This privacy notice sets out how we use your personal information at IFM Limited (IFM), or the links on the IFM website (Website).

For the purposes of this privacy notice, personal information means any information about an identified or identifiable individual and can include such information that can allow someone to identify you either directly (e.g. through your name) or indirectly (e.g. through your address, phone number or date of birth) (Personal Information).

Please read this document carefully and contact us if you have any questions. By accessing and using our Website and providing your Personal Information you are deemed to have read this privacy notice, understood its contents and agree to the provisions contained herein.

The Personal Information Protection Act 2016 (PIPA) provides individuals in Bermuda with protection of their rights in relation to their Personal Information. This privacy notice is written with a view of ensuring compliance with PIPA requirements.

 

1. Who we are & our contact details

IFM is a limited company incorporated in Bermuda and a subsidiary of Liberty ReGen Group Limited (ReGen). ReGen is a subsidiary of Liberty Group Limited (LGL). LGL is also a limited company incorporated in Bermuda.

In addition to being a parent company of IFM, ReGen is a parent company to, among others:

• AIRCARE LTD.
• iEPC Limited
• Liberty Fuze Limited

ReGen and its subsidiaries are together herein referred to as the “ReGen Group”.

IFM’s principal place of business is located at:

25 Serpentine Road
Pembroke, HM07
Bermuda

Any reference to “our”, “we” or “us” in this privacy notice means the ReGen Group. Any references to “you” or “your” means those persons who access or use the Website and/or provide their Personal Information by email links located on the Website.

As the parent company for IFM, ReGen may provide certain services to its subsidiaries that include, but may not be limited to:

• Human Resources
• IT
• Finance

As the parent company of ReGen Group, LGL may provide certain services to its subsidiaries that include, but may not be limited to:

• Legal/Privacy
• Marketing/Communications

The provision of the above services may require the transfer of Personal Information between the ReGen Group and LGL. All members of the ReGen Group are subject to the applicable LGL policies related to privacy and data protection, which aims to protect the Personal Information of ReGen Group customers.

If you have any questions about this privacy notice or about our use of your Personal Information please contact our privacy officer, Ms. Wendy King (Privacy Officer), using the following contact details:

Office Address:
27 Serpentine Road
Pembroke HM 07
Bermuda

Mailing Address:
PO Box HM 3392
Hamilton HM PX
Bermuda

Email: privacy@liberty.bm

 

2. What personal information do we use?

The Website, aligning system and the security systems may request and store any of the following data and information:

• Your name and address (mailing address) and other contact information related to service call or otherwise (e.g. home and work telephone numbers and email addresses)
• Your correspondence or communications with us through our Website or by email, including comments or concerns.
• Your submitted pictures or images, when applicable.
• Anonymous statistics collected as you browse the Website.
• Personal information that you knowingly give to us in the course of doing business with you for business purposes.
• Your video Images from CCTV footage on and around our premises.

 

3. How we use your personal information?

We may use your Personal Information for any of the following purposes:

• Deliver the services you requested.
• Respond to your enquiries and maintain business relations with you.
• Improve information about our services.
• Confirm your identity.
• To allow access to our products and services and to enhance our product or service offerings.
• To contact you to participate in quality control or other market research surveys with the goal of improving customer satisfaction and developing better products and services. Note that you can opt out of participating in these engagements.
• To improve and broaden the range of products services available to you.

 

4. Who has access to your personal information & do we transfer your personal information to organisations in Bermuda/overseas?

Your Personal Information is generally used to:

• Support the provision of requested services; and/or
• Support the performance of a duty related to service.

All staff are required to adhere to LGL’s policies regarding data protection and the relevant Personal Information will only be shared and/or accessed by staff members who have a need to know such information to carry out their work functions in the course of delivering the services required by our customers.

We transfer your Personal Information to third parties located in or outside of Bermuda for the purposes of completing tasks relating to the operation of our Website and/or the delivery of our services.

When using third party service providers located either in or outside of Bermuda, only the Personal Information that is necessary for the execution of the task will be disclosed. In addition, these third parties are held to the same standard for protecting your Personal Information as required by PIPA.

Unless you have consented, we will not share your Personal Information with third parties for marketing purposes. We will not sell or rent your Personal Information.

 

5. How long do we keep your personal information?

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this privacy notice unless a longer retention period is required for a business purpose or allowed by law.

 

6. What are your rights?

We will do all we reasonably can to assist you with any issue arising from our use of your Personal Information.

You may request that we do the following with your Personal Information:

• Access or Limit the use of access,
• Rectify (correct inaccurate information),
• Block (stop the use of all or part of your Personal Information),
• Erase or
• Destroy.

 

7. How can you exercise your access rights to your Personal Information?

If you would like to request access to, rectify, block, erase or destroy your Personal Information, you can submit a written request to the Privacy Officer at privacy@liberty.bm. We may request specific information from you to verify your identity.

Note that access to your Personal Information may not be allowed where:

• Protected by legal privilege.
• Disclosure would reveal confidential information about the Company or a third party that is of a commercial nature, and it is not unreasonable to withhold the information.
• The Personal Information is being used for current disciplinary or criminal investigation or legal proceedings and refusal does not prejudice the right of the individual to receive a fair hearing.
• The Personal Information is being used for mediation or arbitration purposes.
• Disclosure would reveal the intentions of the Company in relation to negotiations with the individuals to the extent that the provision of access would likely prejudice such negotiations.
• Disclosure would reasonably be expected to threaten the life or security of an individual.
• The Personal Information will disclose personal information about another individual.
• The Personal Information would reveal the identity of an individual who has in confidence provided an opinion about another individual and the individual does not consent to the disclosure of his/her identity.

 

8. Security

We maintain reasonable and appropriate security measures to protect your Personal Information from loss, misuse, unauthorised access, disclosure, alteration or destruction in accordance with the PIPA.

Note that information transmitted over the internet cannot be guaranteed as 100% secure. As a result, while we strive to protect your Personal Information, we cannot guarantee the security of any information you transmit to us.

However, once we receive your Personal Information, we will make all reasonable (and appropriate) effort to ensure its security on our systems by constantly monitoring the security of our systems and reviewing our policies and procedures pertaining to such on a regular basis.

 

9. Privacy Notice (administrative details)

Privacy notice No. version 1.0
Effective Date: January 2025
Last Updated: December 2024

On occasion we will update this privacy notice.
Any amended privacy notice becomes effective once published.