PRIVACY POLICY. Last Modified: 23 rd of May, 2018

Transcription

1 PRIVACY POLICY Last Mdified: 23 rd f May, 2018 Infrmatin abut Us ALTIUS INSURANCE LTD (hereinafter we, us r ur ) is the cntrller f the infrmatin cllected r prvided directly. We respect yur privacy and yur persnal data and are cmmitted t prtecting it thrugh ur cmpliance with applicable privacy and data prtectin laws and regulatins. Please read this privacy plicy carefully t understand ur plicies and practices regarding yur infrmatin and hw we will treat it. If yu have any questins abut ur privacy practices, please refer t the end f this privacy plicy fr infrmatin n hw t cntact us. Scpe f ur Privacy Plicy This privacy ntice applies t anyne wh interacts with us abut ur prducts and services ( yu, yur ), in any way (fr example, by , thrugh ur website, by phne). We will give yu further privacy infrmatin if necessary fr specific cntact methds r in relatin t specific prducts r services. This privacy ntice applies t yu if yu ask us abut, buy r use ur prducts and services. It describes hw we handle yur infrmatin, regardless f the way yu cntact us (fr example, by , thrugh ur website, by phne and s n). The plicy als applies t infrmatin we cllect thrugh third parties in the standard curse f the business we d in rder t prvide yu with the service yu requested. We will prvide yu with further infrmatin r ntices if necessary, depending n the way we interact with each ther, fr example if yu use ur apps we may give yu privacy ntices which apply just t a particular type f infrmatin which we cllected thrugh that app. Cllectin f Persnal Infrmatin We cllect and use several types f infrmatin the individuals we c-perate with, including infrmatin by which yu may be persnally identified and that is defined as persnal data r persnally identifiable infrmatin under applicable law ( Persnal

2 Infrmatin ), such as yur first and last name, address, billing infrmatin, demgraphics, telephne number, r ther (nline) cntact infrmatin, persnal details, health related infrmatin. Categries f Persnal Infrmatin we cllect, and use include: Infrmatin that yu prvide by filling in frms, in particular at the time f first cntact with us. Recrds and cpies f yur crrespndence (including addresses), if yu cntact us. Details f insurance payment claims yu perfrm including the supprting evidence yu submit with them. Purpses fr Which We Use Yur Persnal Infrmatin In general, we use infrmatin that we cllect abut yu r that yu prvide t us, including General Persnal Infrmatin and Special Persnal Infrmatin (sensitive), fr fllwing purpses: Prvisin f services: t prvide yu with infrmatin n ur insurance prducts, n the prducts r services that yu request frm us and fr fulfilling ur bligatins in rder t prvide yu the service yu requested, and we agreed t prvide; Custmer management: t manage yur accunt t prcess yur claims and t t prvide yu with the necessary supprt and insurance cverage. Further we will prvide yu with ntices abut yur accunt, including ntices, ntices abut changes t any prducts r services we ffer r prvide thrugh it; Advertising: fllwing explicit cnsent t cmmunicate with yu abut prducts r services that may be f interest t yu either frm us, ur affiliates r ther third parties; Functinality and security: t detect, prevent, and respnd t actual r ptential fraud, illegal activities, r intellectual prperty infringement; Cmpliance: t enfrce ur terms and cnditins and t cmply with ur legal bligatins as these derive frm the applicable laws r ur regulatrs; in any ther way we may describe when yu prvide the infrmatin; r fr any ther purpse with yur cnsent prvided separately frm this privacy plicy. Disclsure f Yur Persnal Infrmatin We want yu t understand when and t whm we disclse Persnal Infrmatin and ther infrmatin we have cllected abut yu r yur activities n the Website. We d nt share yur Persnal Infrmatin with third parties except as indicated belw:

