Phoenix e-Insurance Privacy Policy

Effective Date: May 18, 2018

This Privacy Policy describes how Phoenix e-Insurance collects and uses personal information (your "Personal Content") about you ("you" or "your"), and your rights in relation to this information. This Privacy Policy applies to all Personal Content that we collect or process about you through the Phoenix e Insurance Service which includes the use of the Phoenix’s iOS and Android applications, website, products, and services, including but not limited to applying for, purchasing, and making claims under any Terms of Protection purchased through and/or provided by Phoenix e-Insurance. Personal Content is information, or a combination of pieces of information, that could reasonably allow you to be identified.

 

Your privacy is very important to us and we handle your Personal Content with great care and discretion. We’ve developed this Privacy Policy which explains to you how we collect, use, disclose, transfer and store your Personal Content when you use the Phoenix e-Insurance Service and/or communicate with us. As the business environment changes and Phoenix e-Insurance evolves, we may need to update this Privacy Policy. We’ll announce changes on our website, and we may also notify you by sending an email to you.

If you have any questions or comments in relation to this Privacy Policy, please  contact privacy@phoenixinsurancegh.com.

What Personal Content Does Phoenix Collect and Why?

We collect and process the following data about you:

·       Information that you give us

o   This is information that we collect, for example, when you register with us, download the Phoenix e-Insurance, use the Phoenix e-Insurance, fill in forms via the Phoenix e-Insurance, correspond with us by email, report a problem with the Phoenix e-Insurance, submit a claim via the Phoenix e-Insurance or make a purchase;

·       Information we collect about you and your device

o   We automatically collect certain technical information about you when you use the Phoenix e-Insurance including your device identifier and location, how you use the Phoenix e-Insurance, language selection and preferences;

·       Information we receive from third parties

o   We collect information about you from third parties, such as companies with whom we partner, business partners, analytics providers and any social media sites that you may use, such as Facebook, Twitter, YouTube and LinkedIn. The information supplied to us by such third parties is regulated by their respective privacy and cookies policies; and

·       Cookies and other similar technologies

o   We collect cookies and other similar identifiers to distinguish you from other users of the Phoenix e-Insurance.

Further details of the Personal Content we collect and why we collect it is set out below.

If you register a Phoenix Account:

We May Collect

Why We Collect It

Your email address and information about whether you own or rent your home

·       To create and support your Phoenix account.

·       To send you insights about your Phoenix account.

·       To communicate product news and marketing messages, unless you have opted out from receiving such information (please see the section on “Opting out of email & notifications” for further information).

The language selected and geographic area of your device when you use the Phoenix e-Insurance

·       To localize and improve the user experience of the Phoenix e-Insurance.

·       To comply with local legal restrictions.

Your device identifier

·       To calculate aggregate statistics, for fraud prevention, for product development and analytics purposes including for sharing with third parties on an anonymous, aggregated basis for the reasons described under "Information Access and Disclosure".

Your location information, if you elect to share it

·       To quickly add your home/address to your Phoenix account and to provide you with localized information and alerts about items in your Phoenix account.

Actions you perform, including your use of certain product features, as well as the type of device and software you are using

·       To improve the features and usability of the Service. For instance, we may track your actions to better understand how you use our services in order for us to make improvements.

Anonymous logging of our HTTP API usage

·       To provide better security and troubleshoot errors.

Information regarding items that you add to your Phoenix Account

·       To provide the Phoenix e-Insurance to you and to help us maintain a record of items that you add to your Phoenix account. For more information, see “Does Phoenix Share My Personal Content?” below.

 

If you purchase a policy with Phoenix e-Insurance:

We May Collect

Why We Collect It

Full name, email, phone number (if provided), home address, age (D.O.B.), social security number, gender, location information.

·       To confirm your identity.

·       To personally cater a price for you

·       Identify you and conduct appropriate checks.

·       As a primary means of communication with you to send you important information about the policy purchased through your Phoenix e-Insurance account, including purchase receipts, billing and claims updates.

