22 February 2024

Privacy Policy

Data Privacy Statement

At Britam, we are committed to protecting the privacy of your personal information. This Privacy Statement describes how Britam Holdings PLC protects personal data it processes, why and how we collect and use your personal data and how you can exercise your rights in relation to the processing of your personal data.

The Privacy Statement is issued on behalf of the Britam Holdings Plc and its subsidiary companies. When we mention “Britam”, “we”, “us” or “our” we are referring to the relevant company in the Britam Group that processes your personal information.

This privacy statement should be read together with the Terms and Conditions of Use for other Britam products and services.

This statement applies to all customers, suppliers, agents, merchants, dealers and all visitors frequenting any of Britam premises.

Please note:

Before providing us with Personal Information about another individual you must (unless we agree otherwise): (a) inform the individual about the content of this Privacy Policy and any other applicable privacy notices provided to you; and (b) obtain their permission (where possible) to share their Personal Information with us in accordance with this Privacy Policy and other applicable privacy notices.

Who is responsible for Personal Information?

Personal information is collected by each member of the Britam group who is responsible for its processing in their capacity as a controller. A full list of our group entities is available here.

Each Britam Holdings PLC company that processes your Personal Information is responsible for looking after it in accordance with this Privacy Policy, our internal standards and procedures, and the requirements of data protection law.

Your relationship with us will determine which of our group companies has access to and processes your Personal Information, and which of our group companies are the data controller(s) and or processor responsible for your Personal Information. Usually, if you are an individual policyholder, the Briam Holdings Plc company that underwrites your insurance policy will be the main company responsible for your Personal Information, the controller and or processor. Depending on our relationship with you, we will provide further information in a supplemental privacy notice tailored to our relationship.

For more precise information about the specific company or companies in the Britam Holdings Plc group that have access to and are responsible for your Personal Information (including the identity of the relevant Britam Holdings Plc companies that are the data controller(s) for your Personal Information), please contact us using the details provided below (see section below ‘Who to contact about your Personal Information?’).

We may also share your information with third parties (see section below 'Who is Personal Information shared with?'). Those third parties will assume certain responsibilities under data protection law for looking after the Personal Information that they receive from us.

What Personal Information do we collect and hold?

The personal information we collect varies depending upon the nature of our services. This Statement provides an overview of the categories of personal information we collect and the purposes for which we use it.

The information we collect about you may include the following (please note that this list is not exhaustive):

