This Privacy Policy sets out how FinSef processes personal information of clients and insureds and other businesses that we interact with and beneficiaries of insured products.

The kinds of personal information we collect and how that personal information is used is set out in this policy. Please read this privacy policy to understand our views and practices regarding personal information and how we will treat it.

What is personal information

Personal information is information relating to an identified or identifiable individual, who can be identified directly or indirectly, particularly by reference to an identification number, or to one or more factors specific to the individual’s physical, mental, physiological, economic, cultural or social identity.

It can also be an opinion about an identified individual, or an individual who is reasonably identifiable:

• whether the information or opinion is true or not; and
• whether the information or opinion is recorded in a material form or not.

What kinds of personal information do we collect and hold?

The personal information collected and maintained by FinSef generally includes your contact information, such as name, title, address, business and/or personal telephone number, date of birth, gender and information specific to the product or service you decide to purchase from us, as well as details of any property being insured, or other information needed for your specific dealings with FinSef.

For some policies, we also collect and maintain your sensitive information. This includes information about your health, genetics, physical and mental health condition, membership of any trade unions or professional associations and any criminal convictions you may have.

For employment applications, we collect your name, address, contact details, current and past employment information, educational qualifications and professional associations. We also collect information about and proof of your residency status, the name and contact details of your referees and other information required for recruitment purposes. Where we seek your consent to conduct a background check, we also collect details of your proof of identity from you.

In the recruitment process, we may ask you to answer optional questions about your personal attributes such as age, gender, ethnic background and language spoken. This personal (including sensitive) information is collected only for the purpose of understanding the diversity profile of applicants and employees and for internal reporting purposes within FinSef.

There are some circumstances where you can deal with us anonymously including, if you are only looking for general information about one of our products or services.

How do we collect your personal information?

We collect your personal information directly from you in person, in writing, over the telephone, by e-mail, through our online services and/or by electronic messages. In some circumstances, we may also collect it from:

• your agents or representatives, for example your legal advisers, your family member who applies for a policy that covers you or is instructed by you to deal with us;
• a co-insured on your policy;
• third parties who you have asked to provide your personal information to us including, your insurer and a financier with an interest in your insured property;
• our and our related entities’ agents, distributors and service providers and agents or subcontractors of any of those providers;
• other insurers;
• people who are involved in a claim or assist us in assessing, investigating, processing or settling claims, including another party involved in the claim or third parties claiming under your policy, witnesses, medical service providers or other professional experts, external claims data collectors and verifiers, and your employer;
• third parties who may be arranging insurance cover for a group that you are a part of;
• statutory authorities or government departments, for example, law enforcement, dispute resolution and/or Financial Complaints Authority;
• marketing organizations, including through the use of purchased lists;
• industry databases;
• publicly available sources such as the Internet and telephone directories; and/or
• the general public when it is unsolicited and may be relevant to a particular policy or fraud investigation.

Unless we are required or permitted by law to collect sensitive information about you, we will only do so by obtaining your consent.

If you nominate individuals to be covered by your insurance policy, you should direct them to this Privacy Policy and make them aware of the content of any privacy notice we provide you.

If you decide to complete an online form, the information that you enter into the online form will only be collected by us if and when you submit it. If at any stage you cancel your application prior to submitting your application, the information you have entered up to that point will be automatically deleted.

Website and other data tracking

We may collect information about your visit to our site to assist us to measure and improve our website. Examples of information that we collect include: day and time of your visit, whether you have visited our website previously, whether you used a search engine to find us and some geographical information about what country and state you are in.

We also use other external companies for the following purposes:

• for web hosting services for this website; and/or
• to gather non-personal information (using cookies) in order to evaluate the website’s effectiveness, for example online marketing activities.

Email

We retain the content and associated data of any email that you send to us if we believe we have a legal requirement to do so. Your email message content may be monitored by our employees for security issues, including where email abuse is suspected; our response to you may also be monitored for quality assurance issues.

For what purposes do we collect, hold and use your personal information?

