PHILINSURE DATA ​PRIVACY​​ ​NOTICE 

POLICY STATEMENT  

We at Philinsure know you care about how your personal information is used and shared, and we take your privacy seriously. Philinsure is fully committed to respect your privacy and protect your information in compliance with the requirements Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012. 

In this Privacy Notice, we identify the personal data that we may collect about you and how we may use that data. This Privacy Notice applies to any personal data you provide to Philinsure and any personal data we may collect from other sources unless you are provided a more specific privacy statement at the time of data collection. This Privacy Notice does not apply to any third-party websites, applications or portals (“Sites”) linked to Philinsure’ s Sites. If you provide personal data to us about other people, you must provide them with a copy of this Privacy Notice and obtain any consent required for the processing of that person’s data in accordance with this Privacy Notice. 

Any decisions for the disclosure, retention or disposal of personal data we receive​ ​and process are made in line with the implementing rules and regulations of the Data Privacy Act of 2012 and other relevant government regulations and issuances​.​​ ​​We ​will always ensure that the personal data being processed is protected at all times.  

By using or accessing our services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information. 

SCOPE OF THIS POLICY 

This Privacy Policy pertains to all the data we handle concerning you, which includes information acquired through customer forms and website cookies, in relation to your association with us as a client or prospective client. Its purpose is to ensure transparency regarding our privacy procedures, specifically regarding the kinds of personal information we gather, the methods of collection, the potential uses of such information, and the parties with whom we may share it. 

We follow this Privacy Policy in accordance with the applicable laws in the Philippines. 

CONSENT 

By using our Sites, or providing us your Personal Data, you ​have given ​your permission for our collection, use, and processing of your Personal Data, and you have accepted the policies and practices described in this Privacy Notice. 

If you do not allow the collection, use, and processing of your Personal Data, kindly refrain from using our websites, applications, portals, and platforms (Sites) /or contact us for any privacy-related concerns. 

WHY DOES PHILINSURE COLLECT AND PROCESS YOUR PERSONAL DATA 

Philinsure ​will use your personal information for the following purposes:​​     ​ 

  • Perform services for you or our clients. 
  • Provide services and fulfil our contractual obligations, including providing services that you may not have personally requested but were requested by our client(s) and require us to interact, directly or indirectly, with you. 
  • Facilitate and enable placement of policies and assist in the ongoing management of such policies, including premium management, renewals, adjustments, cancellations, claims management and settlement. 
  • Provide various consulting, administration and actuarial services and claims administration. 
  • Advise on the management of our clients’ business risks and opportunities, affairs and insurance arrangements and on the administration of claims. 
  • Manage our business operations 
  • Enter into business relationships and perform due diligence and background checks, such as fraud, trade sanctions screening, and credit and anti-money laundering checks. 
  • Create, maintain, customize and secure your account with us.
  • Maintain accounting records, analyze financial results, comply with internal audit requirements, receive professional advice, apply for and make claims on our own insurance policies, manage or dispute a claim and recover a debt. 
  • Conduct data analytics, surveys, benchmarking, and risk modelling to understand risk exposures and experience, for the purposes of creating de-identified and/or aggregate industry or sector-wide reports, to share within Philinsure’ s affiliates, partners and with third parties. 
  • Communicate and market to you 
  • Communicate with you regarding your account or changes to our policies, terms and conditions, respond to any inquiries you may have, and send you invitations for events or meetings. 
  • Advertise, market and promote our services or the services of others, including by email, LinkedIn, SMS, post or telephone. 
  • Send you newsletters, offers or other information we think may interest you, as well as offer and administer promotions. 
  • Monitor usage of our Sites and personalize your experience with our Sites and the messages we send you to deliver content, product and service offerings relevant to your interests, including targeted offers and ads through our Sites, third-party Sites, and via email, SMS or text (with your consent, where required by law). 
  • Comply with legal obligations 
  • Comply with national security or law enforcement requirements, discovery requests, or where otherwise required or permitted by applicable laws, court orders or regulatory authorities. 
  • Exercise and defend ours, yours or third parties’ legal rights. 
  • Monitor and prevent fraud or wrongdoing 
  • Maintain the safety, security, quality, and integrity of our products, services, systems and data, detect security incidents, protect against inadvertent data loss, malicious, deceptive, fraudulent, or illegal activity, and debug or identify and repair errors that impair existing intended functionality. 
  • Monitor and ensure the safety and security of our premises, property, employees and visitors. 
  • Improve our services 
  • Develop, enhance, expand or modify our services through research and development. 
  • Monitor, review, assess and improve our technology systems, including any Sites, and our content on social media platforms. 
  • Improve quality, training and security (for example, with respect to recorded calls). 
  • Mergers and acquisitions 
  • Facilitate commercial transactions, including a reorganization, merger, sale of all or a portion of our assets, a joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). Should such a sale or transfer occur, we will use reasonable efforts to ensure the entity to which we transfer your personal data agrees to use it in a manner consistent with this Privacy Notice. 

