PRIVACY POLICY

If you have any questions about our use of your Personal Information you can e-mail: chartiskenya@chartisinsurance.com or write to the General Manager, Chartis Kenya Insurance Company Limited, P O Box 49460-00100, Nairobi, Kenya. Fax: + 254 20 375 1818  

Depending on your relationship with us (for example, as a consumer policyholder; non-policyholder insured or claimant; witness; commercial broker or appointed representative; or other person relating to our business), Personal Information collected about you and your dependants may include: 

• General identification and contact information 
  Your name; address; e-mail and telephone details; gender; marital status; family status; date of birth; passwords; educational background; physical attributes; activity records, such as driving records; photos; employment history, skills and experience; professional licenses and affiliations; relationship to the policyholder, insured or claimant; and date and cause of death, injury or disability.   
• Identification numbers issued by government bodies or agencies
  Social Security or national insurance number; passport number; tax identification number; military identification number; or driver’s or other license number.
• Financial information and account details
  Payment card number; bank account number and account details; credit history and credit score; assets; income; and other financial information.
• Medical condition and health status
  Current or former physical or mental or medical condition; health status; injury or disability information; medical procedures performed; personal habits (for example, smoking or consumption of alcohol); prescription information; and medical history.   
• Other sensitive information
  In certain cases, we may receive sensitive information about your trade union membership, religious beliefs, political opinions, family medical history or genetic information (for example, if you apply for insurance through a third-party marketing partner that is a trade, religious or political organization).  In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud.  We may also obtain sensitive information if you voluntarily provide it to us (for example, if you express preferences regarding medical treatment based on your religious beliefs).
• Telephone recordings
  Recordings of telephone calls to our representatives and call centers.
• Information to investigate crime, including fraud and money laundering
  For example, insurers commonly share information about their previous dealings with policyholders and claimants for this purpose
• Information enabling us to provide products and services
  Location and identification of property insured (for example, property address, vehicle license plate or identification number); travel plans; age categories of individuals you wish to insure; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organization; and other insurance you hold.
• Marketing preferences and customer feedback
  You may let us know your marketing preferences, enter a contest or prize draw or other sales promotion, or respond to a voluntary customer satisfaction survey.

We may use this Personal Information to:

• Communicate with you and others as part of our business.

• Send you important information regarding changes to our policies, other terms and conditions, the Site and other administrative information.

• Make decisions about whether to provide insurance; provide insurance and assistance services, including claim assessment, processing and settlement; and, where applicable, manage claim disputes.

• Assess your eligibility for payment plans, and process your premium and other payments.

• Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers).

• Prevent, detect and investigate crime, including fraud and money laundering, and analyze and manage other commercial risks.

• Carry out market research and analysis, including satisfaction surveys.

• Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed.

• Personalize your experience on the Site by presenting information and advertisements tailored to you.

• Identify you to anyone to whom you send messages through the Site.

• Allow you to participate in contests, prize draws and similar promotions, and to administer these activities.  Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these carefully.

• Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management.

• Resolve complaints, and handle requests for data access or correction.

• Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence).

• Establish and defend legal rights;protect our operations or those of any of our group companies or insurance business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.

Due to the global nature of our business, for the purposes set out above we may transfer Personal Information to parties located in other countries (including the United States and other countries that have a different data protection regime than is found in the country where you are based).  For example, we may transfer Personal Information in order to process international travel insurance claims and provide emergency medical assistance services when you are abroad.  We may transfer information internationally to our group companies, service providers, business partners and governmental or public authorities.

Chartis may make Personal Information available to:

• Our group companies
  For a list of Chartis group companies that may have access to and use of Personal Information, please refer to: http://www.aigcorporate.com/AIG_All_Entities.pdf.  CHARTIS Kenya Insurance Company Limited is responsible for the management and security of jointly used Personal Information.  Access to Personal Information within Chartis is restricted to those individuals who have a need to access the information for our business purposes.

• Other insurance and distribution parties
  In the course of marketing and providing insurance, and processing claims, Chartis may make Personal Information available to third parties such as other insurers; reinsurers; insurance and reinsurance brokers and other intermediaries and agents; appointed representatives; distributors; affinity marketing partners; and financial institutions, securities firms and other business partners.
• Our service providers
  External third-party service providers, such as medical professionals, accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; travel and medical assistance providers; call center service providers; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; banks and financial institutions that service our accounts; third-party claim administrators; document and records management providers; claim investigators and adjusters; construction consultants; engineers; examiners; jury consultants; translators; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
• Governmental authorities and third parties involved in court action
  Chartis may also share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.

• Other Third Parties
  We may share Personal Information with payees; emergency providers (fire, police and medical emergency services); retailers; medical networks, organizations and providers; travel carriers; credit bureaus; credit reporting agencies; and other people involved in an incident that is the subject of a claim; as well as purchasers and prospective purchasers or other parties in any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business, assets or stock. To check information provided, and to detect and prevent fraudulent claims, Personal Information (including details of injuries) may be put on registers of claims and shared with other insurers. We may search these registers when dealing with claims to detect, prevent and investigate fraud.
  

Personal Information may also be shared by you, on message boards, chat, profile pages and blogs, and other services on the Site to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public information, and may be available to visitors to the Site and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Site.

