Trust International Insurance Company (Cyprus) Ltd Data Protection Policy
Trust International Insurance Company (Cyprus) Ltd («Trust Cyprus», «we», «us», «our») is a member of the Nest group of companies (hereinafter referred to as the «Group») and is a limited liability company with shares with registration number HE 42182 and having its head office at 79 Limassol Avenue, 1&3 Kosti Palama Corner, 2121 Aglantzia, Nicosia.
Trust Cyprus is active in the General Sector of Insurance in Cyprus since 2009 offering a full range of personal and corporate insurance products. Trust Cyprus belongs in the Nest Group of companies, which operates in 23 countries in the Middle East, Africa, Asia and Australia.
THE PURPOSE OF THIS DOCUMENT
Trust Cyprus is committed to protecting the privacy and security of the personal information of its clients, potential clients, insurance policy holders, authorised parties, vendors, business associates, third party claimants, third parties (non-claimants) and guarantors (the «data subjects», «you»).
This data protection policy describes how we collect and use personal information about you during and after the contractual, commercial or any other kind of relationship with us, in accordance with the General Data Protection Regulation («GDPR») any national implementing laws, regulations and secondary legislation, for so long as the GDPR is effective in Cyprus.
Trust Insurance Cyprus is a «data controller». This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this data protection policy.
This data protection policy applies to current and former clients, potential clients, insurance policy holders, authorised parties, vendors, business associates, third party claimants, third parties (non-claimants) and guarantors. This data protection policy does not form part of any contract of insurance or other contract to provide services. We may update this data protection policy at any time.
It is important that you read this data protection policy, together with any other data protection policy we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
DATA PROTECTION PRINCIPLES
We will comply with data protection law. This provides that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
THE KIND OF PERSONAL INFORMATION WE HOLD ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We will collect, store, and use the following categories of personal information about you in our various departments:
Contact Information: Name, Surname, Email, Address, Telephone Number, Fax
Other Information: Age, Marital Status, Gender, Date of Birth, Occupation, Country of Residence, Vehicle License Plate, Telephone Recordings, Nationality
Identification Information: ID, Passport Number, Driving License Details (i.e. Number, License Category, etc.) Photograph, Signature Specimen, Social Security, National tax
Insurance Policy related Information: Policy and claim identifiers, insured items, travel plans, date and cause of event relevant to the insurance claim (traffic accident, fire, theft etc.), previous insurance claims (prior disputes, prior accidents, traffic records etc.), valuation report
Financial and Credit Information: Bank Account Number and IBAN Certificate, Assets (movable and immovable), Income/Gross Earnings, Fees for Services, Financial Turnover Credit Reference information and Credit Score.
We will hold some sensitive personal information of you and in particular:
Medical Information and Health Condition: health (physical and mental) status, current and previous injuries, disabilities, medical diagnosis, medical and medicinal treatment, unhealthy personal habits that may expose you to increased health risks (such as alcohol consumption or smoking) and any other information related to medical history.
Other sensitive information: certificate of clean criminal record where necessary, Pending criminal or civil litigation against you, History of bankruptcy, Police Reports and Governmental Authorities Reports and any other reports, such as accident reports.
We understand the importance of protecting children’s privacy. We may collect personal data in relation to children provided that we have first obtained their parent’s or legal guardian’s consent or unless otherwise permitted under law. Our website is not designed for use by children nor do we provide any online services to children. For the purposes of this privacy statement, “children” are individuals under the age of sixteen (16).
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about the data subjects:
1. Directly from you during
a. Completion of insurance policy forms for quotation in hard copy, by phone; online via our website
b. Completion of insurance policy proposal forms in hard copy, by phone, online via our website
c. Making a claim as an insured or as a third party (directly or via authorized legal representatives)
d. Making a complaint in relation to insurance policy
e. Submission of general queries in hard copy, by phone, online via our website
2. Through other sources:
a. Our vendors/service providers (e.g. Road Assistance companies, accident care, home assistance, travel assistance, Garages)
b. Insurance Agents/Brokers
c. The insured and/or policy holder (in cases you are a secondary named driver, or employee under an employer’s liability insurance or next of kin or a beneficiary under a public liability insurance etc.)
d. Third Party Insurance Companies
e. From authorized legal representatives
f. Publicly available sources e.g. Department of Registrar of Companies and Official Receiver Registry, Road Transport Department, press and media, internet
g. Authorised Representatives e.g. Family Members, Financial Institutions, Doctors and other medical service providers
h. Liaison Officers (Group Medical Policies)
i. Credit Reference Agencies & Credit Bureaus
j. In the event of a claim, other parties involved, witnesses, medical professionals, assessors, loss adjusters, other experts.
k. Police and other Governmental Authorities which are responsible in preparing relevant reports, such as accident reports
HOW WE WILL USE INFORMATION ABOUT YOU
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the contract we have entered into with you.
a. Provide insurance and other assistance services, including quotations, risk and claim assessment, credit control, and engage with you settlement negotiations and/or dispute resolution.