3 Affiliates. We share abve categries f Persnal Infrmatin with ur subsidiaries and affiliates t the extent this is necessary fr the purpses f prvisin f services, custmer management, custmizatin f cntent, advertising (if yu have cnsented) and security, and cmpliance, r t the extent yu have prvided yur cnsent prvided separately frm this privacy plicy. Service Prviders. T ur authrized service prviders that perfrm certain services n ur behalf, including fr purpses f prvisin f the services yu requested frm us, custmer management and security. These services may include fulfilling rders, prcessing credit card payments, risk and fraud detectin and mitigatin, prviding custmer service and marketing assistance. These service prviders may have access t Persnal Infrmatin needed t perfrm their functins but are nt permitted t share r use such infrmatin fr any ther purpses. We have taken all reasnable steps t ensure that they cmply with the current data prtectin regulatins. Legal successrs. T a buyer r ther successr in the event f a merger, divestiture, restructuring, rerganizatin, disslutin r ther sale r transfer f sme r all f ur assets, whether as a ging cncern r as part f bankruptcy, liquidatin r similar prceeding, in which persnal infrmatin held by is amng the assets transferred. Shuld such a sale r transfer ccur, we will use reasnable effrts t try t ensure that the entity t which we transfer yur persnal infrmatin uses it in a manner that is cnsistent with this privacy plicy. Other. T the extent this is necessary t fulfill any ther purpse nt mentined abve fr which yu prvided Persnal Infrmatin and, if applicable, yur cnsent separately frm this privacy plicy. We als disclse yur Persnal Infrmatin t ther third parties, including fficial authrities, curts, r ther public bdies: In respnse t a subpena r similar investigative demand, a curt rder r ther judicial r administrative rder, r a request fr cperatin frm a law enfrcement r ther gvernment agency; t establish r exercise ur legal rights; t defend against legal claims; t cmply with applicable law r cperate with law enfrcement, gvernment r regulatry agencies; r t enfrce ur Website terms and cnditins r ther agreements r plicies; r as therwise required by law (including respnding t any gvernment r regulatry request). In such cases, we may raise r waive any legal bjectin r right available t us, in ur sle discretin. T the extent a disclsure is necessary in cnnectin with effrts t investigate, prevent, reprt r take ther actin regarding illegal activity, suspected fraud r ther wrngding; t prtect and defend the rights, prperty r safety f ur cmpany, ur users, ur emplyees, r thers; t maintain and prtect the security and integrity f ur Website r infrastructure.

4 Third parties t whm we may disclse Persnal Infrmatin may have their wn privacy plicies which describe hw they use and prtect Persnal Infrmatin. If yu want t learn mre abut their privacy practices, we encurage yu t visit the websites f thse third parties. We may disclse aggregated infrmatin abut ur users, and infrmatin that des nt identify any individual, withut restrictin. In particular, we may transfer nn- Persnal Infrmatin and prcess it utside yur cuntry f residence, wherever the Website, its affiliates and service prviders perate. We may cmbine nn-persnal Infrmatin we cllect with additinal nn-persnal Infrmatin cllected frm ther surces. We als may share aggregated infrmatin with third parties, including advisrs, advertisers and investrs, fr the purpse f cnducting general business analysis. Hw We Stre Yur Persnal Infrmatin The infrmatin that we cllect abut yu, including Persnal Infrmatin, will be stred and prcessed in Cyprus and/r in remte cases in the Cuntries in which we and the third parties mentined abve maintain facilities. If yu are lcated in the Eurpean Unin r ther regins with laws gverning data cllectin and use that may differ frm Eurpean data prtectin laws, please nte that in the curse f prviding yu with the service yu requested we may transfer Persnal Infrmatin t sme f these cuntries and jurisdictins that have data prtectin laws that d nt prvide the exact same level f prtectin as in yur jurisdictin, hwever we make every effrt pssible t verify and audit that the prcessr and sub prcessrs prvide the best level f prtectin f persnal data. Retentin f Persnal Infrmatin We keep yur persnal infrmatin in line with set perids calculated using the fllwing criteria. Hw lng yu have been a custmer with us, the types f prducts r services yu have with us, and when yu will stp being ur custmer. Hw lng it is reasnable t keep recrds t shw we have met the bligatins we have t yu and by law. Any time limits fr making a claim. Any perids fr keeping infrmatin which are set by law r recmmended by regulatrs, prfessinal bdies r assciatins. Any relevant prceedings that apply. If yu wuld like mre infrmatin abut hw lng we will keep yur infrmatin fr, please cntact us at dp@altiusinsurance.cm.cy.

