Privacy
The Insurance Company of the West Indies Limited is part of the ICWI Group of Companies (“ICWI”, “Company”), which operates through subsidiaries in various jurisdictions across the region. ICWI respects your privacy and is committed to protecting your personal information as we value earning and keeping the trust of our customers, business partners, and others who share their personal information with us.
This Privacy Statement explains ICWI’s information processing practices. It applies to any personal information which you provide to ICWI directly or through ICWI and to any personal information which we may collect or receive from other sources. In this Privacy Statement, ICWI explains how it collects, uses, and protects your personal data and your privacy rights. This statement does not apply to your use of third-party sites which may be linked to this website.
This Privacy Statement covers the following topics:
a. Definitions
b. What Personal Data Do We Collect?
c. When And How Do We Collect Personal Data?
d. How Will We Use Your Personal Data?
e. Disclosure To Third Parties
f. How Do We Store Your Personal Data?
g. Your Privacy Rights
h. Cookies And Other Technologies
i. Managing Cookies And Other Technologies
j. Changes To Our Privacy Statement
k. How To Contact Us
A. DEFINITIONS
Several terms have been defined throughout this statement and have specific meanings in the context of this Privacy Statement. These terms are outlined below:
1. ‘Personal Data/Personal Information’ means information (however stored) relating to (i) a living individual or (ii) an individual who has been deceased for less than thirty years, who can be identified from that information alone or from that information and other information in the possession of, or likely to come into the possession of, the data controller; and (b) includes any expression of opinion about that individual and any indication of the intentions of the data controller or any other person in respect of that individual;
2. ‘Data processing’ means obtaining, recording, or storing the information or personal data, or carrying out any operation or set of operations (whether or not by automated means) on the information or data, including— (a) organization, adaptation, or alteration of the information or data; (b) retrieving, consulting or using the information or data; (c) disclosing the information or data by transmitting, disseminating or otherwise making it available; or (d) aligning, combining, blocking, erasing or destroying the information or data, or rendering the data anonymous;
3. ‘Data processor’ means, in relation to personal data, any person other than an employee of the data controller, who processes personal data on behalf of the data controller.
4. ‘Data controller’ means any person or public authority, who, either alone or jointly or in common with other persons determines the purposes for which and the manner in which any personal data are, or are to be, processed, and where personal data is processed only for purposes for which they are required under any enactment to be processed, the person on whom the obligation to process the personal data is imposed by or under that enactment is for the purposes of this Act a data controller.
B. WHAT PERSONAL DATA DO WE COLLECT?
ICWI asks that you provide certain personal data in order for us to best serve your needs as our customer. When you register with ICWI or on icwi.com, ICWI typically requests that you provide us with the following information:
a) Name
b) Address
c) Occupation
d) Date of Birth
e) E-mail Address
f) Telephone Number(s)
g) Taxpayer Registration Number (TRN)
Please note, that this list is not comprehensive, as additional data elements may be required in order for ICWI to process your inquiry or claim.
C. WHEN AND HOW DO WE COLLECT PERSONAL DATA?
You directly provide ICWI with most of the data that it collects. ICWI collects and processes data when you:
a) request a service from us (for example, an insurance quote)
b) register with, or use our website(s) or application(s)
c) contact us with a complaint or query
d) make contact with us via social media
ICWI may also receive your data from shared sources, including, but not limited to, Tax Administration Jamaica and Claims Bank.
D. HOW WILL WE USE YOUR PERSONAL DATA?
ICWI uses personal information to deliver services to clients. The gathering of personal data allows ICWI to process your application, facilitate issuing your policies, and process any renewals you may request. The relevant information is then used by us, our agents, and sub-contractors to provide you with your policy documents and information, statements of your account, and to communicate with you on any matter relating to the conduct of your account and the provision of the service in general.
ICWI also uses personal data for its own purposes. When ICWI uses personal data for its own purposes it uses it to analyze and improve how it delivers its services to clients and to market to them. For this purpose, ICWI may use your e-mail address or mailing address in order to conduct a survey or add you to our mailing list, or by your request to have someone contact you for additional information. Whenever we request the identity of a visitor, ICWI will clearly indicate the purpose of the inquiry before the information is requested. ICWI maintains a strict “No Spam” policy which means ICWI will not sell, rent, or otherwise give your e-mail address to a third-party, without your consent.
In addition, ICWI will not send you e-mails that you have not agreed to receive. If you are a member of our Mailing List, you will be contacted with announcements and news. You have the option of “Unsubscribing” from our Mailing List at any time, thereby disabling any further such e-mail communication from being sent to you. If you wish to have specific communications with a member of the ICWI staff, you will be required to provide specific information that will be routed to the appropriate contact within ICWI.