We collect, hold and use your personal information for the purposes of providing our products and services and managing our business. This may include:

• to deal with enquiries;
• to provide a product or service including,
  • providing you with a quote;
  • considering your application;
  • arranging, verifying and administering insurance, assessing risks and underwriting insurance;
  • issuing, renewing or amending a policy;
  • pricing a policy, offering excesses and discounts;
• assessing, investigating, processing and settling claims, including managing workers compensation return to work programs;
• communicating details about our products and services or marketing our services and products and those of our related companies, representatives and business partners that may interest you;
• conducting customer research and analytics in relation to our service and products, improving our service and products, auditing and quality assurance;
• handling complaints and disputes;
• training our employees, agents and representatives;
• facilitating our business processes;
• conducting competitions, loyalty programs or surveys;
• detecting, investigating and preventing fraud;
• identifying and contacting individuals who do business with us;
• assessing and processing employment applications; and
• any other purpose communicated to you at the time we collected your personal information or as required or permitted by law.

Personal information (including sensitive information) collected for workers compensation claims will only be used in connection with the business of providing workers compensation claim services or for purposes required by workers compensation regulators or by law.

Direct marketing and your privacy

We may use your personal information to advise you about or offer you other products or services that may be relevant and of interest to you. Personal Information you or another party have provided us will be held on file for marketing purposes until you opt out of receiving such information. If you do not want to receive these offers from us (including product or service offerings from us and/or our business partners), please call the relevant customer service line in the ‘Contact Us’ section.

We may in some instances, disclose your personal information (but not sensitive information) to others we have business arrangements with to enable them to offer their products and services to you.

We do not use or disclose sensitive information for the purposes of direct marketing.

Personal information that is collected for workers compensation insurance will not be used or disclosed to others for direct marketing, customer or market research purpose unless it is required.

We do not disclose any personal information to any third parties except;

As reasonably necessary or appropriate in connection with one of the following:

• our distributors and agents;
• other insurers and reinsurers;
• credit reporting agencies;
• government, law enforcement, dispute resolution, statutory, regulatory or enforcement bodies and agencies;
• external data collection and verification agencies;
• loss adjusters and assessors;
• repairers and suppliers;
• investigators and recovery agents;
• medical and health service providers, case managers and rehabilitation consultants;
• our advisers (including legal, actuary and accounting advisers) and service providers, including data analytics, marketing organisations and debt collecting agents;
• your employer;
• parties that we have an insurance scheme in place with under which you purchased your policy, such as a financier or motor vehicle manufacturer or dealer;
• the agent and contractor of any of the third parties above;
• your co-insured to confirm full disclosure has been made to us; and/or
• other parties as required by law.

We may also disclose your personal information (but not sensitive information) to others we have business arrangements with to enable them to offer their products and services to you.

We will not disclose your sensitive information for any purpose, other than the purpose for which it was collected, or a directly related secondary purpose, unless you otherwise consent.

Certain laws also authorise or require us to collect, use and disclose your personal information. These laws include but are not limited to; The Data Protection Act 2018, The Financial Intelligence Act 2019,

How do we hold your personal information?

We may hold your personal information in a number of ways, including:

• in our secure computer systems or databases, which may involve storing data on storage or computer systems provided by third party suppliers;
• in paper records; and/or
• in telephone recordings (used for training and verification purposes).

Where it has been collected from our or your agent, or our service providers, they may also hold copies of your personal information.

We may combine personal information we receive about you with other information we hold about you. This includes information received from third parties and information collected for different products and services.

Contact us

Access to, and correction of, your personal information

FinSef claims to ensure that your personal information is accurate, up to date, complete and relevant. If you would like to access, or revise, your personal information, or feel that the information we currently have on record is incorrect or incomplete, please contact us using the following contact details:

Phone: +267 3164650 8am-5pm, Monday to Friday

Making a complaint

In the event of any complaint regarding any of the services we at FinSef provide, please fill out the form, under the heading ‘Contact us’ on our website, to lodge a complaint.