The confidentiality of your Personal Data is our priority. For this reason, all the persons who are recipients of your Personal or Sensitive Data are subject to an obligation of confidentiality and of processing your data in accordance with applicable data protection law and GDPR. Data is disclosed to such recipients and processed by such recipients only for the purposes set out above under the heading “Why we process your Personal and Sensitive Data and on what legal basis”.
Recipients of your data may be, for example:
Some of the recipients of your personal data may be located in third countries (i.e. countries outside the European Economic Area). We ensure that such processers are obligated to comply with the European data protection standards and to provide appropriate safeguards in relation to the transfer of your data in accordance with the GPR.
We will keep your personal data for as long as we have a business relationship with you as either an individual or as an appointed representative of a legal entity, or a beneficial owner.
Once our business relationship with you has ended, we may keep your personal data for the longest of the following periods: (i) any retention period set out in our retention policy which is in line with regulatory requirements relating to retention or (ii) the end of the period in which legal action or investigations might arise in respect of the products and services provided.
We may keep your data for longer if we cannot delete it for legal, regulatory or technical reasons. If we do, we will make sure that your privacy is protected and only use it for these purposes.
For prospective customer data we shall keep your personal data for 12 months from the date that a quotation was provided to you, assuming that no insurance applications or policies arose in relation to the quotation provided, or unless you have requested that we maintain this data for a further period of time as determined by yourself.
With regard to certain types of insurance cover, when you wish to submit an electronic application for such insurance cover with us, we will use systems to make automated underwriting decisions based on Personal and Sensitive Data you have provided us with. You have the right in this case to contact us to:
a) Give you information about the processing of such Data
b) To object to such electronic underwriting and to request that you are assessed by our Underwriting Department instead. In such a case we will require the completion of a hard copy insurance application.
We may process your personal data to tell you about products, services and offers that may be of interest to you or your business.
The personal data that we process for this purpose consists of information you provide to us and data we collect and/or infer when you use our services, such as information on your policy transactions. We study all such information to form a view on what we think you may need or what may interest you. In some cases, profiling is used, i.e. we process your data automatically with the aim of evaluating certain personal aspects in order to provide you with targeted marketing information on products.
We can only use your personal data to promote our products and services to you if we have your explicit consent to do so or, in certain cases, if we consider that it is in our legitimate interest to do so.
You have the right to object at any time to the processing of your personal data for marketing purposes, which includes profiling, by contacting at any time our Customer Services Center or any of our branches either in person or in writing.
In order for us to proceed with a business relationship with you, you must provide the Personal Data required for the commencement and execution of a business relationship and the performance of our contractual obligations.
In the case of an insurance policy you wish us to provide to you, this means that If you do not provide us with the necessary personal information requested in our quotations, application or claim forms, we will most likely not be in a position to accept your application for insurance with us, or any claims you may make under the Policy.
Furthermore we are obligated in certain circumstances to collect personal data from you for compliance with our legal obligations, such as for example identification details for compliance with anti-money laundering measures and tax details for compliance with FATCA/CRS treaties.
Kindly note that if you do not provide us with the required data, then we will not be allowed to commence or continue our business relationship either with you as an individual or as the authorized representative of a legal entity or beneficial owner of a policy.