This Notice is designed to help you understand what kind of information Preferred Global Health Ltd. of Canon’s Court, 22 Victoria Street, Hamilton HM 12, Bermuda and its subsidiaries (“PGH”) collects in connection with our products and services and how we will process and use this information. In the course of providing you with products and services we will collect and process information that is commonly known as personal data. Under applicable European data protection laws, including the General Data Protection Regulation and all other supplemental and other laws governing data security and data protection in the European Economic Area, UK and Switzerland (the “European Data Privacy Laws”), PGH is a data controller. Although the PGH servicing subsidiary is located in the US, which has a lower standard of data protection laws compared to the Data Privacy Laws, it adheres to The Health Insurance Portability and Accountability Act of 1996, HIPAA. In Summary, the HIPAA Privacy Rule was issued to limit the use and disclosure of sensitive Personal Health Information, PHI. It seeks to protect the privacy of patients by requiring Hospitals, Doctors and other Health Care Service Providers (Providers) to provide patients with an account of each entity to which the Provider of services discloses PHI for billing and administrative purposes, while still allowing relevant health information to flow through the proper channels. Furthermore, it provides federal standards to safeguard the privacy of PHI and gives patients an array of rights with respect to that information, including rights to examine and obtain a copy of their health records and to request corrections. The U.S. Department of Health & Human Services' (HHS) Office of Civil Rights (OCR) oversees compliance with HIPAA privacy requirements.
This Notice describes how we collect, use, share, retain and safeguard personal data.
This Notice sets out your individual rights; we explain these later in the Notice but in summary these rights include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data.
Please read carefully. Effective date 18 July 2018.
The information we hold about you includes the following categories of information:
The sources of this information are:
All the personal information we collect from you or generated by you is used to provide the services you have requested or for communications to which you have subscribed. We will safeguard the privacy and security of your personal data, including your medical and health data, as required under applicable laws including the European Data Privacy Laws. You may also consent to us using your personal information for additional purposes not described in this Notice. We will not use your personal information for these additional purposes without your consent. You have the right to tell us that you do not want to be contacted by us for these additional purposes any time after you initially provide your consent.
We are also permitted to process your personal information to comply with our legal and regulatory obligations and/or our contractual obligations to you to provide the services to you and to manage any technical issues or support requests that may arise.
We do not allow any third parties to have access to your personal information, except as required or permitted by applicable laws or in accordance with the Notice. We may disclose your personal information to our subcontractors, agents, or payment service providers (who may be located in the US) that we contract with to assist us in providing the services, provided that any such subcontractors or agents adhere to HIPAA or shall agree in writing to comply with the privacy and security standards described in this Notice.
There may be instances when we disclose your personal information to other parties:
We may share your personal information with other entities in connection with the sale, assignment, merger or other transfer of all or a portion of PGH’s business to that other entity.
PGH understands that storing data in a secure manner is essential. PGH stores personal information and other data using reasonable physical, technical and administrative safeguards to secure data against foreseeable risks, such as unauthorized use, access, disclosure, destruction or modification. Although we make good faith efforts to store the information we collect in a secure operating environment that is not available to the public, we cannot guarantee complete security. Further, while we work to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party "hackers" from illegally obtaining this information.
We retain your personal data relating to our services for the duration of our business relationship and for seven years after the policy has expired for legal, regulatory, audit and tax requirements. After this period has expired, the personal information relating to your policy will be deleted or de-identified. Any personal information which you have provided to us for marketing purposes will be kept until you notify us that you no longer wish to receive this information.
Subject to applicable European Data Privacy Laws, you have the right to:
You have some choices in the way that we use and share information as we:
We may use and share your information with third-parties as we:
When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you. These rights are, where applicable, subject to laws including the European Data Privacy Laws.
Receive a copy of health and claims records
Ask us to correct health and claims records
Request confidential communications
Ask us to limit what we use or share
Ask for your personal information to be deleted
Get a list of those with whom we’ve shared information
Get a copy of this privacy notice
Select a third party to act for you
File a complaint if you feel your rights have been violated
For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions.
In these cases, you have both the right and choice to tell us to:
If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.
In these cases we never share your information unless you give us written permission:
We typically use or share your health information in the following ways.
Help manage the health care treatment you receive
We can use your health information and share it with professionals who are treating you.
Example: A doctor sends us information about your diagnosis and treatment plan so we can arrange additional services.
Run our organization
Example: We use health information about you to develop better services for you.
Pay for your health services
We can use and disclose your health information to PC/PHCC insurers and the insurers’ reinsurers to pay for your health services.
Example: We share information about you with your insurer to coordinate payment for your medical expenses.
Protecting your Data
We will take all appropriate technical and organisational steps to protect the confidentiality, integrity, availability and authenticity of your data, including when sharing your data within our company and authorised third parties.
We are allowed or required to share your information in other ways – usually in ways that contribute to the public good, such as public health and research. We have to meet many conditions in information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html.
Help with public health and safety issues
We can share health information about you for certain situations such as:
Conduct research
We can use or share your information for health research.
Comply with the law
We will share information about you if state or federal laws require it. This includes the Department of Health and Human Services, if they want to confirm that we’re complying with federal privacy law.
Respond to organ and tissue donation requests and work with a medical examiner or funeral director
Address law enforcement and other government requests
We can use or share health information about you:
Respond to lawsuits and legal actions
We can share health information about you in response to a court or administrative order, or in response to a subpoena.
Uses or Disclosures (Sharing) of Information that Require Your Written Permission (Authorization)
Using and/or disclosing health information for other purposes not described in this Notice requires your specific authorization. For example, unless you give your authorization, PGH may not sell your health information or disclose such information in exchange for payment to a third party for purposes of marketing their products or services to you. Furthermore, certain information that may be contained in your medical record is considered by state and/or federal law to be highly confidential, including, for example, HIV testing or test results, certain clinical psychotherapy documentation, and certain genetic information; therefore, this type of information gets additional protection from disclosure, and, at times requires your written authorization even before disclosure for treatment, payment, or health care operations. If you are asked to and give written authorization for the use and/or disclosure of your health information, you may withdraw such authorization at any time in writing or, in certain limited cases, orally, except to the extent that the providers have already acted upon your previously provided authorization.
International transfers of personal data
We will process and transfer your data to third parties based in the US and other jurisdictions outside the European Economic Area and UK that may also have less stringent data privacy laws compared to the European Data Privacy Laws. This is necessary for the purposes of administering our business and underwriting and claims processing purposes. Such parties are not permitted to use your personal data for any other purpose than for what has been agreed with us. These parties are also required to safeguard your personal data through the use of appropriate technical and organizational data security measures and are prohibited from disclosing or sharing your data with other third parties without our prior authorization, or unless as required by law.
Please contact Privacy@pghworld.com for a list of countries and organizations your personal data is transferred to and/or for further information on the measures undertaken to safeguard your data.
Right to Erasure
You have the right to request from PGH the erasure of personal data concerning yourself without undue delay. We shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
For more information see:
www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.htmlWe can change the terms of this notice at any time and without prior notice to you, and the changes will apply to all information we have about you. The new notice will be available upon request, on our web site, and we will mail a copy to you.