1. Contact information	Name, email address, postal address, physical address, residential address and telephone number.
2. General information	Gender, marital and family status, date of birth, and physical characteristics (appropriate to the circumstances).
3. Occupation/Vocation and employment information	Your vocation, employer details, employment status (such as full/part time, contract), salary information, employment benefits, and employment history.
4. Insurance and claim information	Information relevant to your insurance policy or relevant to your claim or your involvement in the matter giving rise to a claim.
5. Government and other official identification numbers	National Identity card number, passport number, tax identification number, driver’s licence number, or other government issued identification number.
6. Financial information and account details	Payment card number (credit or debit card), bank account details, mobile money statements, income, credit history, credit worthiness, bank statements, details about payments to or from you and other details of products and services you have purchased from us.
7. Medical condition and health status	Current or previous physical, mental or medical condition, health status, injury or disability information, medical diagnosis, medical procedures performed and treatment given, personal habits (for example, smoking or consumption of alcohol), prescription information, and medical history.
8. Other sensitive information	Information about religious beliefs, ethnicity, political opinions or trade union membership (for example, if an insurance application is made through a third party marketing partner that is a professional, trade, religious, community or political organization). We may obtain information about criminal records or civil litigation history (for example, for preventing, detecting and investigating fraud). Information provided voluntarily to us (for example, preferences expressed regarding medical treatment based on religious beliefs) (where collected in accordance with applicable law).
9. Telephone recordings	Recordings of telephone calls with our representatives and call centres.
10. Photographs and video recordings	Images (including photographs and pictures) or video recordings created in connection with our insurance or other business activities, including for claims assessment, administration and settlement, claim disputes, or for other relevant purposes as permitted by law, as well as CCTV recordings captured by equipment on our premises.
11. Information to detect, investigate or prevent crime, including fraud and money laundering	Insurers commonly collect, hold and share information about their previous dealings with policyholders and claimants with the intention of the detection, investigation and prevention of fraud, money laundering and other criminal activities.
12. Information enabling us to provide products and services	Location and identification of property insured (for example, property address, vehicle licence plate or identification number), travel plans, age categories of individuals to be insured, details of the risks to be insured, prior accident or loss history, and cause of loss, status as company officer or director, or partner, or other ownership or management interest in an organisation, history of disputes, civil or criminal proceedings or formal investigations involving you, and information about other insurance held.
13. Marketing preferences, marketing activities and customer feedback	Marketing preferences, information relating to competition, prize draw or other promotion entry, or responses to voluntary customer satisfaction surveys. To improve our marketing communications, we may collect information about interaction with, and responses to, our marketing communications.
14. Online activity information	We will receive Personal Information about you when you use Britam Digital Services; this may include your social media account identifier and profile picture, your IP address and other online identifiers (to the extent that they are Personal Information), and other Personal Information that you provide to us online. If you choose to connect your social media account provided by another social media service provider to your account on any of the Britam Digital Services, Personal Information from your other social media account may be shared with us, which may include Personal Information that is part of your social media account profile, or the profiles of your friends and other connected individuals.
15. Supplemental information from other sources	We and our service providers may supplement the Personal Information we collect with information obtained from other sources (for example, publicly available information from online social media services and other information resources, third party commercial information sources, and information from our group companies and business partners). We will use any such supplemental information in accordance with applicable law (including obtaining your consent where required).

How do we collect your information?

Britam collects personal information in the following ways:

Information you provide to us

Britam collects information directly from you when you:

Apply for a product or service from us;
Interact with our website or attend a Britam event;
Apply for a position at Britam;
Contact us with a complaint or query;
Engage with us over social media; or
Register with or use any of our websites or applications.
When you visit any of our premises.

You are required to provide any personal information we reasonably require (in a form acceptable to us) to meet our obligations in connection with the services we provide to you, including any legal and regulatory obligations. Where you fail to provide or delay in providing information we reasonably require to fulfill these obligations, we may be unable to offer the services to you and/or we may terminate the services provided with immediate effect.

Where you provide personal information to Britam about third-party individuals (e.g., information about your spouse, civil partner, child(ren), dependents or emergency contacts), where appropriate, you should provide these individuals with a copy of this Statement beforehand or ensure they are otherwise made aware of how their information will be used by Britam.

Where you provide information to us about your beneficiaries we may require you to provide explicit consent on their behalf.

Information we automatically collect

In some instances, we automatically collect certain types of information when you visit our websites and through e-mails that we may exchange. Automated technologies may include the use of web server logs to collect IP addresses, "cookies" and web beacons.

Further information about our use of cookies can be found in our Cookie Notice and Cookie Preference Center at the footer of our page (where applicable).

Information we collect from clients or third parties

When we provide the services to our clients, we may collect personal information from our clients about you, such as your name, contact details, date of birth, gender, marital status, financial details, employment details, and benefit coverage. We may also collect (in each case as strictly relevant to the services we provide) sensitive information about you, such as health information in relation to life, health, professional liability and workers compensation insurance or employee benefit programs sponsored by your employer. Most of the personal information we receive relates to your participation in the compensation and benefits programs offered by your employer. Where permitted by national law, and appropriate to do so, we may collect criminal records information; for example, where required as part of our business acceptance, finance, administration, recruitment, anti-money laundering and sanctions screening processes.

How do we use Personal Information?

We use Personal Information to carry out our business activities. The purposes for which we use your Personal Information will differ based on our relationship, including the type of communications between us and the services we provide. Personal Information will be used for different purposes if you are a policyholder, insured or claimant under an insurance policy, an insurance broker or appointed representative, a witness or another individual with whom we have a relationship.