E. DISCLOSURE TO THIRD PARTIES
ICWI may share your personal data with other insurance companies, law enforcement, relevant government agencies, bankers, reinsurers and/or other entities in the course of providing services to you. ICWI will not share your information with third parties except in the following circumstances:
a) Personal information may be shared with entities that provide certain specialized services to ICWI or who cooperate with us on projects. These entities are responsible for their own compliance with data protection laws. Examples include banking institutions, insurance intermediaries, reinsurers, loss adjusters, investigators, lawyers, and those involved in the claims handling process.
b) Personal Information may also be shared with service providers that have been retained by ICWI to perform services on the Company’s behalf, either in relation to services performed for you or information that ICWI uses for its own purposes.
c) Personal information may be disclosed if ICWI is required to do so by law, legal process, statute, rule or regulation or in connection with an investigation of suspected or actual illegal or if the Company believes disclosure is necessary or appropriate to prevent physical harm or financial loss.
d) Disclosure may also be required in the course of audits of the Company.
ICWI does not rent, sell, or otherwise disclose personal data to unaffiliated third parties for their own marketing use.
F. HOW DO WE STORE YOUR PERSONAL DATA?
The security of your personal information is important to ICWI and as such the Company has put in place reasonable physical, technical, and administrative security standards to protect your information from loss, misuse, unauthorized alteration, and destruction. ICWI will use technical and organizational measures to safeguard your personal data, for example:
– Only authorized ICWI employees, and authorized employees of our third-party service providers’ processing data on our behalf, have access to your personal data.
– All ICWI employees who have access to your personal data are required to adhere to the ICWI Acceptable Use Policy and all contractors who have access to your personal data are requested by ICWI to sign non-disclosure agreements.
In addition, contracts are in place with any third-party service providers processing personal data on behalf of ICWI, to ensure an adequate level of security is in place, and that your personal data is processed only as instructed by ICWI.
Whilst we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the Internet is not entirely secure and for this reason, we cannot guarantee the security or integrity of any personal data that is transferred from you or to you via the internet.
If at any time there is a breach to our systems that compromises your personal data, ICWI will notify you within 72 hours of first becoming aware of the personal data breach.
ICWI will keep your personal data for the period necessary to fulfill the purposes described in this statement unless a longer retention period is required by law.
G. YOUR PRIVACY RIGHTS
There are a variety of data protection laws around the globe that provide privacy rights to you. Subject to applicable laws, you may have the following rights:
● Delete: Right to delete or erasure (“right to be forgotten”) of personal data we have collected from or about you;
● Access: Right to know and access the personal data we have collected about you, as well as other information about our data processing practices;
● Rectify: Right to rectify, correct, update, or complement inaccurate or incomplete personal data we have about you;
● Restrict: Right to restrict the way we process your personal data;
● Withdraw Consent: Right to withdraw your consent to process your personal data;
● Object: Right to object to our processing of your personal data based on legitimate interest;
● Object to Automated Individual Decision-Making: Right to object to our processing of your personal data in automated individual decision-making;
● Equal Service: Right not to receive discriminatory treatment for the exercise of your privacy rights, subject to certain limitations;
● Opt-Out: Right to Opt-Out of the sale of personal data, or the Right to Opt-Out of sharing of personal data for cross contextual advertising. U.S. residents can opt out of personalized advertising as set forth here: Do Not Sell or Share My Personal Information. U.S. residents can also turn on the Global Privacy Control (GPC) to opt out of the sharing of your personal information for cross contextual advertising. Learn more at the Global Privacy Control website (https://globalprivacycontrol.org/). You may have the right to opt out of the processing of your personal data for certain types of profiling in furtherance of decisions that produce legal or similarly significant effects. Please note that ICWI does not engage in such profiling.
● Portability of Personal Data: Right to obtain a portable copy of your personal data; and
● Lodge a Complaint: Right to lodge a complaint with a supervisory authority if you are not satisfied with the way we have handled your personal data, or any privacy request, or
other request that you have raised with us.
To exercise any of your rights, or to raise any other questions, concerns, or complaints about our privacy practices, or about our use of your personal data and its privacy, or if you are not a customer of ours and want to know what personal data we have about you, please contact us as explained below (“How to Contact Us”). You may appeal any decision with regard to your privacy request by using the details provided in the “How to Contact Us” section.
Once we receive your request, we will verify your identity and your authorization to take the actions requested, authenticating your identity at a level appropriate to the requested action. We require you to re-authenticate before we will disclose or delete personal data. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent.
Please note that there are exceptions and limitations to each of these rights and that while any changes will be reflected in active user databases instantly or within a reasonable period of time, we may retain personal data for backups, archiving, prevention of fraud, and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so, to the extent permitted by applicable law.
We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on a service may change or no longer be available to you where the processing of certain data is essential to the use of the service or feature.