·       To help with fraud prevention

·       To help make decisions on insurance policies and insurance claims

Information about the protected item(s) in your Phoenix e-Insurance account including photographs that you upload and the related metadata.

·       To provide appropriate pricing and protection for your item(s).

·       To validate possession, ownership and/or condition.

·       For fraud prevention

·       For claims management purposes.

Details related to Phoenix Policy transactions, claims & other communications (email, chat, phone)

·       To ensure effective delivery of service, including support, claims and complaints.

·       For internal training & quality assurance purposes.

·       Manage complaints and disputes, and report to dispute resolution bodies.

·       For fraud prevention

Your payment information

·       To collect premium for protection or to process claims. See also "Payment Service Providers" below.



Please note that Phoenix Policies cannot be purchased unless you provide the above data.

If you use our mobile app or visit www.phoenixinsurancegh.com:

We May Collect

Why We Collect It

Your email address, full name, phone number, age, postcode, gender

·       To provide you with a personalized quote

·       To communicate with you about relevant news, updates, and promotions related to Phoenix.

IP address, pages visited, browser type and settings, cookies and similar tracking information

·       To improve our website and create better, more relevant content for you.

·       To calculate aggregate statistics and to improve the features and usability of the Phoenix e-Insurance.

Communications, transactions and experiences between you and Phoenix

To better assist you and other users of the Phoenix e-Insurance.

Marketing

We may use your Personal Content and your marketing preferences to build a profile for you and to inform you of our products and services which we consider may be of interest to you. You have a right to ask us not to process your Personal Content for marketing purposes and may exercise that right by opting out at any time (see "Opting out of email & notifications" for further information). We do not share your Personal Content with unaffiliated third parties for their own marketing purposes.

Opting out of email & notifications

You may opt out of different types of email communications using the unsubscribe link found in the footer of the emails sent. Your decision to opt-out does not prohibit our sharing of information in order to service your account, as permitted by law, or if necessary for us to follow the law. For example, if you buy a Phoenix Policy, you will continue to receive legally required service-related and account-related information and documents, even if you unsubscribe from promotional emails. You may opt out of any app notifications from Phoenix through the settings in the Phoenix e-Insurance on your device (iOS or Android).

Types of Third Parties to Which We Disclose Personal Data and Why

Does Phoenix Share My Personal Content?

Personal Content is content added to your Phoenix e-Insurance account that personally identifies you. As a rule, Phoenix employees do not have access to any portion of your Phoenix e-Insurance account details and we make sure that our access and use of these services is protected at the highest level. We will never share your Personal Content with third parties without your separate permission. However, we may share your Personal Content as follows:

·       We may share your Personal Content with businesses that are legally part of the same group of companies that Phoenix is part of, or that become part of that group ("Affiliates"), or that are contractors or service providers to Phoenix or its Affiliates that are contracted to provide services on behalf of Phoenix or its Affiliates that are also subject to confidentiality. Affiliates and contractors may use this information to help provide, understand, and improve the Phoenix e-Insurance. These Affiliates and contractors will honor the choices you make about who can use your data.

·       Partners, such as distributors, channel partners and other third parties, including companies with whom Phoenix jointly offers products or services to fulfill product or information requests, and/or to provide customers or prospective customers with information about Phoenix and its products or services.

·       If you acquire protection through any particular group we may share your Personal Content to report claims experience or to all any such group policy to review or audit the Phoenix e-Insurance.

·       On rare occasions, we may be required by law, legal process, litigation, or governmental authorities, including to meet national security or law enforcement or regulatory requirements to disclose your Personal Content. In such instances, if permitted by law, we will notify you of such request, and allow for you to interject yourself into the disclosure of such information.

·       Phoenix may also disclose Personal Content in special cases when we have a good faith belief that such action is necessary to protect and defend our legal rights or property, enforce website terms and conditions, or to protect the interests of our users or others.

·       We may disclose your Personal Content in connection with the sale, bankruptcy, dissolution, reorganization or other business transition such as merger, acquisition, or sale of all or part of Phoenix’s business, as permitted by applicable law. Where required by law, we will inform you of such disclosure prior to the implementation of any of these changes, and will provide you with an opportunity to remove your personal data from the Phoenix e-Insurance.