The main purposes for which we use Personal Information are to:

Communicate with you and other individuals.
Make assessments and decisions (automated and non-automated, including by profiling individuals) about: (i) the provision and terms of insurance and (ii) settlement of claims and provision of assistance and other services.
Provide our products and services and fulfil our contractual obligations to clients and other third parties.
Assess your eligibility for payment plans, and process your premium and other payments.
Improve the quality of our products and services, provide staff training and maintain information security (for example, for this purpose we may record or monitor phone calls).
Fulfilling legal or regulatory obligations and protecting ourselves and our clients against fraud, money laundering, terrorism and other crimes.
Carry out research and data analysis, including analysis of our customer base and other individuals whose Personal Information we collect, complete market research, including customer satisfaction surveys, and assess the risks faced by our business, in accordance with applicable law (including obtaining consent where required).
Provide marketing information in accordance with preferences you have told us about (marketing information may be about products and services offered by our third party partners subject to your expressed preferences). We may carry out marketing activities in accordance with your preferences by using email, SMS and other text messaging, post or telephone.
Allow you to participate in competitions, prize draws and similar promotions, and to administer these activities. These activities have additional terms and conditions, which will contain more information about how we use and disclose your Personal Information where this is useful to provide you with a full picture of how we collect and use Personal Information, so we recommend that you review those too.
Personalise your experience when you use Britam Digital Services or visit third party websites by presenting information and advertisements tailored to you, identify you to anyone to whom you send messages through the Britam Digital Services, and facilitate sharing on social media.
Manage our business operations and IT infrastructure, in line with our internal policies and procedures, including those relating to finance and accounting; billing and collections; IT systems operation; data and website hosting; data analytics; business continuity; records management; document and print management; and auditing.
Manage complaints, feedback and queries, and handle requests for data access or correction, or the exercise of other rights relating to Personal Information.
Comply with applicable laws and regulatory obligations (including laws and regulations outside your country of residence), for example, laws and regulations relating to anti-money laundering, sanctions and anti-terrorism; comply with legal process and court orders; and respond to requests from public and government authorities (including those outside your country of residence).
Establish, enforce and defend legal rights to protect our business operations, and those of our group companies or business partners, and secure our rights, privacy, safety or property, and that of our group companies or business partners, you, or other individuals or third parties; to enforce our terms and conditions; and pursue available remedies and limit our damages.

Are automated decisions made using Personal Information?

Where you apply or register to receive a product or service we may carry out a real-time automated assessment to determine whether you are eligible to receive the service.

An automated assessment is an assessment carried out automatically using technological means (e.g., computer systems) without human involvement. This assessment will analyse your personal information and comprise several checks, e.g., credit history and bankruptcy check, validation of your identification and motoring convictions, validation of your previous claims history and other fraud prevention checks. Where your application to receive, the service does not appear to meet the eligible criteria, it may be automatically refused, and you will receive notification of this during the application process.

However, where a decision is taken solely by automated means involving the use of your personal information, you have the right to challenge the decision and ask us to reconsider the matter, with human intervention. If you wish to exercise this right, you should contact us.

Who is Personal Information shared with?

Our employees have access to and process personal data based upon the "need to know" principle. In other words, they have access to personal data where this is necessary in order to do their job.

In connection with the purposes described above (see section above 'How do we use Personal Information?'), we sometimes need to share your Personal Information with third parties (this can involve third parties disclosing Personal Information to us and us disclosing Personal Information to them).