b. Communicate with you in relation to any queries/complaints with respect to your insurance policy.
c. Manage our internal business operations in relation to finance and accounting, billing, recovery and collection of debts, records management and auditing.
d. Perform any other type of contract with non-policy holders (e.g. insurance brokers/ agents, third party vendors etc.)
e. Make payments in relation to claims, premiums, invoices, etc.
f. Make collections in relation to your premiums
g. Identity verification during usual communication channels
2. Where we need to comply with a legal obligation.
a. Keep necessary data to comply with Tax, Anti-Money Laundering and Insurance Laws (including applicable laws outside your country of residence).
b. Comply with court orders.
c. Comply with requests from Supervisory Authorities
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
a. Direct Marketing
b. Records Management
c. Claim assessment, settlement and dispute resolution, with third party claimants (i.e. parties that are not insured with us and have a claim against our insured)
d. Improve the quality of our services, provide (for this purpose we record and monitor our phone calls)
e. Training for our insurance brokers/agents.
f. Establish, enforce and defend legal rights to protect our business operations.
g. Payment reminders when you are in arrears.
h. Identify, prevent and investigate fraud and other unlawful activities, unauthorised transactions, claims and other liabilities, and manage risk exposure and quality;
i. Safeguard the security of our people, premises and assets and prevent trespassing through video surveillance;
j. Manage our infrastructure, business operations and comply with internal policies and procedures;
k. Modify, personalise or otherwise improve our services/communications;
l. Defend, investigate or prosecute legal claims;
m. Receive professional advice (e.g. tax or legal advice);
n. Perform data analytics (such as market research, trend analysis, financial analysis and customer segmentation)
o. Enhance the security of our network and information systems
p. Register relevant legal charges over your assets in case you are classified as bad debtor
4. Where you provided your consent.
a. Direct Marketing
b. Where you provided sensitive personal information in order for us to provide insurance and other assistance services, including quotations, risk and claim assessment, credit control, and engage with you settlement negotiations and/or dispute resolution.
5. Where we need to process your personal data in order to protect your vital interests or those of another person.
a. We will only process your personal data on this basis in very rare circumstances, such as where you or a third person is physically or legally incapable of giving consent and only provided that your life, or a third person’s life, is in jeopardy.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you and for instance not able to satisfy your claim, or we may be prevented from complying with our legal obligations or otherwise not be able to enter into or carry out any contractual relationship with you.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
«Special categories» of particularly sensitive personal information require a higher level of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:
1. With your explicit written consent where you provided sensitive personal information in order for us to provide insurance and other assistance services, including quotations, risk and claim assessment, credit control, and engage with you settlement negotiations and/or dispute resolution.
2. We may process this type of information where it is needed in relation to any legal claims against us during civil or administrative court proceedings or during out-of court settlement negotiations.
3. Where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent.
4. For reasons of substantial public interest, such as investigating fraudulent claims and carrying out fraud.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.
In particular this is done:
1. When recruiting insurance intermediaries, in accordance with the relevant legislation
2. If this is necessary for a client assessment for insurance purposes
Our Marketing Department may use your personal information to communicate via direct marketing channels and update you about our services that we feel you may be interested. Our direct marketing channels involve: telephone calls, SMS, email, post or display advertising that you may see on our website, third party websites or social media.
In many occasions your prior consent, when requesting an insurance quotation from us or entering into an insurance related contract with us, will be requested in order to allow us to communicate with you in order to promote our services and send you offers that we think you might be interested in based on the information we hold about you. When consent is needed and obtained then in every direct marketing communication you will always be given the right to ‘opt out’ of receiving future direct marketing information via unsubscribe links in email or stop instructions in text messages or you may ‘opt-out’ by contacting us.
Moreover, and only with your consent we may share your personal information with our group companies or our third party partners for their own marketing purposes. In case you do not wish any longer for your personal information to be shared within our group or our business partners, you may ‘opt-out’ by contacting us.
Any unsubscribe, stop instructions and general ‘opt-outs’ will be handled within a reasonable time.
It must be noted that even if you ‘opt-out’ of receiving direct marketing communications from us, we may still communicate with you with information that is ancillary related to the insurance service we are providing to you.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are using automated decision-making in the following circumstances:
1. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights, in particular when we offer quotations or when you are in arrears with your obligations and our internal debt recovery system will send you warning letters.
2. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
In such cases, you have the right to contact us to:
(a) give you information about the processing of your personal data (please also below section in relation to your rights); and/or
(b) request that one of our employees examines your application and obtain an explanation for the automated decision reached. You also have the right to challenge such a decision. Following such a request, we will reassess your application, taking into consideration both the reasons that a particular automated decision was reached as well as your own point of view.
We may have to share your data with third parties, including third-party service providers and other entities in the group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EEA.
If we do, you can expect a similar degree of protection in respect of your personal information through contractual arrangements to observe confidentiality and data protection assuring they comply with data protection law and the GDPR.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the commercial relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
«Third parties» includes third-party service providers and other entities within our group.
