GENERAL PRIVACY NOTICE
1. Introduction
1.1. In this General Privacy Notice, “ILA” refers to Island Life Assurance Co. Ltd and all the words and expressions used in this General Privacy Notice shall be interpreted and construed in line with the definitions used in ILA’s General Data Protection Policy.
1.2. This General Privacy Notice should be read and interpreted in conjunction with and subject to ILA’s General Data Protection Policy that governs all the personal data processing activities of ILA.
1.3. This General Privacy Notice is relevant to all persons (“data subjects”) whose personal data is collected by ILA in line with the requirements of the European General Data Protection Regulation 2016 (“GDPR”) and the Mauritius Data Protection Act 2017 (“DPA”).
1.4. Users of ILA’s website as well as ILA’s customers and potential customers are likely to be data subjects in as much as ILA may collect their personal information whether by automated or non-automated means.
2. Responsibilities
2.1. ILA is responsible for ensuring that this General Privacy Notice is made available to data subjects prior to ILA collecting/processing their personal data.
2.2. All Employees of ILA who interact with data subjects, both employees and non-employees are responsible for ensuring that:
2.2.1. this General Privacy Notice is drawn to the data subject’s attention prior to processing the latter’s personal data; and
2.2.2. they obtain the consent of the data subjects prior to the processing of their data wherever consent is required under either the GDPR or the DPA.
3. Privacy Statement
3.1. Who is ILA and what does ILA do?
3.1.1. ILA, one of the key players in the life insurance sector in the country, is part of the Currimjee Group of Companies, and is a fully owned subsidiary of Currimjee Jeewanjee and Company Limited (CJ), which has been in existence since 1890.
3.1.2. ILA has its registered office situated at 38 Royal Street, Port Louis 11602, Mauritius and its administrative headquarters situated at Corner Leoville L’homme & Sir William Newton Streets, Port Louis, Mauritius. ILA’s other contact details are as follows:
Telephone Number: +230 217 6900
Email address: customer.service@ila.mu
3.1.3. More information on ILA is contained in its General Data Protection Policy.
3.1.4. ILA is likely to process personal data both under the GDPR and the DPA.
3.1.5. The contact details of the Data Protection Officer are as follows:
Name: Deepti Gooroochurun
Postal address: Corner Leoville L’homme & Sir William Newton
Streets, Port Louis, Mauritius
Email address: iladpo@currimjee.com
Telephone No.: +230 217 69 00
3.1.6. The personal data ILA is likely to collect from you and process is mandatory and may include any information about an individual from which that person can be identified. Such data includes contact information (for e.g. name, home address, telephone numbers, email address, date of birth, identity and passport documentation), financial information (for e.g. bank details and payment card details), as well as other personal information such as medical history and reports, family history and employment/income details. The personal data referred to is not an exhaustive list and can be updated for legitimate business or legal purposes.
3.1.7. The personal data ILA collects from you will be used for such purposes as may be related, directly or indirectly, to our business activities. Your data may be used in the course of our business operations, for the purpose of the contract you have entered with us and for compliance with any legal and regulatory obligations. The data will be shared with Regulatory bodies and Reinsurance companies.
3.1.8. In any event, ILA is committed to ensuring that the information it collects and uses is appropriate for the purpose for which it was collected, and does not constitute an invasion of your privacy.
3.1.9. From time to time, ILA would like to use your name and contact details to send you either through telephone calls, messaging services, emails, post, or social media platforms, information about our offers, promotions, products, surveys and services, as well as those of CJ and its subsidiaries and affiliates, that we believe may be of interest to you, but we will only do so with your consent.
If you have agreed to receive direct marketing, you may always opt out at a later stage by following the unsubscribed instructions on each of our marketing communications.
You have the right at any time to stop ILA from contacting you for direct marketing purposes.
3.2. Consent
3.2.1. By using ILA’s website (as a user of ILA’s website) you are giving ILA permission to process your personal data specifically for the purposes identified above.