These third parties may include:

Type of third party	Examples
Our group companies	Britam Holdings Plc has subsidiary companies throughout the Africa. We may share your Personal Information with other group companies (including for administrative accounting purposes).
Other insurance and insurance distribution parties	Where permitted by applicable law, Britam may share Personal Information with other third parties, for example, other insurers, reinsurers, insurance and reinsurance brokers, other intermediaries and agents, affinity marketing partners and financial institutions and other business partners.
Our service providers	External third party service providers, such as medical and accountants, actuaries, auditors, Trustees, Custodians, Fund administrators, experts, lawyers and other professional advisors; travel and medical assistance providers; call centre service providers; IT systems, support and hosting service providers; printing, advertising, marketing and market research, and data analysis service providers; banks, credit reference bureaus and financial institutions that service our accounts; third party claim administrators; document and records management providers; claim investigators and adjusters; construction consultants; engineers; examiners; translators; and other third party vendors and outsourced service providers that assist us in carrying out business activities.
Government authorities and third parties involved in legal proceedings	We may also share Personal Information with: (a) government or other public authorities (including, but not limited to courts, regulatory bodies, law enforcement agencies, tax authorities and criminal investigations agencies); and (b) third party participants in legal proceedings and their accountants, auditors, lawyers, and other advisors and representatives, as we believe to be necessary or appropriate.
Other third parties	We may share Personal Information with payees; emergency providers (police and medical emergency services); retailers; medical networks, organisations and providers; travel carriers; credit bureaus; 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 reorganisation, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our businesses, assets, companies or company shares. Where permitted by applicable law, 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 prevent, detect and investigate fraud. If you benefit from another party’s insurance policy or service arrangement with Britam (for example, a policy taken out by your employer), Personal Information relating to the administration of that insurance policy or service may be shared with that other party.

Personal Information may also be shared by you on message boards, chat, profile pages and blogs, and other Britam Digital Services to which you are able to post information and materials (including, without limitation, our Social Media Content). Please note that any information you post or disclose through these services will become public information, and may be available to visitors and users of the Britam Digital Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, when using Britam Digital Services.

Where do we process Personal Information?

From time to time, we may need to transfer your personal information outside the country.

When making these transfers, we will take steps to ensure that your Personal Information is adequately protected and transferred in accordance with the requirements of data protection law.

For further information about these transfers and to request details of the safeguards in place, please contact us using the details below (see section below ‘Who to contact about your Personal Information?’).

How do we keep Personal Information secure?

Britam uses appropriate technical, physical, legal and organisational measures, which comply with data protection laws to keep Personal Information secure.

As most of the Personal Information we hold is stored electronically we have implemented appropriate IT security measures to ensure this Personal Information is kept secure. For example, we may use anti-virus protection systems, firewalls, and data encryption technologies. We have procedures in place at our premises to keep any hard copy records physically secure. We also train our staff regularly on data protection and information security.

When Britam engages a third party (including our service providers) to collect or otherwise process Personal Information on our behalf, the third party will be selected carefully and required to use appropriate security measures to protect the confidentiality and security of Personal Information.

Unfortunately, no data transmission over the Internet or electronic 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 sent to us has been compromised), please immediately notify us (see section below ‘Who to contact about your Personal Information?’).

What is the legal justification for our use of Personal Information?

We will process your personal information based on any of the lawful basis provided for under the Data Protection Law:

The performance of a Product/Service Agreement with you;
Britam’s legitimate business interests;
Compliance with a mandatory legal obligation;
Consent you provide;
Public interest;
Your vital interest.

Sensitive Special Categories of Personal Information

For more sensitive special categories of Personal Information we will rely on either:

Your consent; or
One or more of the other legal justifications set out above and typically one of the following two additional justifications (however other legal justifications may be available):

The use is necessary for the establishment, exercise or defence of legal claims, or whenever courts are acting in their judicial capacity (for example, when a court issues a court order requiring the processing of Personal Information); or
The use is necessary for the purposes of preventive or occupational medicine, medical diagnosis or the provision of health or social care or treatment.

These more sensitive special categories of Personal Information include Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning an individual’s sex life or sexual orientation.

Additional legal justifications may also be available in the country in which you are based and we may also rely on these justifications from time to time.

Processing of Personal Information relating to criminal convictions and offences is subject to the requirements of applicable law.

Do we record calls and monitor email communications with us?