The following third-party service providers process personal information about you so that we perform our obligations or if we are legally required to do so, or if we are authorized under our contractual and statutory obligations:
1. Road Assistance
2. Garages and Automobile Repair and Maintenance Stations
3. Car hire companies
4. Reinsurance companies/ reinsurance brokers that may reside outside the EEA
5. Insurance companies
6. Insurance agents/brokers and representatives
7. Foreign insurance agents
8. Risk surveyors/loss adjusters/valuators
9. Your legal representatives
10. Lawyers in Cyprus and abroad
11. Government Agencies & Bodies & Supervisory Authorities (e.g. Department of Road Transport, Police, Superintendent of Insurance)
12. Liaison officers (group medical policies)
13. Financial institutions
14. Doctors and other medical service providers
16. Intra group Nest IT team
17. Payment assistance providers (e.g. JCC)
18. File storage/archiving companies and record management companies and cloud storage companies
19. Credit Reference Agencies & Credit Bureaus
20. Motor Insurance Fund (MIF)
21. Cyprus Hire and Rejected Risks Pool
22. Accident care and assistance service providers (i.e. in relation to motor, home, travel, medical)
23. Data backup companies
24. Software Service providers we have chosen to support us in the effective provision of our products and services to you by offering technological expertise, solutions and support
How secure is my information with third-party service providers?
All our third-party service providers and all other third party entities, other than those which we are required under the law to disclose your personal information, are required to take appropriate security measures to protect your personal information in line with our policies and relevant contractual data sharing obligations. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions as per the GDPR.
When might you share my personal information with other entities in the group?
We will share your personal information with other entities in our group for:
1. Reinsurance purposes/arrangements
2. IT technical development
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
Transferring information outside the EU
We may transfer the personal information we collect about you to countries outside the EU in order to perform our contract with you, protect our legitimate interest or those of third parties and in particular share them with:
(a) Reinsurance companies / reinsurance brokers
(b) Foreign insurance companies/agents
(c) Foreign lawyers
(d) File storage/archiving companies and record management companies
(e) Accident care and assistance service providers (ie in relation to motor, home, travel, medical)
(f) Government Agencies & Bodies
(g) Risk surveyors/loss adjusters/valuators
(h) Doctors and other medical service providers
(i) Internal Group IT service providers
Where there is not an adequacy decision by the European Commission in respect meaning your personal information are not deemed to be provided with an adequate level of protection for your personal information, we ensure that your personal information does receive an adequate level of protection by putting in place appropriate measures such as Standard Contractual Clauses or Binding Corporate Rules in order to safeguard that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and Cyprus laws on data protection.
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where our contractual relationship is terminated we will retain your personal information until at least all related limitation periods are elapsed in order to safeguard our interests from any legal claims but we may keep them for a longer period if deemed necessary.
It is noted that when you provide any personal information for the purposes of obtaining an insurance policy quotation and a contract has not been concluded for any reason whatsoever then we will keep your personal information, other than contact information which will be used for the purposes of direct marketing and provided that we obtained your consent, for a period of 12 months after the collection of your data.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further data protection policy to you. Once you are no longer in a commercial relationship with us we will retain and securely destroy your personal information in accordance with our data retention policy.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Subject to certain legal conditions, you may have the right to:
- Request access to your personal information (commonly known as a «data subject access request»). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
It is noted that in accordance with the legislation in force, your right to apply for the erasure of your personal data or to object to the processing of your personal data by Trust Cyprus is not applicable or may be limited in the following instances where the processing of the data is carried out for the purpose of:
a) establishing, exercising or supporting legal claims, and
b) maintaining a legal obligation that necessitates the processing on the basis of Cypriot or European Law, to which Trust Cyprus is subject.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact email@example.com.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
RIGHT TO WITHDRAW CONSENT
In the circumstance where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. It is also noted that the processing based on the consent carried out prior to the withdrawal will remain lawful.
In some occasions withdrawing or not providing your consent will have an impact on us for continuing the performance of an insurance contract, in particular those insurance policies that require your disclosure of sensitive personal information (e.g. medical insurance policies), or the processing of your claim in case you are a third party claimant given that your consent may be inextricably linked with the provision of insurance services.
DATA PROTECTION OFFICER
We have appointed a data protection officer (DPO) to oversee compliance with this data protection policy. If you have any questions about this data protection policy or how we handle your personal information, please contact our DPO at email@example.com.
You have the right to make a complaint at any time to the Data Protection Commissioner’s Office, the Republic of Cyprus’ supervisory authority, for data protection issues.
1 Iasonos Street,
1082 Nicosia, Cyprus
Tel.: +357 22 818 456
Fax: +357 22 304565
CHANGES TO THIS DATA PROTECTION POLICY
We reserve the right to update this data protection policy at any time, and we will provide you with a new data protection policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this data protection policy, please contact our DPO.