3.2.2. ILA will request your consent prior to processing any of your sensitive or special categories of personal data.
3.2.3. Sensitive or special categories of personal data is information about racial origin, ethnic origin, political opinion, religious belief, philosophical belief, trade union membership, genetic data, biometric data, health data, criminal record, data concerning sex life and/or sexual orientation.
3.2.4. You may withdraw consent at any time by informing ILA and/or ILA’s Data Protection Officer in writing of your wish to withdraw your consent without having to assign any reason for your decision.
3.2.5. ILA may exceptionally process sensitive or special categories personal data without your consent if such processing is required by law and/or a Court order or where the information is already in the public domain.
3.3. Disclosure and transfer
3.3.1. ILA may pass your personal data on to third-party service providers contracted by ILA in the course of dealing with you. Any third parties that ILA may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on ILA’s behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with ILA’s procedures.
3.3.2. Basically, ILA will not pass on your personal data to third parties unless it has obtained your consent or such disclosure is necessary for the processing activities of ILA in furtherance of a contractual relationship to which you are privy as a customer or potential customer of ILA or from which you will be deriving a personal interest.
3.3.3. ILA will not transfer your personal data to a different country without having carried out an adequacy test as explained in ILA’s General Data Protection Policy.
3.4. Third Party Websites
The ILA website may contain links to other websites, apps, content, services or resources of interest, which are operated by third parties. If you access websites, apps, content, services or resources using the links provided and you have left the ILA website, you must be aware ILA does not have any control over the other websites apps, content, services or resources. ILA is not responsible for the protection and privacy of any information you provide whilst visiting such websites, apps, content, services or resources and they are not governed by this Privacy Notice.
3.5. Use of Cookies
We use cookies that identify your browser. When you visit the ILA website, ILA may collect information from you automatically through cookies or similar technology. ILA may collect and store information about how you use the ILA website, as well as provide you with a better service and experience when browsing, and for analytics. The personal data we collect through these technologies will also be used to manage your session.
3.6. Report of Breach
Whenever ILA is on notice that a breach of personal data has been committed or reasonably suspects that a breach of personal data is likely to be committed, ILA shall as soon as reasonably practicable inform the relevant supervisory authority about the same. You shall also be informed about the same where such a breach is likely to impact on your rights and freedoms as a data subject.
3.7. Retention Period
3.7.1. Subject to paragraph 3.7.2 below, ILA will process and store your personal data for no longer that is required for the purpose for which it is initially collected.
3.7.2. Notwithstanding paragraph 3.7.1 above, ILA may store your personal data for such period as may be necessary for ILA’s compliance with legal obligations and for ILA’s legitimate interests such as the defence by ILA of legal claims that may be brought before it.
3.8. Your rights as a data subject
At any point, while ILA is in possession of or processing your personal data, you, the data subject, have the following rights:
(a) Right of access to your personal data;
(b) Right of rectification to correct data that ILA holds about you that is inaccurate or incomplete;
(c) Right to erase personal data from ILA records;
(d) Right to restriction of processing – where certain conditions apply to have a right to restrict the processing;
(e) Right of personal data portability;
(f) Right to object – you have the right to object to certain types of processing such as direct marketing;
(g) Right to object to automated processing of your personal data, including profiling; and
(h) Right to complain against ILA.
3.9. Complaints
In the event that you wish to make a complaint about how your personal data is being processed by ILA, or how your requests under paragraph 3.8 above have been handled, you have the right to lodge a complaint directly with the relevant supervisory authority and ILA’s Data Protection Officer.
3.10. What does ILA hold about you?
3.10.1. At any point in time, you can find out the personal data that the organisation holds about you, if any.
3.10.2. Upon a written request being received, ILA can confirm what information it holds about you and how it is processed.
3.10.3. Where ILA holds your personal data, you can request the above from ILA who will provide the information in accordance with the provisions of the Data Protection Act.
3.10.4. When making a written request to ILA pursuant to this paragraph 3.10, you will need to provide to ILA an appropriate form of identification (“ID”) in order to have access to the information. An appropriate form of ID is either your National Identity Card or your passport (provided the same has not expired).