About this Policy

We at EuroLife Ltd. (referred to as ‘we’, ‘us’, ‘our’ or ‘EuroLife’) are committed to protecting your privacy and handling your data in an open and transparent manner. The personal data that we collect and process depends on the product or service requested and agreed in each case.  

This privacy statement sets out general information about how we manage your personal information and how you can contact us about this Privacy Statement or the personal information that we hold.

For the purposes of this privacy statement the following terms mean as follows:

“Personal Data” or “Personal Information” : when we refer to Personal Data or Personal Information, we mean data which identifies or may identify you. An indicative list of the personal data we process can be found under the heading “What Personal Data do we Process?”  below.  In cases of certain insurance policies you may have with us, Personal Data will also include Sensitive Data.

“Processing”: when we refer to Processing of your Personal Data, we collectively refer to the handling, collecting, amending, protecting, storing or other such action of your personal data.

“Sensitive Data”: Sensitive Data is the term we use to describe Special Categories of Personal Data (as these are set out in the GDPR) that we may process, and for our purposes mainly concerns data concerning health which may identify or reveal details about your past or current physical or mental health status, including data on any physical or mental disease or disability. Sensitive data may also include genetic data which is personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person.

“GDPR” : GDPR stands for the General Data Protection Regulation (EU) 2016/679 which is part of the legal framework (along with any other data protection laws or regulations in Cyprus) that governs the processing that we undertake of your personal data.   

Who we are

EuroLife Ltd is a licensed insurance company registered in Cyprus under registration number ΗΕ36247 as a private limited liability company having its registered office at Evrou 4, Strovolos, 2003, Nicosia, Cyprus.  EuroLife Ltd. also operates in Greece by virtue of a Freedom of Services license under the trade name ‘Kyprou Zois’. This privacy statement is also applicable for operations undertaken in Greece under this trade name.   

How we collect your Personal Data

We obtain your Personal Data through the following channels:

(a)    From information you provide to us, examples include:

  • When you visit our website or social media pages or submit written inquiries to our website or social media pages;
  • If you request a quotation for insurance cover either directly or through our insurance representative or undertake an analysis of your insurance needs;
  • When you apply for an insurance policy;
  • When you participate in any marketing activity/competition provided by EuroLife or in any employee/insurance intermediary recruitment process of the Company;
  • When you submit any query or complaint to us through email, telephone or social media;
  • When you submit a claim with us or request an alteration to your policy.

(b)    From information lawfully obtained by third parties, examples include:

  • Directly from an individual or an authorised representative of the legal entity that has a policy with us under which you are either an insured person or a named beneficiary (e.g. your employer for a group policy that is provided to you as an employment benefit);
  • Our representatives and insurance intermediaries who have passed on your Personal Data to us;
  • Persons who provide services to you directly on our behalf such as our healthcare claims handlers, who collect and process your healthcare claims;
  • Medical practitioners or medical facilities;
  • Your legal representatives;
  • Other insurance companies;
  • Other entities within the Bank of Cyprus Group;  
  • Public Authorities.

(c)    From publicly available sources:

  • Department of Registrar of Companies and Official Receiver;
  • The press and media;
  • Internet search engines;
  • Bankruptcy Archive.

 

What Personal Data do we process?

The type of Personal Information we usually collect and process depends on the nature of our interactions and relationship with you. We collect Personal Information about (a) current or potential customers of EuroLife, that is, persons who contract with us for the provision of a service, namely insurance cover (b) insured persons for who we provide cover under a Eurolife insurance policy (c) beneficiaries and nominated representatives of legal entities or of natural persons who hold an insurance policy with Eurolife (d) EuroLife employees and current or potential insurance intermediaries that we cooperate with (e) contact persons of our business partners, suppliers and service providers (f) persons who take part in any competitions/surveys we carry out.

1. The Personal Data collected, handled and processed by us may include:

  • Contact details such as your name, address, telephone number, email address and fax number;
  • Identification details such as your identification or passport number, a copy of your Identification or passport, a copy of your residence permit for non-EU nationals;
  • Biographical and demographic data such as your date of birth, age, gender, marital status, occupation details, or if you hold/held a prominent public function and details in this regard;
  • Financial information such as annual income, source of income, proof of income, bank account number and account details, tax residency and tax identification number; 
  • Information about other previous or current insurance policies you may have and claims histories of such policies;  
  • Information with regard to your lifestyle activities and habits, such as for example smoking and drinking habits or whether you undertake dangerous activities; 
  • Information relevant to your insurance policy such as policy history and status, cash value of the policy, policy and claims numbers;
  • Details of your visits to EuroLife website or social media pages, information you have provided through such channels, information collected through cookies and other tracking technologies;
  • Other information collected in the form of various surveys/marketing research which you agree to participate in or provide other feedback to us regarding our products or services; 
  • Your marketing preferences;
  • Information about your interactions with us including complaints;
  • Sensitive Data
  • Children’s Data 

