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.
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.
We obtain your Personal Data through the following channels:
(a) From information you provide to us, examples include:
(b) From information lawfully obtained by third parties, examples include:
(c) From publicly available sources:
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:
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).
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:
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:
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;