·       We may also disclose your Personal Content to enable Phoenix to enforce its rights (including enforcing the Privacy Policy, the Cookies Policy and/or Terms of Use) and/or to protect the security of the system and/or other users and protect its intellectual property and/or to prevent and detect fraud (see "Preventing & Detecting Fraud" below for more information).

·       While we do not share Personal Content without your separate permission, we may publicly share aggregated, non-identifiable data, for example, anonymized reports related to categories of items owned in different geographies or other aggregate insights related to the things that people own and are protecting, for marketing and business development purposes.

If You Choose to Purchase Protection

We provide insurance for items in your Phoenix Account. If you do not purchase a Phoenix policy through Phoenix e-Insurance, then none of your Personal Content is shared with us except the details entered on sign up. If you choose to purchase a Phoenix policy for an item or items in your Phoenix e-Insurance policy, then your Personal Content is shared with us to use in issuing the insurance product. This is required in order for you to purchase a policy and to effectively deliver the Phoenix Insurance service.

Payment Service Providers

Phoenix uses 3rd party providers to process payments, refunds and claims. Since these organizations are separate businesses to Phoenix, payment information will be managed in accordance with their privacy policy, which may differ from this one. We currently use MTN Mobile Money for payments, and would let you know when we add other payment providers to our list. We maintain limited information about your payment information.

Disclosure to other Third Parties

App Analytics & Communication

To continuously improve the Phoenix experience, we employ third party technology providers that anonymously track actions within the Phoenix e-Insurance and facilitate email communications. Some such third parties may be located in jurisdictions whose laws do not provide equivalent protection for your Personal Content as in your location. We implement contractual and other measures with such third parties in order to ensure that your Personal Content is treated securely and in accordance with this Privacy Policy. We may also share your Personal Content with third parties for the purpose of performing actuarial or research studies. Please note that if we do so, your name or your identity will never appear in any resulting report. We also will implement contractual and other measures with such third parties in order to ensure that your Personal Content is treated securely and in accordance with this Privacy Policy.

 

Preventing & Detecting Fraud

To help keep premiums low by detecting and preventing fraud and other crimes, we may, at any time, disclose information about you to:

·       Other organizations and public bodies including the police;

·       Our underwriting partners and other insurers;

·       Recognized insurance industry application, policy and claims checking systems;

·       Insurance fraud registers or databases - this may affect future applications for insurance products as these entities may retain any information provided to them and they are permitted to disclose that information to others, including other insurance entities;

·       Check details and any information with fraud prevention agencies and databases, including publicly available data - if false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies to prevent fraud and/or money laundering;

·       If permitted by law, at inception of the relationship and periodically thereafter we may provide information to and obtain information from fraud prevention agencies or services, credit reference agencies, insurance support organizations or insurance databases in order to (i) help make decisions on insurance policies and claims for you or your financial associates; (ii) trace people who owe money, recover debt, prevent fraud and to manage your insurance policies and the insurance services that we provide; (iii) check your identity to prevent money laundering and to comply with “Know Your Customer” or similar obligations; or (iv) carry out credit searches and further fraud searches or otherwise to prevent fraud. Please note that any personal content provided to or obtained from a report of credit reference agencies or an insurance support organization or insurance databases may be retained by such entities and disclosed to other persons.

For more information about the agencies with which we share your data, including further details explaining how the information held by fraud prevention agencies may be used, please email us at privacy@phoenixinsurancegh.com.

Data Storage, Transfer and Deletion

How do I Make Changes to My Personal Content?

You may make changes to your Personal Content by logging into the Phoenix application and editing your Personal Content.

Where Is My Personal Content Stored?