We may record telephone calls with you so that we can:

Improve the standard of service that we provide by providing our staff with feedback and training;
Address queries, concerns or complaints;
Prevent, detect and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks; and
Comply with our legal and regulatory obligations.

In addition, we monitor electronic communications between us (for example, emails) to protect you, our business and IT infrastructure, and third parties including by:

Identifying and dealing with inappropriate communications; and
Looking for and removing any viruses, or other malware, and resolving any other information security issues.

How long do we keep Personal Information for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, the need to comply with our internal policy and the applicable legal, regulatory, tax, accounting or other requirements.

Anonymized information that can no longer be associated with you may be held indefinitely.

We will keep Personal Information for as long as is necessary for the purposes for which we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the purpose for which we hold your information, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the need to comply with our internal policy and the applicable legal, regulatory, tax, accounting or other requirements.

For further information about the period of time for which we retain your Personal Information, please contact us using the details below (see section below ‘Who to contact about your Personal Information?’).

How can you tell us about your marketing preferences?

We will provide you with regular opportunities to tell us your marketing preferences, including in our communications to you.

To tell us your marketing preferences, and to change your preferences if required, you can contact us by email at: customerservice@britam.com or by writing to: The Office of the Director, Customer Experience, Brand & Marketing, Britam Holdings Plc.

In addition, you can also opt-out of receiving marketing communications as follows:

Receiving email messages and text messages from us: If you no longer want to receive marketing emails or text messages from Britam, you can opt-out of receiving these marketing-related messages by clicking on the link to “unsubscribe” provided in each email message, following the stop instructions in a text message, or by contacting us using the addresses above.
Receiving telephone communications and postal mail from us: If you no longer want to receive marketing via telephone communications or postal mail from Britam, you may opt-out of receiving these marketing communications by contacting us using the addresses above.
Sharing of your Personal Information with our group companies for their marketing purposes: With your consent we may share your Personal Information with our group companies for their own marketing purposes. If you change your mind, you may opt-out of this sharing by contacting us using the addresses above.
Sharing of your Personal Information with selected third party partners for their marketing purposes: If you have provided your consent we may share your Personal Information with our third party partners for their own marketing purposes. If you change your mind, you may opt-out of this sharing by contacting us using the addresses above.

We aim to comply with your opt-out requests within a reasonable time period and in any event within any period prescribed by law. 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 service and administration communications relating to the services which we provide to you, and you cannot opt-out from these service and administration communications.

What are your Personal Information rights?

The following is a summary of the data protection rights available to individuals in connection with their Personal Information. These rights may only apply in certain circumstances and are subject to certain legal exemptions.

Subject to legal and contractual exceptions, you have rights under data protection laws in relation to your personal data. These are listed below: -

Right to be informed that we are collecting personal data about you;
Right to access personal data that we hold about you and request for information about how we process it;
Right to request that we correct your personal data where it is inaccurate or incomplete;
Right to request that we erase your personal data noting that we may continue to retain your information if obligated by the law or entitled to do so;
Right to object and withdraw your consent to processing of your personal data. We may continue to process if we have a legitimate or legal reason to do so;
Right to request restricted processing of your personal data noting that we may be entitled or legally obligated to continue processing your data and refuse your request;
Right to request transfer of your personal data in [an electronic format].

If you wish to exercise your rights, please contact us using the details below (see section below ‘Who to contact about your Personal Information?’).

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We hope that we can satisfy any queries that you may have about the way we process your personal data.