Chartis will take appropriate technical, physical, legal and organizational measures, which are consistent with applicable privacy and data security laws. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have with us has been compromised), please immediately notify us. (See the “Who to Contact About Your Personal Information” section above.)

When Chartis provides Personal Information to a service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the Personal Information.

Chartis takes reasonable steps to ensure that the Personal Information we process is reliable for its intended use, and as accurate and complete as is necessary to carry out the purposes described in this Privacy Policy. Chartis will retain Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

If you provide Personal Information to Chartis regarding other individuals, you agree: (a) to inform the individual about the content of this Privacy Policy; and (b) to obtain any legally-required consent for the collection, use, disclosure, and transfer (including cross-border transfer) of Personal Information about the individual in accordance with this Privacy Policy.

We will provide you with regular opportunities to tell us your marketing preferences, including in our communications to you. You can also contact us by e-mail at chartiskenya@chartisinsurance.com or by writing to: General Manager, Chartis Kenya Insurance Company Limited, P O Box 49460-00100, Nairobi, Kenya to tell us your marketing preferences and to opt-out.

If you no longer want to receive marketing-related e-mails from Chartis on a going-forward basis, you may opt-out of receiving these marketing-related emails by clicking on the link to “unsubscribe” provided in each e-mail or by contacting us at the above addresses.

• Receiving [mobile messages (for example SMS text messages) / telephone communications / postal mail] from us:  If you no longer want to receive mobile messages / telephone communications / postal mail from Chartis on a going-forward basis, you may opt-out of receiving these marketing-related communications by contacting us at the above addresses.
• Our sharing of your Personal Information with our group companies for their marketing purposes:  If you would prefer that we do not share your Personal Information on a going-forward basis with our group companies for their own marketing purposes, you may opt-out of this sharing by contacting us at the above addresses.
• Our sharing of your Personal Information with selected third-party partners for their marketing purposes:  If you would prefer that we do not share your Personal Information on a going-forward basis with our third-party partners for their own marketing purposes, you may opt-out of this sharing by contacting us at the above addresses.
  

We aim to comply with your opt-out request(s) within a reasonable time period.  Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the databases of third parties with whom we have already shared your Personal Information (i.e., to those to whom we have already provided your Personal Information as of the date on which we respond to your opt-out request).  Please also note that if you do opt-out of receiving marketing communications from us, we may still send you other important administrative communications from which you cannot opt-out.

In certain countries, an individual may have the right to access, correct, object to the use of, or request deletion or suppression of Personal Information on certain grounds.  Please contact us as set out in the “Who to Contact About Your Personal Information” section above with any such requests or if you have any questions or concerns about how we process Personal Information.  Please note that some Personal Information may be exempt from access, correction, objection, deletion or suppression rights in accordance with local privacy and data protection laws.

“Other Information” is any information that does not reveal your specific identity, such as:

• Browser information;

• Information collected through cookies, pixel tags and other technologies;

• Demographic information and other information provided by you; and

• Aggregated information
  

Other Information We Collect

We and our third-party service providers may collect Other Information in a variety of ways, including:   

• Through your internet browser:  Certain information is collected by most websites, such as your IP address (i.e., your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, internet browser type and version, time of the visit and the page(s) visited.  We use this information for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.

• Using cookies:  Cookies are pieces of information stored directly on the computer you are using.  Cookies allow us to recognize your computer and to collect information such as internet browser type, time spent on the Site, pages visited, language preferences, etc.  We may use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while visiting the Site, or to gather statistical information about the usage of the Site.  Cookies further allow us to present to you the advertisements or offers that are most likely to appeal to you.  We may also use cookies to track your responses to our advertisements and we may use cookies or other files to track your use of other websites.
  
  One of the advertisement companies that we use is Google, Inc, trading as DoubleClick.  To opt out from the DoubleClick advertisement cookie please visit: www.doubleclick.com/privacy/index.aspx.  You can refuse to accept other cookies we use by adjusting your browser settings.  However, if you do not accept these cookies, you may experience some inconvenience in your use of the Site and some online products.

• Using pixel tags, web beacons, clear GIFs or other similar technologies:  These may be used in connection with some Site pages and HTML-formatted e-mail messages to, among other things, track the actions of Site users and e-mail recipients, measure the success of our marketing campaigns and compile statistics about Site usage and response rates. 
  
  We use Adobe’s Omniture analytics service, which uses cookies and web beacons to help us understand more about how our website is used by consumers so we can continue to improve it.  Adobe does not have the right to use the information we provide to them beyond what is necessary to assist us. For more information on Adobe’s Omniture service, including how to Opt-Out, go to http://www.omniture.com/privacy/policy#optout.

• From you:  Some information (for example, your location or preferred means of communication) is collected when you voluntarily provide it.  Unless combined with Personal Information, this information does not personally identify you.

• By aggregating information:  We may aggregate and use certain information (for example, we may aggregate information to calculate the percentage of our users who have a particular telephone area code).

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, then, in addition to the uses listed in the “Other Information We Collect” section above, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which this Site contains a link.  The inclusion of a link on the Site does not imply endorsement of the linked site by us or by our group companies.

The Site is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Information through the Site.

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements.  We will place updates on our website.

Please take a look at the “LAST UPDATED” date at the bottom of this Privacy Policy to see when it was last revised.