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UNITRUST PRIVACY NOTICE

INTRODUCTION


Unitrust Insurance Company Limited is an insurance company established and licensed in 1981 in Nigeria to operate as an insurer. It presently carries out all forms of general/non-life insurance transactions including Oil & Gas


Unitrust Limited (“us”, “we”, or “our”) understands the criticality of privacy in handling your (“Data subject”) personal data. Hence, we want you to engage with us knowing that we value your Personal Data and that we protect it.


We have prepared this privacy policy in line with the Nigeria Data protection Regulation (NDPR) principles statutorily mandated by the NITDA ACT of 2007. This regulation governs the way in which we collect, use, disclose, store, secure and dispose of your Personal Data.


Here you will find details of how we process your Personal Data, the purposes for which we process it, your rights regarding the data we process and how you can contact us.


For the purposes of this notice and data protection legislation, the Company is the controller of your Personal Data




  1. PERSONAL DATA COLLECTED


    Personal Data refers to data that could identify a specific individual such as names, addresses, e-mail addresses, and telephone numbers. This data can either be provided by you or by a third party (for example, information from search information providers for due diligence purposes).
Depending on your medium of interaction with Unitrust (online, offline, mobile phone, etc.), or your relationship with us (for example, as a consumer policyholder; insured person benefiting under another policyholder’s policy, or claimant; witness; commercial broker or appointed representative; or other person relating to our business), we collect various types of information from you, as described below.



  • General identification and contact information 
Your name; address; e-mail and telephone details; gender; marital status; family status; date of birth; passwords on our systems; educational background; physical attributes; activity records, such as driving records; photos; employment history, skills and experience; professional licenses and affiliations; relationship to the policyholder, insured or claimant; and date and cause of death, injury or disability.

  • Identification numbers issued by government bodies or agencies 
National Identification Number; passport number; tax identification number or driver’s or other license number.

  • Financial information and account details 
Bank account or other financial account number and account details; and other financial information.

  • Other sensitive information 
In certain cases, we may receive sensitive information about you for example, if you apply for insurance through a third-party marketing partner that is a professional, trade, political, religious or community organization.  In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud.  We may also obtain Sensitive Personal Data if you voluntarily provide it to us (for example, if you express preferences regarding medical treatment based on your religious beliefs).

  • Telephone recordings 
Recordings of telephone calls to our representatives and call centers.

  • Photographs and video recordings 
Photographs or video recordings created in connection with our insurance or other business activities, including for claims assessment, processing, settlement, and disputes, or for other relevant purposes as permitted by law.

  • Information to investigate or prevent crime, including fraud and money laundering:
For example, insurers commonly share information about their previous dealings with policyholders and claimants for this purpose.

  • Information enabling us to provide products and services 
Location and identification of property insured (for example, property address, vehicle license plate or identification number); travel plans; age categories of individuals you wish to insure; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organization; other insurance you hold; and details on products for which you have or seek a warranty.

  • Marketing preferences, customer feedback and survey responses
    You may let us know your marketing preferences, enter a contest or prize draw or other sales promotion, or respond to a voluntary survey.



  • Social media account and information from Apps
    We may receive certain Personal Data about you when you use our Apps or Social Media Pages, including your social media account ID and profile picture.  If you elect to connect any of your other social media accounts to your account(s), Personal Data from your other social media account(s) will be shared with us, which may include Personal Data that is part of you profile relating to those accounts or your friends’ profiles.



  • Information from Other Sources
    We and our service providers may supplement the Personal Data we collect with information from other sources, such as publicly available information from social media services, commercially available sources and information from our affiliates or business partners.

    Other Information We Collect Through our On-line Services  
    “Other Information” is any information that does not reveal your specific identity, such as :



  • Browser and device information.

  • App usage data.

  • Information collected through cookies, pixel tags and other technologies.

  • Demographic information and other information provided by you; and

  • Aggregated information

    How We Collect Other Information


    We and our third-party service providers may collect Other Information, including Personal Data in a variety of ways, including:



  • Through your browser or device:   Certain information is collected by most websites or automatically through your 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, device manufacturer and model, language, internet browser type and version, time of the visit, page(s) visited and the name and version of the our On-line Services (such as the App) you are using.  We use this Personal Data to ensure that our On-line Services function properly. 

  • Using cookies; online tracking: 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 on our On-line Services, pages visited, language preferences, country website preference. We may use the information for security purposes, to facilitate navigation, to display information more effectively, or to personalize your experience while using our On-line Services. In addition, we may use the information to gather statistical information about the usage of our On-line 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. We do not respond to browser do-not-track signals at this time.