Description	When is this right applicable?
Right of access to Personal Information You have the right to receive a copy of the Personal Information we hold about you and information about how we use it.	This right is applicable at all times when we hold your Personal Information (subject to certain exemptions).
Right to rectification of Personal Information You have the right to ask us to correct Personal Information we hold about you where it is incorrect or incomplete.	This right is applicable at all times when we hold your Personal Information (subject to certain exemptions).
Right to erasure of Personal Information This right is sometimes referred to as 'the right to be forgotten'. This right entitles you to request that your Personal Information be deleted or removed from our systems and records. However, this right only applies in certain circumstances.	Examples of when this right applies to Personal Information we hold include (subject to certain exemptions): · When we no longer need the Personal Information for the purpose we collected it; · If you withdraw consent to our use of your information and no other legal justification supports our continued use of your information; · If you object to the way we use your information and we have no overriding grounds to continue using it; · If we have used your Personal Information unlawfully; and · If the Personal Information needs to be erased for compliance with law.
Right to restrict processing of Personal Information You have the right to request that we suspend our use of your Personal Information. However, this right only applies in certain circumstances. Where we suspend our use of your Personal Information we will still be permitted to store your Personal Information, but any other use of this information while our use is suspended will require your consent, subject to certain exemptions.	You can exercise this right if: · You think that the Personal Information we hold about you is not accurate, but this only applies for a period of time that allows us to consider if your Personal Information is in fact inaccurate; · The processing is unlawful and you oppose the erasure of your Personal Information and request the restriction of its use instead; · We no longer need the Personal Information for the purposes we have used it to date, but the Personal Information is required by you in connection with legal claims; or · You have objected to our processing of the Personal Information and we are considering whether our reasons for processing override your objection.
Right to object to processing of Personal Information You have the right to object to our use of your Personal Information in certain circumstances.	You can object to our use of your Personal Information where you have grounds relating to your particular situation and the legal justification we rely on for using your Personal Information is our (or a third party's) legitimate interests. However, we may continue to use your Personal Information, despite your objection, where there are compelling legitimate grounds to do so or we need to use your Personal Information in connection with any legal claims.
This right is different where it relates to direct marketing and you can read about how to exercise your right to opt-out of receiving any direct marketing in the 'How can you tell us about your marketing preferences?' section of this Privacy Policy.	You can also object to the use of your Personal Information for direct marketing purposes at any time (including if we are carrying out profiling related to direct marketing).
Rights relating to automated decision making and profiling You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. However, this right only applies in certain circumstances.	This right is not applicable if: · We need to make the automated decision in order to enter into or fulfil a contract with you; · We are authorised by law to take the automated decision; or · You have provided your explicit consent to the decision being taken in this way using your Personal Information.
Right to withdraw consent to processing of Personal Information Where we have relied upon your consent to process your Personal Information, you have the right to withdraw that consent.	This right only applies where we process Personal Information based upon your consent.

Description

When is this right applicable?

Right of access to Personal Information

You have the right to receive a copy of the Personal Information we hold about you and information about how we use it.

This right is applicable at all times when we hold your Personal Information (subject to certain exemptions).

Right to rectification of Personal Information

You have the right to ask us to correct Personal Information we hold about you where it is incorrect or incomplete.

This right is applicable at all times when we hold your Personal Information (subject to certain exemptions).

Right to erasure of Personal Information

This right is sometimes referred to as 'the right to be forgotten'. This right entitles you to request that your Personal Information be deleted or removed from our systems and records. However, this right only applies in certain circumstances.

Examples of when this right applies to Personal Information we hold include (subject to certain exemptions):

· When we no longer need the Personal Information for the purpose we collected it;

· If you withdraw consent to our use of your information and no other legal justification supports our continued use of your information;

· If you object to the way we use your information and we have no overriding grounds to continue using it;

· If we have used your Personal Information unlawfully; and

· If the Personal Information needs to be erased for compliance with law.

Right to restrict processing of Personal Information

You have the right to request that we suspend our use of your Personal Information. However, this right only applies in certain circumstances.

Where we suspend our use of your Personal Information we will still be permitted to store your Personal Information, but any other use of this information while our use is suspended will require your consent, subject to certain exemptions.

You can exercise this right if:

· You think that the Personal Information we hold about you is not accurate, but this only applies for a period of time that allows us to consider if your Personal Information is in fact inaccurate;

· The processing is unlawful and you oppose the erasure of your Personal Information and request the restriction of its use instead;

· We no longer need the Personal Information for the purposes we have used it to date, but the Personal Information is required by you in connection with legal claims; or

· You have objected to our processing of the Personal Information and we are considering whether our reasons for processing override your objection.

