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Privacy Policy

Last Updated January 2025

Table of Contents

  1. INTRODUCTION AND BACKGROUND
  2. MOONGATE GROUP’ POLICY STATEMENT
  3. DEFINITIONS
  4. PRIVACY OFFICER
  5. PERSONAL INFORMATION
  6. SENSITIVE PERSONAL INFORMATION
  7. USE OF PERSONAL INFORMATION
  8. DISCLOSURE OF PERSONAL INFORMATION
  9. DISCLOSURE OF PERSONAL INFORMATION WITHOUT CONSENT
  10. RECORD KEEPING
  11. PIPA RIGHTS
  12. CHANGES IN POLICY

Introduction and Background

Effective January 1, 2025, and in accordance with the Personal Information Protection Act 2016, all individuals, private entities and public authorities that use personal information in Bermuda have a legislative obligation to protect personal information. As part of those obligations, MoonGate Group is required to notify all individuals by the time their personal information is collected or as soon as possible thereafter with a Privacy Notice about its practices and policies with respect to personal information including:

  1. The fact that personal information is being used and the purpose for which that information is being used.
  2. The identity and types of individuals or organizations to whom personal information might be disclosed.
  3. The identity and location of the organization, including how to contact it about its handling of personal information.
  4. The name of the privacy officer, and the choices and means the organization provides to an individual for limiting the use of and accessing, rectifying, blocking, erasing and destroying his or her personal information.

Moongate Group Privacy Policy Statement

At MoonGate Group, we recognize the importance of protecting your personal information and respecting your privacy when providing our services including medical and nursing care. This Privacy Policy outlines how we collect, use and safeguard your personal information in compliance with Bermuda healthcare regulations and data protection laws.

MoonGate Group adheres to the Personal Information Protection Act 2016 (PIPA) regarding the collection, storage, management, use and deletion of personal information. 

Definitions

“MoonGate Group” means MoonGate Group Ltd., MoonGate (Bermuda) Ltd., RISCAP Holdings Ltd., MASA Assist Bermuda Ltd., and any other affiliate companies and trading names including MoonGate Medical, MoonGate Aesthetics & Anti-aging and MoonGate Chemist.

“Individual” means a natural person.

“Personal information” means any information about an identified or identifiable individual.

“Sensitive personal information” means any personal information relating to an individual’s place of origin, race, color, national or ethnic origin, sex, sexual orientation, sexual life, marital status, physical or mental disability, physical or mental health, family status, religious background, political opinions, trade union membership, medical, biometric information or genetic information.

“Biometric information” means any information relating to physical, physiological or behavioral information or characteristics pertaining to his or her unique identification.

“Genetic information” means all personal information relating to the genetic DNA, characteristics of an individual that have been inherited or acquired, which give unique information about the physiology or the health of that individual resulting from an analysis of a biological sample from said individual.

“Use” in relation to personal information means carrying out any operation on personal information, including collection, obtaining, recording, holding, storing, organizing, adapting, manipulating, altering, receiving, transferring, consulting, disseminating, making available or otherwise, combining, blocking, erasing, destroying or deleting or any other interaction with personal information. 

“Applicant” means an individual who makes a written request in accordance with Section 20 of PIPA.

“Overseas third party” means an organization not domiciled in Bermuda.

“Publicly available information” means personal information about an individual which the individual knowingly makes or permits to be made available to the public, or which is legally obtained or accessed from

  1. Government records that are available to the public; or
  2. Information required by law is to be made available to the public.

Privacy Officer

The privacy officer is responsible for communicating with the Privacy Commissioner and for members of the public to contact if they have any questions or concerns on how MoonGate Group uses personal information. The privacy officer’s name and contact information are as follows:

Leon Bascome CEO

+1 441 542-2201

MoonGate Group

Ground Floor

48 Church Street

Hamilton HM 12

Personal Information

MoonGate Group keeps records about clients’ health, treatment and care that MoonGate Medical, along with other health and medical providers and professionals, has provided or intend to provide. These records form client’s medical records and these records may include personal information such as:

  • Full Legal name, Date of Birth and Residential Address
  • Medical Identifier Number/Code
  • Billing and Health Insurance Information
  • Evidence of Client Consents; and
  • Any other information which is about an identified or identifiable client:
  • Health information, medical history, test results, diagnoses, treatment and treatment plans, prescriptions, laboratory results and other medical information.
  • Insurance information, insurance provider, policy numbers, and claims information.
  • Communication records, notes from consultations, appointments, phone calls, and email communication.  