When you use the Phoenix e-Insurance, Personal Content you save will be stored locally on your mobile device. It will also be replicated on our cloud servers in the United States. Please be aware that regardless of your location, Phoenix Insurance Ghana Co. Ltd is the data controller of your Content, which is stored in our United States data centers. Where we share your Content with our Affiliates, we will implement contractual and other measures with such Affiliates to ensure that your Content is treated securely and in accordance with this Privacy Policy.

How Secure Is My Personal Content?

We take many precautions to protect your Personal Content through administrative, technical, and physical safeguards to protect the security, confidentiality, and integrity of your Personal Content. For example, we use industry standard (SSL) encryption to protect your network communications; to the extent allowed by law, we run background checks on our employees; and we architect our networks to protect access to our storage servers. In addition to maintaining our high level of security, we are always striving to increase our security measures.

You are an important part of securing the data in your Phoenix Account. We recommend you use a strong password for the Phoenix e-Insurance. You should use the security features of your devices, including passcodes, Touch ID, and lost device location services. We are not responsible for any unwanted access to your Phoenix Account due to poor security of your devices or personal password.

How do I delete Personal Content in my Phoenix e-Insurance account?

You can delete the items in your Phoenix e-Insurance account or request them to be deleted at any time and they will be removed from our servers, if you have never purchased a Phoenix policy for them. You cannot delete items that have been protected, because we are required by law to retain these records. Residual copies of your deleted Personal Content, regardless of whether you’ve purchased a Phoenix policy, may remain on our backup systems for several months due to the nature of those systems’ operations.

If you’d like to stop all communications related to your account, you can deactivate it through the settings menu in the Phoenix application. Note, deactivating your account will not delete the items in it; this needs to be done manually prior to deactivation. Please note, however, that if you purchased a Phoenix policy even if you deactivate your account, we must maintain your account on our system and retain necessary records relating thereto. As a result, even if you deactivate your account, you will continue to receive legally required service-related and account-related information and documents. If you deactivate your account you can log in to your account at any time to re-activate it.

Other

Children’s Privacy Protection

The Phoenix e-Insurance is not directed to children, nor do we knowingly collect any personally identifiable information from children under 18 years of age through the Phoenix e-Insurance or software. If it comes to our attention through reliable means that a registered user is a child under 18 years of age and has purchased a policy, we will initiate cancellation of any such policy, unless we are prevented by law from doing so.

 

Other Websites

We are not responsible for the practices employed by any websites or services linked to or from the Phoenix e-Insurance, including the information or content contained within them. Please remember that when you use a link to go from our service to another website or service, our privacy policy does not apply to those third party websites or services. Your browsing and interaction on any third party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third parties that you authorize to access your data. If you are using a third party website or service and you allow them to access your data, you do so at your own risk.

Right to Access and to Request Correction

Requesting Access to or Correction of Personal Content

We take such steps as are reasonable to ensure that the personal information we collect and hold about you is accurate, up-to-date and complete. However, we rely on the accuracy of the personal information you provide to us. You may request details of the personal information which we hold about you. If you believe that any information we are holding about you is incorrect or incomplete, please visit www.phoenixinsurancegh.com/contact-us to request copies of the personal information that we have about you and if necessary to request correction.

Once we receive a request for access and/or correction, we will respond to that request within a reasonable period after the request is made and in any event within the timescales required by law. We will promptly correct any information found to be incorrect. There are some exceptions, specified by law, where we may refuse your requests. If one of these circumstances applies, we will provide you with a written explanation of the reasons for the refusal, unless it would be unreasonable to do so.

 

Concerns about Personal Content

If you have any concerns about our handling or treatment of your personal information or if you believe your privacy has been breached, please contact privacy@phoenixinsurancegh.com, setting out the nature of your complaint. We will investigate your complaint and provide you with our response within a reasonable time of receiving your complaint and in any event within the timescales required by law.

Contact Us

If you have any comments, questions or concerns about this Privacy Policy, please contact us at privacy@phoenixinsurancegh.com or by post at:

 

Phoenix Insurance Ghana Company Ltd

Location: House No. 244/3, 6th Ringway Estates.

Telephone: 233-302-246319, 246322, 246644.

E-mail: info@phoenixinsurancegh.com