Right to object to processing of Personal Information

You have the right to object to our use of your Personal Information in certain circumstances.

You can object to our use of your Personal Information where you have grounds relating to your particular situation and the legal justification we rely on for using your Personal Information is our (or a third party's) legitimate interests.

However, we may continue to use your Personal Information, despite your objection, where there are compelling legitimate grounds to do so or we need to use your Personal Information in connection with any legal claims.

This right is different where it relates to direct marketing and you can read about how to exercise your right to opt-out of receiving any direct marketing in the 'How can you tell us about your marketing preferences?' section of this Privacy Policy.

You can also object to the use of your Personal Information for direct marketing purposes at any time (including if we are carrying out profiling related to direct marketing).

Rights relating to automated decision making and profiling

You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. However, this right only applies in certain circumstances.

This right is not applicable if:

· We need to make the automated decision in order to enter into or fulfil a contract with you;

· We are authorised by law to take the automated decision; or

· You have provided your explicit consent to the decision being taken in this way using your Personal Information.

Right to withdraw consent to processing of Personal Information

Where we have relied upon your consent to process your Personal Information, you have the right to withdraw that consent.

This right only applies where we process Personal Information based upon your consent.

Who to contact about your Personal Information?

If you have any questions, concerns or complaints about the way your Personal Information is used by us, you can contact us by email or post using the details below.

Email: dataprotection@britam.com

Writing: Data Protection Officer, Britam Holding Plc, Britam Tower, Hospital Road, Upper hill, Nairobi

What user and device data do we collect through Britam Digital Services?

User and device data is collected when you use Britam Digital Services. This information may not reveal your specific identity and therefore may not be Personal Information which is used as described in the earlier sections of this Privacy Policy.

Examples of this type of user and device data are:

Internet browser and electronic device information;
App usage data;
Information collected through cookies, pixel tags and other technologies;
Demographic information; and data grouped together so that it is not possible to link the data to a particular individual, known as aggregated data.

We and our third party service providers may collect user and device data in a variety of ways when you use Britam Digital Services, including:

Method of data collection	Examples
Through your internet browser or electronic device	Certain information is collected by most websites or automatically through your electronic device, 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, electronic device manufacturer and model, language, time of the visit, pages visited, and the name and version of the Britam Digital Services (such as the App) you are using. We use this information to ensure that the Britam Digital Services function properly.
Through your use of an App	When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your electronic device accesses our servers and what information and files have been downloaded to the App based on your device number.
Using cookies and online tracking	We may use cookies and other online tracking tools (with your consent where required by applicable law). Cookies are pieces of information stored directly on the device you are using. Cookies allow us to recognize your device and to collect information such as internet browser type, time spent using Britam Digital Services, pages visited, language preferences and relevant country website. We may use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience while using the Britam Digital Services. In addition, we may use the information to gather statistical information about the usage of the Britam Digital Services in order to understand how they are used, continually improve their design and functionality, and assist us with resolving questions about them. 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. You can refuse to accept the 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. We do not respond to browser do not track signals at this time. Third parties may collect information about your use of Britam Digital Services and your use of other websites or online services.
Using pixel tags, web beacons, clear GIFs or other similar technologies	We may use pixel tags, web beacons, clear GIFs and other similar technologies with your consent (where required by applicable law). These may be used in connection with some Britam Digital Services and HTML-formatted email messages to, among other things, track the actions of users of Britam Digital Services and email recipients, measure the success of our marketing campaigns and compile statistics about usage of Britam Digital Services and response rates. We may use interest-based advertising service providers to customize, target, serve and report on Britam advertisements served across the web and mobile applications, based on information relating to our offline interactions with you, our online interactions with you (on any of your devices) and information received from third parties. To do this, these service providers may use cookies, pixel tags and other technologies to collect information about your and other users’ use of the Britam Digital Services and third party sites and mobile applications. They may also use these technologies along with information they collect about your online use, to recognise you across the devices you use, such as a mobile phone and a laptop. Our service providers may also match personal information we provide to them with your IP address and serve Britam advertisements to you across the web, based on your IP address.
Physical location	Subject to applicable law (and your consent where required by applicable law), we may collect the physical location of your electronic device by, for example, using satellite, mobile/cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. Subject to your marketing preferences and applicable law, we may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content. In addition, we may obtain the precise geolocation of your device when you use our mobile applications for travel or other assistance services. In connection with providing travel or other assistance services, we may share your device’s precise geolocation information with our clients and other entities with whom we work. You may opt-out of our collection and sharing of precise geolocation information by deleting the mobile application from your device, by disallowing the mobile application to access location services through the permission system used by your device’s operating system, or by following any additional opt-out instructions provided in the privacy notice available within the mobile application. In some circumstances, physical location information may become your Personal Information if you are identifiable in relation to the physical location information. In such cases, the physical location information will be handled as Personal Information as described in the earlier sections of this Privacy Policy.
Using information provided by 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 group information together so that it does not link to a specific individual, i.e. aggregate, and use that information (for example, we may aggregate information to calculate the percentage of our users who have a particular telephone area code).