Third parties may collect information about your use of our On-line Services and your use of other websites or online services.

Below is a description of some of the cookies we may use on the Site, what they do, what data about you they collect and what we may use them for: 

  • Geo Location cookie – When a visitor visits the Site 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 a cookie to store this information and to store the language that they chose to view the site. The next time they visit the Site we read the cookie and present the same country and language version they used on their last visit. This has the intended benefit that they don’t need to reselect the country site they need each time they visit our site.  No Personal Data is collected or used by the cookie.

  • Site Catalyst cookie (by Adobe) – This cookie enables us to collect and analyze data about how visitors arrive at the Site and then how they interact with the Site, including products they may search, content they may view, and the steps leading up to a completed or abandoned sale.  We use this aggregated information to adapt the Site to better serve their and other users’ needs and interests, and to provide more relevant and useful information. The cookie is placed on a visitor’s PC on a temporary basis only.  The cookie does not collect or use their Personal Data. Instead, it logs an anonymous code which identifies users and this code “follows” the user in their journey through the Site.  We use the aggregated and anonymous information for statistical analysis.

  • DoubleClick cookies - We place a tracking pixel cookie on to all Site visitors’ computers for the purpose of our banner advertising activity. We use these cookies to know that a visitor has been on the Site before which allows us to display an appropriate banner ad on to an affiliated network website. No Personal Data is collected.  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 cookie – We use a tracking pixel cookie, which is put on a visitor’s PC and collects only the transaction ID (which identifies the affiliated website the visitor has come from) and a time and date stamp.  This enables our affiliate network partners to track affiliated sales and ensure an affiliate is credited for a sale referred to us. It does not involve any passing of Personal Data.

    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.

  • Using pixel tags, web beacons, clear GIFs or other similar technologies: These may be used in connection with some of our On-line Services and HTML-formatted e-mail messages to, among other things, track the actions of users of our On-line Services and e-mail recipients across the devices they use, measure the success of our marketing campaigns and compile statistics about usage of our On-line Services and response rates. In some instances, we may combine information collected through these technologies with your Personal Data. We may use interest-based advertising service providers to customize, target, serve and report on our 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 our On-line Services and third-party sites and mobile applications.  They may also use these technologies, along with information they collect about your online use, to recognize 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 our advertisements to you across the web, based on your IP address.  If you would like to opt out of having your information used for these purposes, visit the self-regulatory program opt-out pages at www.aboutads.info/choices/ or www.networkadvertising.org/managing/opt_out.asp to opt out in desktop and mobile web browsers on the particular device from which you access the opt-out options.  Download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile applications.

  • Using your Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. 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 purposes of providing travel or other assistance services to our clients who are enrolled in such services.  In connection with providing travel or other assistance services, and for purposes of developing and improving our actuarial and pricing tools and risk management programs for our commercial insurance clients, we may share your device’s precise geolocation information with our insurance clients and other entities with whom we work to provide our products and services.  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.

  • 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 Data, this information does not personally identify you. 

  • By aggregating information: We may aggregate and use certain information (for example, we may aggregate information to calculate the percentage of our users who have a particular telephone area code).
    Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Data under applicable law, or if we combine Other Information with Personal Data, then, in addition to the uses listed in the “ Other Information We Collect ” section above, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Data.




  1. CONDITION FOR PROCESSING PERSONAL DATA:


    
Unitrust Insurance Co. Ltd. or any third party acting on its behalf shall only process your personal data if at least one of these conditions are met:



  • Consent: this refers to any freely given, specific, informed and unambiguous indication through a statement or a clear affirmative action that signifies your agreement to the processing of your Personal Data by us. We shall not seek consent that may engender direct or indirect propagation of atrocities, hate, criminal acts and anti-social conducts.

  • Contract: processing is necessary for the performance of a contract or entering a contract at your request.

  • Legal obligation: processing is necessary for compliance with a legal obligation to which Bank of Industry is subject.

  • 
 Vital interest: processing is necessary to protect your vital interests or those of another natural person.

  • Public interest: processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Bank of Industry.




  1. HOW WE USE YOUR PERSONAL DATA



    To the extent permissible under applicable law, we may use your information for the following legitimate actions:



  • Communicate with you and others as part of our business.

  • Respond to your requests.

  • Send you important information regarding changes to our policies, other terms and conditions, our On-line Services and other administrative information.

