The Insurance Company of the West Indies Limited (“ICWI”) is part of the ICWI Group of Companies which operates through subsidiaries in various jurisdictions across the region. The ICWI Group of Companies and The Insurance Company of the West Indies Limited is committed to protecting your privacy as we value earning and keeping the trust of our customers, business partners and others who share their personal information with us.
a. What is personal data?
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. What are your rights
h. What are cookies
j. How to manage cookies
l. How to contact us
A. WHAT IS PERSONAL DATA
Throughout this policy you will see certain terms which are defined and have specific meanings in the context of this policy. These definitions are set out below:-
1. ‘Personal Data/Personal Information’– means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
2. ‘Data processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
3. ‘Data processor’ means a natural or legal person, which processes personal data on behalf of the 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:
d) Date of birth
e) E-mail address
f) Telephone number
g) Tax Payer Registration Number
C. WHEN AND HOW DO WE COLLECT PERSONAL DATA?
You directly provide ICWI with most of the data which 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 websites or applications
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 such as 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 the Company 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 analyse 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 to 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 that means ICWI does not intend to sell, rent, or otherwise give your e-mail address to a third-party, without your consent.
In addition, icwi.com 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.com staff, you will be required to provide specific information that will be routed to the appropriate contact within icwi.com.
E. DISCLOSURE TO THIRD PARTIES
ICWI may share your personal data with other insurance companies, the Police, relevant government agencies, bankers, reinsurers and 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 which provide certain specialised services to ICWI or who co-operate 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 which have been retained by ICWI to perform services on the Company’s behalf, either in relation to services performed for you or information which ICWI uses for its own purposes.
c) Personal information maybe 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 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, unauthorised alteration and destruction. ICWI will use technical and organisational 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 such third-party service providers acting as data processors for ICWI that have access to your personal data, to ensure that the level of security required 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 which is transferred from you or to you via the internet.
If at any time there has been a breach to our systems which compromises your personal data, ICWI will notify you within 72 hours of first becoming aware of the breach.
ICWI will keep your personal data for the period necessary to fulfil the purposes described in this policy unless a longer retention period is required by Law.
G. WHAT ARE YOUR RIGHTS
ICWI would like to make sure that you are aware of your rights in relation to your personal data. Each person is entitled to the following:-
a) The right to access– you may ask the Company to confirm whether or not we have and are using your personal information. You may also request copies of your personal data.
b) The right to withdraw consent– where ICWI has requested your consent to use personal information you have the right to withdraw that consent and may contact the Company using the information provided.
c) The right to request corrections– You may request that ICWI corrects any information you believe to be inaccurate or may request that the Company complete information which you believe is incomplete.
d) The right to request erasure– You have the right to request that ICWI erase your personal data under certain circumstances. ICWI may not always be able to comply with request, for example, if the Company needs to keep using your personal information in order to comply with its legal obligations or where we need to use it to establish, exercise or defend legal claims.
e) The right to restrict processing– You have the right to that ICWI restrict the processing of your personal data for example if you believe the information to be inaccurate or if the information is no longer required for the purposes for which it was collected or if you have exercised the right to object and verification of overriding grounds is pending.
g) The right to object to processing– You have the right to object to ICWI’s use of your personal information but please note that if you raise an objection the Company will have an opportunity to demonstrate that it has compelling legitimate interests which override your right herein.
h) The right to data portability– You have the right to request that ICWI transfer your personal data to you in a structured, machine readable format or you can request that it be transferred to another Company.
i) The right to decline Automated Decision Making– You have the right to not be subject to decisions based solely on automated decision making.
H. WHAT ARE COOKIES
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. When you visit ICWI’s website the Company may collect information from you automatically through cookies or similar technology. For example, we may monitor [how many times you visit, which pages you go to, traffic data, location data and the originating domain name of a user’s internet service provider].
From time to time we may provide your information to our customer service agencies for research and analysis purposes so that we can monitor and improve the services we offer.
J. HOW TO MANAGE COOKIES
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. Please note that in a few cases some features of the Company’s website may not function if you disable cookies.
L. HOW TO CONTACT US
If you wish to review further and more detailed information on consumer data rights you may visit www.gdpr.ruv.de.
If you have any questions about this policy, 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 email@example.com
Call us on 876-926-9040
Our registered office and mailing address is 2 St. Lucia Avenue, Kingston 5, Jamaica, W.I.