5 Legal Bases fr Cllectin Use and Disclsure f Yur Persnal Infrmatin There are different legal bases that we rely n t cllect, use and disclse yur Persnal Infrmatin, namely: Cnsent: We will rely n yur cnsent t use (i) yur Persnal Infrmatin fr marketing and advertising purpses; (ii) yur Persnal Infrmatin fr ther purpses when we ask fr yur cnsent separately frm this privacy plicy and fr which the purpse f the prcess des nt relate t the services we ffer t yu. Perfrmance f cntract: The use f yur Persnal Infrmatin fr purpses f prviding the services, custmer management and functinality and security as described abve is necessary t perfrm the services prvided t yu under ur term and cnditins and any ther cntract that yu have with us. Cmpliance with legal bligatin: We are permitted t use yur Persnal Infrmatin in t the extent this is required t cmply with a legal bligatin t which we are subject. Hw We Prtect the Security f Yur Persnal Infrmatin We take apprpriate security measures (including physical, electrnic and prcedural measures) t safeguard yur Persnal Infrmatin frm unauthrized access and disclsure. Fr example, nly authrized emplyees are permitted t access Persnal Infrmatin, and they may d s nly fr permitted business functins. In additin, we have trained ur emplyees n hw t handle, manage and prcess persnal data, applied upgraded technical measures and transfrmed ur plicies and prcedures in a way that will cmply with the General Data Prtectin Regulatin. Users shuld als take care with hw they handle and disclse their Persnal Infrmatin and shuld avid sending Persnal Infrmatin thrugh insecure . We are nt respnsible fr circumventins f any privacy settings r security measures cntained n the Website. Chices Abut Hw We Cllect, Use and Disclse Yur Persnal Infrmatin We strive t prvide yu with chices regarding the Persnal Infrmatin yu prvide t us. Yu can chse nt t prvide us with certain Persnal Infrmatin but depending n the infrmatin yu may chse nt t prvide us with, that may result in assessing yu in a different and ptentially wrse way. When yu register with us, yu may be given a chice as t whether yu want t receive messages, newsletters r advertising material abut prduct updates, imprvements, special ffers, r cntaining special distributins f cntent by us. If cnsented yet later n yu decide yu n lnger want t receive cmmercial r prmtinal s r newsletters frm us, yu will need t avail

6 yurself by cntacting the Cmpany directly either via r phne at the infrmatin mentined at the end f this dcument. It may take up t seven days fr us t prcess an pt-ut request. We may send yu ther types f transactinal and relatinship cmmunicatins, withut ffering yu the pprtunity t pt ut f receiving them as these will related directly t yur relatinship with us. If yu prvided Persnal Infrmatin, yu may terminate yur relatinship with us at any time as per the prvisin f the between us agreement r engagement. If yu chse t d s, yur Persnal Infrmatin will be deleted in accrdance with ur retentin plicy. Yur Rights Related t Yur Persnal Infrmatin Yu have the right t access yur infrmatin and t ask us t crrect any mistakes and delete and restrict the use f yur infrmatin. Yu als have the right t bject t us using yur infrmatin, t ask us t transfer f infrmatin yu have prvided, t withdraw permissin yu have given us t use yur infrmatin and t ask us nt t use autmated decisin-making which will affect yu. Fr mre infrmatin, see belw. Yu have the fllwing rights (certain exceptins apply). Right f access: the right t make a written request fr details f yur persnal infrmatin and a cpy f that persnal infrmatin Right t rectificatin: the right t have inaccurate infrmatin abut yu crrected r remved Right t erasure ('right t be frgtten'): the right t have certain persnal infrmatin abut yu erased Right t restrictin f prcessing: the right t request that yur persnal infrmatin is nly used fr restricted purpses Right t bject: the right t bject t prcessing f yur persnal infrmatin in cases where ur prcessing is based n the perfrmance f a task carried ut in the public interest r we have let yu knw the prcessing is necessary fr ur r a third party s legitimate interest. Yu can bject t ur use f yur infrmatin fr prfiling purpses where it is in relatin t direct marketing Right t data prtability: the right t ask fr the persnal infrmatin yu have made available t us t be transferred t yu r a third party in machine-readable frmats Right t withdraw cnsent: the right t withdraw any cnsent yu have previusly given us t handle yur persnal infrmatin. If yu withdraw yur cnsent, this will nt affect the lawfulness f Bupa s use f yur persnal infrmatin prir t the withdrawal f yur cnsent and we will let yu knw if we will n lnger be able t prvide yu yur chsen prduct r service Right in relatin t autmated decisins: yu have the right nt t be subject t a decisin based slely n autmated prcessing which prduces legal effects cncerning yu r similarly significantly affects yu, unless it is necessary fr entering int a cntract with yu, it is authrised by law r yu have given yur