  • Make decisions about whether to provide insurance and assistance services, and other products and services which we offer, and provide such products and services, including claim assessment, processing and settlement; and, where applicable, manage claim disputes.

  • Assess your eligibility for payment plans and process your premium and other payments.

  • Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers).

  • Prevent, detect and investigate crime, including fraud and money laundering, and analyze and manage other commercial risks.

  • Carry out research and analysis, including analysis of our customer base and other individuals whose Personal Data we collect as explained in this Privacy Policy.

  • Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed.

  • Personalize your experience when using our On-line Services or visiting third-party websites by presenting information and advertisements tailored to you.

  • Identify you to anyone to whom you send messages through any of the On-line Services.

  • Allow you to participate in contests, prize draws and similar promotions, and to administer these activities. Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your Personal Data, so we suggest that you read these carefully.

  • Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; data analytics; business continuity; and records, document and print management.

  • Resolve complaints, and handle requests for data access or correction.

  • Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering, sanctions and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence).

  • Establish and defend legal rights; protect our operations or those of any of our group companies or business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.




  1. USER RIGHT


    You have rights when it comes to our handling of your Personal Data. Those rights include:



  • the right to request for access to your Personal Data where those requests are reasonable and permitted by law or regulation. Unitrust shall provide reasonable and accessible means for you to submit your requests, which do not have to take any specific form and can be submitted by any method. We may make a reasonable charge for additional copies of that data in the case of unfounded and excessive requests.

  • the right to request that Unitrust erase your Personal Data if it is no longer valid or necessary for the purposes for which it was collected or if it is incomplete.

  • the right to rectify or amend inaccurate or incomplete Personal Data.

  • the right to withdraw your Consent at any time. This can be initiated by contacting Unitrust.

  • the right to object to Unitrust processing of your Personal Data if there are compelling legitimate grounds to do so and to the extent permitted by law or regulation. For example, you have the right to object to Unitrust processing of your Personal Data for direct marketing purposes.

  • the right to receive your Personal Data in a commonly used and machine-readable format and the right to transmit these data to another Data Controller when the processing is based on (explicit) consent or when the processing is necessary for the performance of a contract.

  • the right to lodge a complaint with the National Information Technology Development Agency (NITDA) where you believe our processing of your data violates the requirements of the Nigeria Data Protection Regulation 2019 (NDPR).

    The contact details are:
    National Information Technology Development Agency
    Tel: +234929220263, +2348168401851, +2347052420189
    Email: info@nitda.gov.ng
    Website: www.nitda.gov.ng
    Where we do not act on your request to exercise any of your rights, we shall inform you within one month of the receipt of your request, of the reasons for not taking action and on the possibility of lodging a complaint with NITDA.




  1.  DATA COLLECTION METHODS






  • Electronic Messages: We keep record of your interactions with us via electronic media (such as email, online complaint forms etc.) in a secure manner while maintaining accuracy. When necessitated by legal or vital obligations, we archive these communications.

  • Hard Copy Forms: We maintain accurate records of the information that you provide to us via hard copy forms in a secure manner. When necessitated by legal or vital obligations, we archive these communications.

  • Web Forms: We keep record of your personal details provided via our web portal. 




  1. SHARING OF PERSONAL DATA


    Unitrust may make Personal Data available to:



  • Other insurance and distribution parties 
In the course of marketing and providing insurance and processing claims, we may make Personal Data available to third parties such as other insurers; reinsurers; insurance and reinsurance brokers and other intermediaries and agents; appointed representatives; distributors; affinity marketing partners; and financial institutions, securities firms and other business partners.

  • Our service providers
External third-party service providers, such as, accountants, auditors, experts, lawyers; IT systems, support and hosting service providers, marketing and market research and analysis service providers; banks and financial institutions that service our accounts; third-party claim administrators; document and records management providers; similar third-party vendors and outsourced service providers that assist us in carrying out business activities.

  • Providers of Internet-connected devices and associated software
We may make the Personal Data you provide to us via our Apps available to providers of Internet-connected devices and/or associated operating systems and/or software as set forth in the terms of use and/or privacy policies you agree to with those providers

  • Governmental authorities and third parties involved in court action 
We may also share Personal Data with governmental or other public authorities (including, but not limited to, courts, law enforcement agencies, tax authorities); as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, you or others; and (g) to allow us to pursue available remedies or limit our damages.