If you want to join our workforce 

We may collect, use, or process your Personal Data to: 

  • evaluate your suitability for employment with Philinsure This includes assessing qualifications, conducting background checks, and verifying the accuracy of the information provided. 
  • retain your personal information for the duration necessary to fulfil the purposes stated above, for future job opportunities that may be of interest to you or as required by applicable laws and regulations. 
  • communicate with you about your employment application. 
  • when hired, process your Personal Data as may be necessary for purposes such as, but not limited to, payroll, benefits application, allowances and refunds processing, tax processing, retirement benefits, and other purposes that demand or require processing of your Personal Data (e.g., to execute business transactions directly related and/or incidental to your job, business travels, socials, and so on). 
  • while employed, evaluate your performance and career development. 
  • upon separation, process your Personal Data for the exit interview and to prepare your final pay. 
  • provide assistance to, and account for, employees in case of emergency. 
  • perform such other processing or disclosure that may be required during Philinsure’ s business or under law or regulations.  

WHAT PERSONAL INFORMATION PHILINSURE COLLECT 

We may collect the following types of personal data depending on the purpose of your interaction with us (e.g. as business contact, customer, claimant, insured): 

  • Basic personal and demographic information, such as your name, date of birth, age, gender and marital status. 
  • Contact information, such as your address, telephone number and email address. 
  • Unique identifiers, such as identification numbers issued by government bodies or agencies (e.g., your national identifier number or social security number, passport number, ID number, tax identification number, driver’s license number). 
  • Employment information, such as your job title, employer, employment status, salary information, employment benefits, employment history and professional certifications. 
  • Financial information, such as your bank account numbers, credit card numbers, brokerage account numbers, transaction information, tax information, details of your income, property, assets, investments, pension and benefits, debts, and creditworthiness. 
  • Policy information, such as your policy number, policy start and end dates, premiums, individual terms, claims history and claims data, mid-term adjustments, reasons for cancellation, risk profile and details of policy coverage. 
  • Claim information, such as a claimant’s relationship to a policyholder/insured, and the date and particulars of such claim, including causes of death, injury or disability and claim number. 
  • Commercial information, such as records of your personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. 
  • Events or meeting information, such as details about your visits to our offices (including CCTV), your interest in and attendance at events or meetings, audio recordings, photographs or videos captured during meetings, events or calls with you. 
  • Special category data and sensitive personal data, such as data relating to your health (including protected health information), genetic or biometric data, sex life, sexual orientation, gender identity, racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership. 
  • Criminal records information, such as criminal charges or convictions, including driving offences, or confirmation of clean criminal records. 
  • Professional disciplinary information. 
  • Personal information received from background checks and sanctions screenings. 
  • Marketing information, such as your consent to or opt out from receiving marketing communications from us and/or third parties, your marketing preferences, or your interactions with our marketing campaigns and surveys, including whether you open or click links in emails from us or complete our surveys. 
  • Sites and communication usage information, such as your username, your password, other information collected by visiting our Sites or collected through cookies and other tracking technologies, including your IP address, domain name, your browser version and operating system, traffic data, location data, browsing time, and social media information, such as interactions with our social media presence.  

HOW DOES PHILINSURE COLLECT YOUR PERSONAL DATA 

We may collect your personal data in a number of ways, which vary based on how you interact with us. The following summarizes our various collection points: 

  • Directly from you or your authorized representative, such as when you provide your personal data to us, including from any of our Sites, surveys, live events, market research, and other direct communications and/or solicitations. 
  • From our clients and partners, such as commercial clients, (re)insurers, network partners, employers, benefit plan sponsors, benefit plan administrators, premium finance companies, health service providers, data/marketing list providers and third-party service providers. 
  • Publicly available sources, such as social media platforms, property and assets registers, and claims and convictions records. 
  • Philinsure affiliate companies. 
  • Government authorities, such as police and regulators. 
  • Background checks and screening tools, such as insurance industry fraud prevention and detection databases, credit agencies and sanctions screening tools. 
  • Other third parties. 

PERSONAL DATA OF CHILDREN 

​​Our Sites are not intended for children. We do not intentionally gather or request Personal Data from individuals under the age of 18 unless we have obtained consent from their parents or legal guardians. ​​     ​ If you are under ​the ​age ​of ​18, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have inadvertently collected Personal Data from our Sites from a child below the age of 18, we will delete that information​     ​​, or where that minor has an account, terminate the minor’s account.​​     ​ 

HOW DOES PHILINSURE PROTECT YOUR PERSONAL DATA 

We endeavour to protect the privacy of your account and other Personal Information we hold in our records by using a range of organizational and technical security measures to protect your personal data, including the following: 

  • Restricted access to those who need to know for the purposes set out in our underlying agreement or this Privacy Notice. 
  • Firewalls to block unauthorized traffic to servers.
  • Physical servers located in secure locations and accessible only by authorized personnel. 
  • Internal procedures governing the storage, access and disclosure of your personal data. 
  • Additional safeguards as may be required by applicable laws in the jurisdictions where we process your personal data. 