7 explicit cnsent. We will let yu knw when such decisins are made, the lawful grunds we rely n and the rights yu have. Please nte: Other than yur right t bject t the use f yur data fr direct marketing (and prfiling t the extent used fr the purpses f direct marketing), yur rights are nt abslute: they d nt always apply in all cases and we will let yu knw in ur crrespndence with yu hw we will be able t cmply with yur request. Yu may, at any time, send us an at dp@altiusinsurance.cm.cy t exercise yur abve rights in accrdance with the applicable legal requirements and limitatins. If yu are lcated in the Eurpean Ecnmic Area, yu have a right t ldge a cmplaint with the lcal data prtectin authrity being the Office f the Cmmissiner fr the Prtectin f Persnal Data. Als nte that it is pssible that we require additinal infrmatin frm yu in rder t verify yur authrizatin t make the request and t hnr yur request. Changes t Our Privacy Plicy We may mdify r revise ur privacy plicy frm time t time. Althugh we may attempt t ntify yu when majr changes are made t this privacy plicy, yu are expected t peridically review the mst up-t-date versin fund at ur website s yu are aware f any changes, as they are binding n yu. If we change anything in ur privacy plicy, the date f change will be reflected in the last mdified date. Yu agree that yu will peridically review this privacy plicy and refresh the page when ding s. Yu agree t nte the date f the last revisin t ur privacy plicy. If the last mdified date is unchanged frm the last time yu reviewed ur privacy plicy, then it is unchanged. On the ther hand, if the date has changed, then there have been changes, and yu agree t re-review ur privacy plicy, and yu agree t the new nes. By cntinuing t use the Website subsequent t us making available an amended versin f ur privacy plicy in a way that yu can easily take ntice f it, yu thereby cnsent t such amendment. Enfrcement; Cperatin We regularly review ur cmpliance with this privacy plicy. Please feel free t direct any questins r cncerns regarding this privacy plicy r ur treatment f Persnal Infrmatin by cntacting us thrugh this Website at we receive a frmal written cmplaint, it is ur plicy t cntact the cmplaining party regarding his r her cncerns. We will cperate with the apprpriate regulatry authrities, including lcal data prtectin authrities, t reslve any cmplaints regarding the cllectin, use and disclsure f Persnal Infrmatin that cannt be reslved by an individual and us.

8 N Rights f Third Parties This privacy plicy des nt create rights enfrceable by third parties r require disclsure f any Persnal Infrmatin relating t users f the Website. N Errr Free Perfrmance We d nt guarantee errr-free perfrmance under this privacy plicy. We will use reasnable effrts t cmply with this privacy plicy and will take prmpt crrective actin when we learn f any failure t cmply with ur privacy plicy. We shall nt be liable fr any incidental, cnsequential r punitive damages relating t this privacy plicy. Cntact Infrmatin If yu have any questins abut this privacy plicy r ur infrmatin-handling practices, please cntact us at dp@altiusinsurance.cm.cy. Yu may als cntact us at ur Head Offices in Nicsia, Cyprus, telephne