    Should you prefer, we will not disclose Personal Data about you to non-affiliated third parties. You may opt out of those disclosures; that is, you may direct us not to make those disclosures (other than disclosures required or permitted by law). Should you wish to opt out of disclosures to non-affiliated third parties you may contact us by e-mail at (info@unitrustinsurance.com) or by writing to:

    Unitrust Insurance Company Limited
    Attn: Legal/Compliance/Data Protection Officer
    Address: 105b, Ajose Adeogun Street,
 Victoria Island, 
Lagos, Nigeria.
    info@unitrustinsurance.com
    01-4617031-2,2701167-9




  1. PERSONAL DATA OF OTHER INDIVIDUALS  


    If you provide Personal Data to us regarding other individuals, you agree: (a) to inform the individual about the content of this Privacy Policy, and any other applicable Privacy Notice provided to you; and (b) to obtain any legally-required consent of Personal Data about the individual in accordance with this Privacy Policy and other Privacy Notice




  1.  MARKETING PREFERENCES  


    We will provide you with regular opportunities to tell us your marketing preferences, including in our communications to you. You can also contact us by e-mail at(info@unitrustinsurance.com) or by writing to:

    Unitrust Insurance Company Limited
    Attn: Legal/Compliance/Data Protection Officer
    Address: 105b, Ajose Adeogun Street,
 Victoria Island, 
Lagos, Nigeria.
    info@unitrustinsurance.com
    01-4617031-2,2701167-9

    to tell us your marketing preferences and to opt out.

If you no longer want to receive marketing-related e-mails from us on a going-forward basis, you may opt out of receiving these marketing-related emails by clicking on the link to “unsubscribe” provided in each e-mail or by contacting us at the above addresses. We will endeavor to comply with your opt-out request(s) within a reasonable time period. Please note that if you opt out as described above, we will not be able to remove your Personal Data from the databases of third parties with whom we have already shared your Personal Data (i.e., to those to whom we have already provided your Personal Data 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 administrative communications from which you cannot opt out.




  1. THIRD PARTY PRIVACY PRACTICES  


    This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which our On-line Services link.  The inclusion of a link on our On-line Services does not imply endorsement of the linked site or service by us or by our group companies.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other software application developer or provider, social media platform, operating system or wireless service provider, or device manufacturer, including any Personal Data you disclose to other organizations through or in connection with the Apps or our Social Media Pages.




  1. USE OF SERVICES BY MINORS  


    Our On-line Services are not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Data through our On-line Services.




  1. TRANSFER OF PERSONAL DATA



    Personal Data collected by us may be transferred among its various divisions (with personnel who have business need to know). The following describes the various scenarios for which we may share your Personal Data to a third party:



  • Transfer as a legal requirement: We may share your information with other parties when required by law or as necessary to protect our service.

  • Out of Country Transfer: Your Personal Data is stored in Nigeria. However, it may be transferred to a foreign country for storage where it is necessary to do so in line with the permissible conditions defined by the NDPR. We will ensure that appropriate safeguards are in place to ensure the protection of your Personal Data being stored out of the country




  1. HOW WE ENSURE PROTECTION OF YOUR PERSONAL DATA



    We have implemented appropriate organizational and technical measures (including physical access controls and secure software and operating environments) to keep your Personal Data confidential and secure. Please note, however, that these protections do not apply to information you choose to share in public areas such as third-party social networks.


    Data Retention Policy: We ensure that your Personal Data are not retained for longer than necessary, and in any case until the purpose of collection the data is achieved, subject to any requirements to retain information otherwise, in order to comply with any applicable law, regulation, professional requirements or standards

    Personal Data Breach Notification: Unitrust will inform relevant authorities and if necessary affected individuals of Personal Data breach within 72 hours of being aware of the breach, where Personal Breach refers to a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data. This includes breaches that are the result of both accidental and deliberate causes


  2. POLICY UPDATES



    If we change the way We handle your Personal Data, we will update this Notice. We reserve the right to make changes to our practices and this Notice at any time, please check
back frequently to see any updates or changes to our Notice.



  3. PRIVACY POLICY COMPLAINTS AND ENQUIRES



    If you have any questions or complaints about our Privacy Policy, please contact us at:

    Unitrust Insurance Company Limited
    Attn: Legal/Compliance/Data Protection Officer
    Address: 105b, Ajose Adeogun Street,
 Victoria Island, 
Lagos, Nigeria.
    info@unitrustinsurance.com
    01-4617031-2,2701167-9

    By signing below, I acknowledge that I have fully read and understood my rights as a data subject. I understand that if I have any questions or concerns about this policy, it is my
responsibility to contact the Data Protection Officer.

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