PIPA

Effective Date: March 2025

Last Updated: May 15, 2025

 

Efficiency Ltd. is committed to protecting the privacy of individuals whose personal information we collect and process. This Privacy Notice outlines how we collect, use, disclose, and safeguard personal information in compliance with Bermuda’s Personal Information Protection Act 2016 (PIPA).

1.      Personal Information

Efficiency collects personal information from our customers and other individuals. We may collect, process, and retain the following types of personal information to deliver our services effectively and meet legal obligations:

 

  • Customer Information: Name, contracts and installation details;

  • Contact Information: Email address, home address and phone number(s);

  • Service History: Maintenance scheduling, correspondence and service requests;

  • Payment and Billing Information: Invoices and transaction history;

  • Photographs and Video Footage: Installation site information and property layout;

  • Marketing and Communication Preferences: Direct marketing preferences;

  • Technical Information: IP address, browser type and version, time zone setting, location, operating system, and device information; and,

  • Usage Data: Website analytics and browsing behaviour.

2.      Data Collection

We collect personal information through:

 

·         Direct interactions. We collect personal information when you:

·         Correspond with us;

·         Request a quote;

·         Request a service;

·         Sign a contract;

·         Visit our premises;

·         Visit our website;

·         Pay for products and services;

·         Place an order;

·         Engage with our employees; and,

·         Sign up to receive email communications.

 

·         Automated technologies. When you visit our website, we automatically collect technical data about your equipment, browsing actions and patterns. This information is collected using cookies, server logs and other similar technologies.

 

·         Third party sources. We may collect personal information from various third parties,  such as:

·         Referrals from industry contractors.

3.      Purposes for using your personal information

 

We only use personal information for the purposes for which it was collected, including:

 

·         Providing services;

·         Managing and fulfilling contracts;

·         Providing equipment warranties;

·         Communicating with you;

·         Account management;

·         Business operations;

·         Marketing and promotion; and,

·         Improving our website.

4.      Conditions for Processing Personal Information

We collect and use personal information in compliance with PIPA and where:

  • Processing is necessary for the performance of a contract to which you are a party or for taking steps at your request before entering into such a contract.

  • It is necessary for our legitimate interests, and these interests do not override your fundamental rights.

  • We need to comply with a legal or regulatory obligation.

  • You have given us consent.

5.      Third-Party Sharing

We require all third parties to respect the security of your personal information and process it in compliance with PIPA. We do not permit our third-party service providers to use your personal information for their own purposes. They are only authorised to process your personal information for specified purposes and in accordance with our instructions.

 

We may share your personal information with:

 

·         Consultants, service providers, contractors, and other third parties engaged to support our operations;

·         Equipment manufacturers or suppliers for the purpose of registering warranties, processing warranty claims, or obtaining replacement parts;

·         Legal advisors, as needed to obtain professional advice or protect our legal interests;

·         Auditors and financial institutions to comply with financial reporting obligations and ensure proper oversight;

·         Any party for a purpose disclosed by us at the time you provide your personal information;

·         Data storage providers; and,

·         Law enforcement agencies as required to comply with legal obligations, court orders, or official requests.

 

 

 

6.        Security of Information

 

We have put in place appropriate operational, technical and physical security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

 

7.        Retention

 

We retain personal information as long as needed for its intended purpose or to meet regulatory requirements.

8.      Closed-Circuit Television (CCTV)

 

We use CCTV to monitor our premises to help maintain a safe and secure environment for our customers and employees and in compliance with data privacy legislation.

 

·         Cameras are in public areas.

·         We do not use covert monitoring or surveillance.

·         Signs are displayed at the entrance to our premises.

 

Purposes of our CCTV System

·         The personal safety of our employees, customers and visitors;

·         To support our health and safety measures;

·         To support law enforcement in the prevention, detection and prosecution of crime; and,

·         To protect our premises and assets (including personal information) and those of our employees, customers and visitors from damage, disruption, vandalism and other crime.

 

Conditions for Processing

·         We will not process CCTV footage unless it captures criminal activity, a security matter or a health and safety incident.

·         We may need to use this personal data to establish, exercise or defend against legal claims.

 

Access and Disclosure

·         Access to recorded CCTV footage is restricted to approved members of staff whose role requires them to have access to such data.

·         CCTV footage will only be accessed or disclosed if it is necessary to deal with an incident which falls within the purposes identified above or to respond to an individual request.

·         CCTV data will only be disclosed to a third party when there is a lawful reason or when required by law.

·         CCTV footage will not be accessed or used for any other purpose.

 

Retention and Security

·         CCTV footage is kept for 14 days when it is automatically erased unless required for a specific investigation (such as criminal damage, when it will be kept only for the duration of that investigation).

·         We have security measures in place to protect CCTV data.

9.        Individual Rights

Every individual has the following data privacy rights:

 

·     The right to be informed: You have the right to know the purposes for which we collect your personal information, how it will be used, and whether it will be shared with third parties.

·     The right to access: You have the right to ask us for copies of the personal information we hold about you. We may charge a small fee for this service.

·     The right to rectification: You have the right to ask us to correct and / or complete any information you think is inaccurate or incomplete.

·     The right to restrict processing: You have the right to request that we restrict the processing of your personal information in certain circumstances (e.g. the accuracy of the information is contested).

·     The right to lodge a complaint: You can file a complaint with Bermuda's Privacy Commissioner if you believe your rights have been violated or if we have failed to comply with PIPA.

 

10.    Cookie Policy

 

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our website, we may collect information from you automatically through cookies or similar technology.

 

The Cookies We Use

Our website uses cookies and similar technologies to enhance your browsing experience and analyse website traffic.

 

·         Essential Cookies: These cookies are fundamental for the website's operation.

·         Performance and Experience-Related Cookies: These cookies enhance the user’s experience by remembering preferences and settings, providing a more personalised browsing session.

·         Form-Related Cookies: When users submit information through forms—such as contact forms or newsletter sign-ups—these cookies may remember user details for future correspondence, streamlining the process for returning users.

·         Analytics Cookies: To collect anonymous data on website traffic and user interactions, helping us improve website performance and user experience.

·         Session Cookies: These are temporary and are deleted once you close your browser.

 

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may impact website functionality.

 


 

11.    Contact Us

If you have any questions about our Privacy Notice, the information we hold about you, or if you would like to exercise one of your data privacy rights, please contact our Privacy Officer:

 

 

Christine Skinner

cskinner@efficiency.bm

441 293-4887

Ryan Saraiva

rsaraiva@efficincy.bm

10 Earl's Lane

Smith’s Parish FL 05

Bermuda

 

 

 

12.    Privacy Commission of Bermuda

If you wish to make a complaint or if you feel we have not addressed your concern in a satisfactory manner, please contact the Privacy Commission of Bermuda at:

 

PrivCom@privacy.bm

www.privacy.bm

(441) 543 7748

Maxwell Roberts Building, 4th Floor

1 Church Street

Hamilton HM 11

Bermuda

 

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