Sensitive Personal Information

Client’s medical records also may include sensitive personal information such as confirmation of a client’s:

  • ethnicity, place of origin, race and color
  • sex, sexual orientation, sexual life, marital status
  • physical and mental disability and/or health
  • family status and relevant family history or medical history
  • religious beliefs, political opinions and trade union membership
  • biometric information (including facial recognition and fingerprints)
  • genetic information (such information resulting from a testing sample from a client)
  • doctor/hospital/referral appointments/ visit details.
  • current medications, allergies and drug sensitivity; and
  • prescription record (including past and current)

Use of Personal Information

Personal information may be used by MoonGate Group to guide and administer individualized health care to ensure that:

  • our health care professionals have accurate and up to date information to provide a good basis for any treatment or advisory services we provide.
  • full and correct information is available to other healthcare providers from whom individuals may be referred to for receiving treatment/ tests or further examination.
  • our health care professionals can enquire about, refer to and check on the type and quality of treatment that an individual may have received in the past.
  • an individual’s concerns can be properly investigated should they wish to raise a complaint.
  • an individual’s health insurance is in place to cover services offered.

Personal information may be used by MoonGate Group outside of individualized health care administration:

  • to collate records of complaints, safety events and root cause analyses for appropriate incident response.
  • in compliance with a legal requirement to do so.
  • in connection with formal court proceedings and for compliance with a formal court order that has been issued.

Disclosure of Personal Information

MoonGate works closely with other organizations both in Bermuda and offshore, to support health care in accordance with legal requirements. This means your personal/sensitive information may be disclosed by MoonGate Group to other organizations.

These may include*:

  • Credit reference agencies
  • Bermuda Hospital
  • Bermuda Pharmacies
  • Bermuda Healthcare Professionals for purposes of referrals
  • MASA USA Ltd., for patients with our Air Medical Policy
  • Insurance Providers medical/health care
  • Legal Representatives
  • Regulators/ Bermuda Medical Council/ The Information Commissioner

*This is not an exhaustive list.

MoonGate Group may also make disclosures to:

  • Your next of kin, parent or guardian in the case of a minor.
  • Healthcare providers involved in your healthcare (such as psychologists and addiction counsellors, physiotherapists and chiropractors, audiologists, speech and language pathologists, sexual health service providers, optometrists and opticians, dentists, pharmacies and dispensaries);
  • Individuals identified in any valid receivership order, enduring power of attorney and any executor of a deceased person’s estate.

Disclosure of Personal Information Without Consent

There are times when we may make disclosures of a client’s personal information (including sensitive personal information) without their express consent. These may occur when:

  • There is a serious risk of harm or abuse to the client or other people.
  • There is a serious crime being investigated or can be prevented.
  • There is an encounter with an infectious disease that may endanger our staff or the safety of others.
  • A formal court order has been issued.
  • Any other legal requirement to do so.

Record Keeping

Personal Information is retained for the duration of your client relationship with MoonGate Group or for as long as it is necessary in connection with the performance of our contractual obligations to you or if it becomes necessary or required to meet legal and regulatory requirements, resolve disputes, prevent fraud and abuse or enforce our terms and conditions.

We will keep your Personal Information while your account with us is active or until such time as you ask us to stop communications with you, unless we need to keep the information for longer.

If you are no longer a client of MoonGate Group, your personal information is retained for a certain period before being archived and destroyed.

PIPA Rights

MoonGate processes your personal data on one or more of the following legal grounds:

Contractual necessity

To fulfill our obligations to you under a contract for medical care and services.

Legal Obligation

To comply with applicable laws and regulatory requirements, including healthcare regulations.

Vital Interests

It is necessary to protect the health and safety of individuals to administer healthcare services or for administrative purposes related to your treatment.

Consent

Where we have your explicit consent to process your data for specific purposes.

Your rights

  • The right to be informed.

MoonGate through this policy communicates what data is being collected, how it is used, how long it will be kept, and whether it will be shared with any third parties.

  • The right to access.

You may submit a request to our Privacy Officer to provide you with a copy of any personal data concerning you. We have one month to produce this information, although there are exceptions for requests that are manifestly unfounded, repetitive or excessive.

  • The right to rectification.

If you discover that the information we hold on you is inaccurate or incomplete, you may request that it be updated.

  • The right to erasure.

You may request that we erase your data in certain circumstances such as when the data is no longer necessary, the data was unlawfully processed, or it no longer meets the lawful ground for which it was collected.

  • The right to restrict processing.

You may request that we limit the way we use your personal data.

  • The right to data portability.

You are permitted to obtain and reuse your personal data for your purposes across different services. This right applies to the personal data that you have provided to us by way of a contract or consent.

  • The right to object.

You may object to the processing of your personal data, on the grounds of legitimate interests or their performance of a task in the interest/exercise of official authority. We must stop processing information unless we can demonstrate compelling legitimate grounds for the processing that overrides your interests, rights and freedoms or if the processing is for the establishment or exercise of defense of legal claims.

  • The right to stop direct marketing messages.

You may disable direct marketing messages by pressing the unsubscribed button at the bottom of the message. This may take a few days to reflect.

  • The right to complain to your data protection regulator.

You can submit a complaint to the Privacy Officer about any matter concerning your personal information.

Changes In Policy

MoonGate Group reserves the right to change, modify, add to, or remove portions from our Privacy Policy Notice. We will notify you of any changes.