who has expertise in relation to the subject matter of the record, and the health professional shall determine whether disclosure of the personal information to the individual would be likely to prejudice the physical or mental health of the individual.

Notwithstanding anything else in this section, in response to a request under subsection (1), an organization—

(a) may refuse to provide access to personal information by relying on section 17(2); and
(b) shall refuse to provide access to personal information pursuant to section 17(3).

If an organisation is reasonably able to redact information which is referred to in section 17(2)(b) or section 17(3)(b) or (c) or information which would be likely to prejudice the physical or mental health of the individual from other personal information about the individual who requested it, the organization shall provide the individual with access to the other personal information after redacting the former information or the information which would be likely to prejudice the physical or mental health of the individual.

• Correct inaccuracies.
• Request data deletion or restrict its processing.
• Object to processing or withdraw consent.
• Request data portability.

To exercise your rights, contact us using the information provided below.

9. Cookies and Automated Decision-Making

We use cookies to enhance your website experience and collect data on site usage. Automated decision-making processes may be used for operational efficiency but are reviewed for fairness and accuracy. Please see our Cookies Policy.

10. International Data Transfers

We ensure that any international data transfers are protected by appropriate safeguards, such as data protection laws or contractual agreements.

11. Changes to This Privacy Notice

We may update this Privacy Notice periodically. The updated version will be available on our website, and your continued use of our services indicates acceptance of the changes.

12. Contact Information

For any questions or to exercise your privacy rights, please contact:

Dr. Samantha Price
Privacy Officer

Juniper Medical LLC
27 Point Finger Road
Paget DV04
BERMUDA

reception@juniper.bm
+1-441-405-1000

This Privacy Notice underscores our commitment to safeguarding your personal information in compliance with PIPA.

You may report a complaint or if you feel that Juniper Medical has not satisfactorily addressed any privacy concern you may have by contacting the Privacy Commissioner’s Office.

Email: privcom@privacy.bm
Website: www.privacy.bm
Phone: +1- 441-543-7748

Address: Maxwell Roberts Building, 4th Floor
1 Church Street
Hamilton HM11
BERMUDA