Please note that, where user and device data is not Personal Information, we may use and disclose that data for any purpose to the extent we are allowed to by law. If we are required to treat user and device data as Personal Information under applicable law, or if we combine user and device data with identifiable Personal Information, then, in addition to the uses listed in this section, we may use and disclose user and device data for all the purposes for which we use and disclose Personal Information.

What cookies are used on our website?

The cookies we use on our website are as follows:

Type of cookie	What it does	What data it collects	What we use the data for
Geolocation cookies	When a visitor visits one of our sites for the first time we read their location from their IP address and use this information to assume the country site that they want to visit.	This method is not entirely accurate, however, so when they navigate to a particular country site we use this cookie to store this information and to store the language that they chose to view the site in. Information relating to which country site and language you have chosen to view.	To ensure that you are presented with the same country site and language as you chose on your last visit to our site without needing to re-select these options.
Site catalyst cookies (by Adobe)	This cookie enables us to collect and analyse data about how visitors arrive at our site and then how they interact with our site.	The cookie is placed on a visitor’s device on a temporary basis only. Information relating to how you arrived at our site and how you interact with it (e.g. content you view, products you search for and steps taken towards a sale).	To adapt our sites to better serve users’ needs and provide more relevant information. To allow us to undertake anonymous statistical analysis.
DoubleClick cookies	A form of tracking pixel cookie which is stored on site visitors’ devices and tells us whether you have previously visited our site. The fact that you have previously visited one of our sites.	We use these cookies to know that a visitor has been on our site before which allows us to display an appropriate banner ad on an affiliated network website. One of the advertisement companies that we use is Google, Inc., trading as DoubleClick.	For more information on the DoubleClick cookie, or to opt-out from the DoubleClick advertisement cookie please visit: http://www.google.com/privacy/ads/.
Affiliate cookies	A form of tracking pixel cookie which tells us which affiliate website you used in order to get to our site.	The transaction ID (which identifies which affiliate website you came through) and a date/time stamp.	To ensure that affiliates who refer sales to us are credited for this.

You can refuse to accept the cookies we use by adjusting your browser settings. However, if you do not accept all the cookies on the Site, you may experience some inconvenience in your use of the Site and some online products.

In addition to the cookies mentioned above, cookies may also be placed on your electronic device when you open emails we send to you. We use these emails to track the effectiveness of our advertising.

When was this Privacy Policy last updated?

This Privacy Policy was last updated on 22/02/2024.

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business activities, legal requirements, and the manner in which we process Personal Information. We will place updates on this website and where appropriate we will give reasonable notice of any changes.

Privacy Policy

We value your privacy