H. COOKIES AND OTHER TECHNOLOGIES
Like many other websites, our site may use “Cookies” or “Other Technologies” (such as “pixel tags,” “web beacons,” “clear GIFs,” links in emails, JavaScript, device IDs assigned by Google or Apple, or similar technologies). Cookies and Other Technologies allow us and third parties to obtain information about your visits to the site, including analyzing your visiting patterns. We use this information to process your applications or requests and to deliver online and mobile advertisements, messages, and content for us and others that are specific to your interests. The information we obtain from our use of cookies will not usually contain your Personal Data. Although we may obtain information about your computer or other electronic device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally. [In certain circumstances we may collect personal information about you but only where you voluntarily provide it (e.g. by completing an online form)]. Cookies are small text files that are stored on your computer or mobile device (“device”) when you visit a website. Cookies alone cannot be used to disclose your individual identity to us, though in some cases we may tie ICWI or third-party Cookies to personal information you have provided to us or that we have otherwise obtained about you. Cookies may be used on the site in order to improve your experience. For example, we will use Cookies to:
● Remember your username and password for future visits so that log-in is easier and faster;
● Remember your language and other preferences;
● Ensure you obtain all requested information;
● Provide a safe and secure service for online transactions;
● Track your response to advertisements and website or app content for analysis and the number of times we send you the same advertisement; Measure how many people use the site, and how they use it so that we may keep it running quickly and efficiently; and
● Help us and others deliver communications and content to you that are relevant and responsive to your interests and location.
Below we explain the different types of Cookies that may be used on the site.
● Essential Cookies – Essential Cookies are necessary for the site to work, and enable you to move around it and use its services and features. Disabling these Cookies may make the services and features unavailable.
● Functional Cookies – We use Functional Cookies to save your settings on the site – settings such as your language preference, or other preference information you have previously used when visiting the ICWI site. Some Functional Cookies are essential to view certain content on our site (videos, animations, etc.).
● Session Cookies – These types of Cookies are stored temporarily during a browsing session, and are deleted from your device when you close the browser. We use Session Cookies to support the functionality of the site and to understand your use of the site—that is, which pages you visit, which links you use and how long you stay on each page.
● Persistent Cookies – These types of Cookies are not deleted when you close your browser but are saved on your device for a fixed period of time or until you delete them. Each time you visit the site, the server that set the Cookie will recognize the persistent Cookie saved on your device. We and others use persistent Cookies to store your preferences, so that they are available for your next visit, to keep a more accurate account of how often you visit the site, how often you return, how your use of the site may vary over time and the effectiveness of advertising efforts.
● Advertising Cookies – These cookies allow us and other advertisers to show you the most relevant products, offers, and advertisements on the site and third-party sites, or through emails or other message platforms. For example, some Advertising Cookies help our service providers and other advertisers select advertisements that are based on your interests, including those expressed or inferred by visits to our websites or apps or across other websites, online services, and apps over time. Others help prevent the same advertisement from continuously reappearing for you. These types of Cookies also help us provide you with content on the site that is tailored to your interests and needs. As noted below, some Analytics Cookies and Other Technologies are used in part to facilitate advertising.
● Social Media Cookies – Advertising Cookies also include Social Media Cookies. Social Media Cookies are used to share content from the site with members and non-members of social media networks such as Facebook, Twitter, YouTube and Pinterest. These Cookies are usually set by the social networking provider, enabling such sharing to be smooth and seamless.
● Analytics Cookies – Collect information about your use of the site and enable us to improve the way it works. These Cookies give us aggregated information that we use to monitor site performance, count page visits, spot technical errors, see how users reach the site, and measure the effectiveness of advertising (including emails we send to you).
● Other technologies may be used for the same purposes as our Cookies, to allow us and third parties to know when you visit the site, and to understand how you interact with emails or advertisements. Through Other Technologies, non-personal information (e.g., your operating system, your browser version, and the URL you came from) or aggregate information may be obtained and used to enhance your experience and understand traffic patterns.
I. MANAGING COOKIES AND OTHER TECHNOLOGIES
If you want to remove or block Cookies from your device at any time, you can update your browser settings (consult your browser’s “help” menu to learn how to remove or block Cookies). ICWI is not responsible for your browser settings. You can find instructions on how to manage Cookies on the different types of web browsers at www.allaboutcookies.org.
You can control what cookies you allow via your web browser’s settings.
Please be aware that rejecting Cookies may affect your ability to perform certain transactions on the Site, and our ability to recognize your browser from one visit to the next.
J. CHANGES TO OUR PRIVACY STATEMENT
We may modify this Privacy Statement from time to time. When we make material changes to this Privacy Statement we will post a link to the revised Privacy Statement on the homepage of our site. You can tell when this Statement was last updated by looking at the date at the top of the Statement. Any changes to the ICWI Privacy Statement will become effective upon posting of the revised Statement on the site. Use of the site, any of our products and services, and/or providing consent to the updated Statement following such changes constitutes your acceptance of the revised Statement then in effect.
K. HOW TO CONTACT US
If you have any questions about this statement, the data we hold on you or you would like to exercise any of your data protection rights as outlined in this policy please do not hesitate to contact us at:
Email to dpo@icwi.com
WhatsApp us at 876-997-3699
Our registered office and mailing address is 2 St. Lucia Avenue, Kingston 5, Jamaica.