​​​In cases where we have provided you with a password, or you have chosen one, it is your responsibility to maintain the confidentiality of that password.​​     ​ ​     ​​​​ 

​​​We have implemented suitable safeguards, both in terms of physical, technological, and administrative measures, to safeguard the personal data entrusted to us. Nevertheless, the security of user information may be compromised due to unauthorized access, hardware or software issues, and various other factors, regardless of our precautionary efforts.​​     ​​ 

HOW WE PROTECT YOUR PERSONAL DATA WHEN SENDING IT INTERNATIONALLY 

​​Being a reinsurance broker, we may transmit your personal data across borders, including within Philinsure’ s affiliates, partners and to certain third parties, including our partners and service providers. This sharing of data allows us to provide you services as set out in our underlying agreement or as otherwise indicated in this Privacy Notice. The laws that apply to the country where the data is transferred may not be equivalent to that in our local jurisdiction (or in the jurisdiction in which we provide the services). Transfers of personal data will be subject to appropriate safeguards to ensure an adequate level of protection and compliance with applicable law. Please contact us using the details provided under the Contact Us section if you would like further information regarding the steps, we take to protect your personal data when sending it internationally.​​​ 

MARKETING ACTIVITIES 

Every now and then, we may provide you with information about our products or services or those of our partners that we think will be of interest to you. We may send you this information by email, LinkedIn, SMS, text, post or we may contact you by telephone. We may also share your personal data with other Philinsure affiliates so that they can provide you with information about their products and services we believe will be of interest to you. We ensure that our marketing activities comply with all applicable legal requirements. In some cases, this may mean that we ask for your consent in advance of sending you marketing materials. 

You can opt out of receiving marketing communications from us at any time. For example, you can click on the “unsubscribe” link in our marketing emails to unsubscribe from those emails. Alternatively, please contact us using the details provided under the Contact Us section. In such circumstances, we will continue to send you service-related communications where necessary. 

HOW LONG DO WE RETAIN YOUR PERSONAL DATA 

The authorization and consent will continue to be in effect throughout the duration of your policy or until the retention limit set by laws and regulations from account closure, and the period set until destruction or disposal of record, unless withdrawn in writing or withheld due to changes in the information supplied by Philinsure. 

WHAT RIGHTS DO YOU HAVE REGARDING YOUR PERSONAL DATA 

If you wish to exercise any of the rights granted to you under the applicable data protection laws, you can contact our Data Protection Officer. However, please keep in mind that we will need you to provide proof of your identity before we can respond to any requests regarding your privacy rights. We will make every effort to respond to your request within a reasonable timeframe after receiving it, and we will grant you access to the requested information in the manner you specified, unless it is deemed unreasonable or impractical for us to do so. 

These are your rights: 

  • ​​​Right to be informed. You have the right to be informed when your personal data shall be, are being, or have been processed.​​ 
  • ​​​Right to be furnished. You have the right to be furnished with relevant information before the entry of your personal data into the processing system or at the next practical opportunity.​​ 
  • ​​​Right to access.  You have the right to find out whether an organization holds any personal data about you on its computer database and/or manual filing system and, if so, gain reasonable access to them.​​ 
  • ​​​Right to object. You have the right to object to the processing of your personal information. You can likewise ask us to stop or restrict how we process your personal information unless we need to process your information to carry out our day-to-day business functions or where we have compelling legitimate grounds for processing your information.​​ 
  • ​​​Right to erasure or blocking. You have the right to suspend, withdraw or order the blocking, removal or destruction of his or her personal data.​​ 
  • ​​​Right to rectify. To preserve the integrity of your personal data, you have the right to dispute the inaccuracy or error in your personal data and have it corrected immediately and accordingly, unless the request is vexatious or otherwise unreasonable.​​ 
  • ​​​Right to data portability. You have the right to ask us to help you move your personal information to other companies, where this is technically possible and only if we have collected and used your data via electronic means. Other conditions may apply to the exercise of this right.​​ 
  • ​​​Right to file a complaint. You have the right to file a complaint with the National Privacy Commission when your personal information has been misused, maliciously disclosed, or improperly disposed of, or when your data privacy rights have been violated.​​ 
  • ​​​Right to damages. You have the right to claim compensation for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use or disclosure of your personal data, taking into account any violation of your rights and freedoms as a data subject.​​ 

​​​​​ 

CONTACT US IF YOU HAVE QUESTIONS REGARDING YOUR PERSONAL DATA 

​​​When you would like to exercise your rights, please send us a request through our Data Protection Officer:​​ 

​​​The Data Protection Officer ​​ 

​​​Philinsure​​ 

​​​dataprotection@philinsure.com​​ 

​​​2/F Centro Maximo II, Corner D. Jakosalem & V. Ranudo Streets, Cebu City, Philippines 6000​​ 

​​​Monday – Friday, 8:30 a.m. – 5:30 p.m. (PT)​​ 

​​​     ​​ 

​​​​​UPDATES TO THIS PRIVACY NOTICE​​ 

​​​Since we are​​​ ​constantly trying to improve our Services, we may amend, interpret, modify or withdraw any portion of this Data Privacy Policy at any time by posting updated contents on our website.  By continuing the use of our service, this ​​constitutes consent​​​ ​to those changes.​​ 

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​​​​​​​     ​​​LAST UPDATE:  JULY 2023​