Bernina Re Ltd. (“Bernina Re”), a company headquartered in Hamilton, Bermuda with a branch office in Switzerland, understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.berninare.com (“Website”) and (subject to the limited exceptions in section 5, below) we do not collect personal data about you unless you contact us (see section 6, below). Any personal data we do collect will only be used as permitted by law.
Please read this Privacy Policy (“Policy”) carefully and ensure that you understand it. Your acceptance of the Policy is deemed to occur upon your first use of the Website. If you do not accept and agree with this Policy, you must stop using the Website immediately.
In this Policy, the following terms shall have the following meanings:
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via the Website. This definition shall, where applicable, incorporate the definitions provided in the Bermuda Personal Information Protection Act (“PIPA”), Swiss Data Protection Act (as revised from time to time) (“DPA”), and/or the General Data Protection Regulation (“GDPR”);
“sensitive personal data” means any personal information relating to an individual’s place of origin, race, colour, national or ethnic origin, sex, sexual orientation, sexual life, marital status, physical or mental disability, physical or mental health, family status, religious beliefs, political opinions, trade union membership, biometric information or genetic information; and
“we/us/our” means Bernina Re Ltd., including Bernina Re Ltd. Swiss Branch, a limited company registered in Bermuda.
This Policy applies only to your use of the Website. The Website may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
As a data subject, you have the following rights under PIPA, DPA and/or GDPR:
The right to be informed about our collection and use of personal data;
The right of access to the personal data we hold about you (see section 5);
The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section 9);
The right to be forgotten – i.e., the right to ask us to delete any personal data we hold about you;
The right to restrict (i.e., prevent) the processing of your personal data;
The right to data portability (obtaining a copy of your personal data to re-use with another service or organization);
The right to object to us using your personal data for particular purposes; and
Rights with respect to automated decision making and profiling.
If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 9 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the Bermuda Privacy Commissioner, Swiss Federal Data Protection and Information Officer (“FDPIC”), and/or any competent EU supervisory authority (as the case may be).
Subject to section 6.2, we do not collect any personal data from you.
If you send us an email, we may collect your name, your email address, and any other information which you choose to give us.
If we do collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under PIPA, the DPA and/or GDPR at all times. For more details on security see section 7.2, below.
As noted above, we do not generally collect any personal data. If you contact us and we obtain your personal details from your email, we may use them as follows:
To reply to your email;
To reply to any other request submitted by you.
Personal data is only shared with employees of Bernina Re on a need to know basis.
Personal data will not be transferred to overseas third parties for use by the overseas third parties.
You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
Personal data used by Bernina Re will be adequate, relevant and not excessive to the purpose for which it is used.
We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.
Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure any data we hold about you (even if it is only your email address).
We make sure your personal data is kept up to date once you send us new information.
In case of a breach of security, the company will proceed according to its defined Incident Management Plan and where necessary the Privacy Officer will notify any affected individuals and the Privacy Commissioner.
You have the right to ask for a copy of any of your personal data held by us (where such data is held). Please contact us for more details at info@berninare.com.
Bernina Re will respond to a request for a copy of personal data held by us within 45 days of receipt of the request. Where we are not permitted by law to provide you with the personal data requested, Bernina Re will notify you in writing.
If you have any questions about the Website or this Policy, please contact our Privacy Officer, Michael Dennis, by email at info@berninare.com. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you.
We may change this Policy from time to time (for example, if the law changes). Any changes will be immediately posted on the Website and you will be deemed to have accepted the terms of the Policy on your first use of the Website following the alterations. We recommend that you check this page regularly to keep up-to-date.