2. Sensitive Data:

For the provision of insurance cover for certain policies, we also collect and process special categories of data for insured persons. Special categories of data processed by us are data relating to your health (this can include genetic information), and can include details in relation to your past and present physical or mental health including any injury or disability information activities that may impact your health, your health history, fitness and physical activities.  We only collect and hold sensitive information with your consent or in other limited situations which the law allows.

3. Children’s Data

We understand the importance of protecting children’s privacy. We may collect Personal data and Sensitive data in relation to children that are insured persons under Eurolife policies, or that are named or legal beneficiaries of such policies, provided that their parent’s or legal guardian’s consent has been obtained or unless otherwise permitted by law. We do not provide online services to children. For the purposes of this Privacy Statement, “Children” are individuals under the age of eighteen (18).

Why we process your Personal Data and on what legal basis

1. Personal Data

We process your Personal Data lawfully for one or more of the following reasons:

a)      Performance of a contract:

Processing of your Personal Data is necessary for the execution/performance of a contract we have entered into with you (e.g. insurance policy) or in the case of a group insurance policy, with the owner of the policy, or for undertaking certain actions prior to this with the aim of entering into a contract with you.

Indicatively, with regard to an insurance policy you have with us, it is necessary for us to process your personal data with regard to the following:

  • To provide you with advice/undertake an analysis of your insurance needs and to provide you with a quotation/quote you have requested for an insurance policy;
  • To process and underwrite insurance policy applications (including deciding whether or not to provide cover) or determine your eligibility under a group insurance scheme;
  • To provide you with the insurance products and services you’ve asked for or under which you may receive cover or benefits;
  • To administer and service your insurance policy and any claims you make;
  • To respond to your requests or complaints with regard to your insurance policy;
  • To notify you of any changes to your insurance policy or services provided under the insurance policy.

b)      Compliance with a legal obligation

As an insurance company we are subject to a number of legal and regulatory obligations which require the collection and processing of personal data (e.g. anti-money laundering measures, FATCA/CRS, other tax law obligations, compliance with court orders and so forth). Such obligations require processing of certain data, for example we are required to obtain and process certain information from you on your identity, your profession and your income for purposes of compliance with anti-money laundering measures. An additional example is tax information that we may request and process from you for compliance with FATCA/CRS tax treaties to which the Republic of Cyprus is a party.

c)       For the purpose of safeguarding legitimate interests

Where necessary, and taking into account your rights and freedoms, we may process Personal Data above and beyond the actual performance of our contractual obligations, in order to safeguard the legitimate interests pursued by us or by a third party.  Examples include:

  • Initiating legal claims, preparing our defence in litigation procedures and seeking recoveries;
  • Receiving legal or tax advice;
  • Identifying and preventing fraud or other unlawful activities, including irregular or fraudulent claims;
  • Ensuring the security of our network and information systems, as well as the security of our premises and assets (through CCTV monitoring, admittance controls and anti-trespassing measures)
  • Improving our products, services and communications (through e.g. voice recording of telephone communications, opinion requests on our customer service and on the services provided by our representatives, market research and data analysis);  
  • Sharing your personal data with the Bank of Cyprus Group where required for execution of the bancassurance arrangement we have with the Bank as well as for investigations for compliance with the anti-money laundering regulatory framework;
  • Recording and honouring a transfer, assignment or other appointment of a beneficiary of an insurance policy, and payment of a policy to beneficiaries other than the contracting party.

 

d)      You have provided your consent

Provided that you have given us your specific consent for processing then the lawfulness of such processing is based on that consent. You have the right to revoke consent at any time. However any processing of Personal Data prior to the receipt of your revocation will not be affected.

2. Sensitive Personal Data

We process your Sensitive Data lawfully for one or more of the following reasons:

a)       You have provided your consent.

When the insurance policy you wish to purchase or the claim you wish to submit requires the provision of your Sensitive Data, we collect and process such data on the basis of your consent.

You may withdraw your consent to processing of your Sensitive Data at any time, however this will likely impact our ability to provide you with the insurance cover requested or process any claims provided under such cover.  

b)      If it is necessary for the establishment, exercise or defence of legal claims;

c)       If it is necessary for reasons of substantial public interest, such as preventing insurance fraud;

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