Enterprise Life Insurance Privacy Policy

We Care About Your Personal Data

At Enterprise Life, we are dedicated to your privacy. We value your trust in us and our services, and our promise to you is to work towards retaining the confidence you have reposed in us.  Our commitment to protecting your privacy is reflected in this Privacy Policy, which describes our practices in using, gathering, communicating, and protecting information about you. Be assured that we remain bound by this policy while you are insured under our policy offerings and anytime thereafter, as long as we remain in possession of your personal data. This policy applies to our website, products, and services we may offer you.

This privacy notice applies to any information obtained by us through your use of this website. It does not apply to any websites controlled by third parties not affiliated with us or our business but linked to this website (“third-party sites”). Please review the privacy statement of third-party sites as we would not be responsible for, neither do we have influence over the content or the privacy practices of third-party sites.

The terms of this privacy notice are subject to any additional terms, disclaimers or other contractual terms you have entered into with us such as client privacy statements or notices, and any applicable mandatory laws and regulations. Please take a moment to study and familiarize yourself with this policy and should you have questions, do not hesitate to contact us. Where any of the procedures outlined in this policy are unacceptable to you, please refrain from proceeding. However, we would be happy to entertain your queries, suggestions and requests for clarification.

This privacy notice would be updated from time to time as our processes evolve and change. Updates would also be added to reflect change in government regulations, new technologies, or other developments in data protection laws or privacy generally. Please do check this website for updates on a regular basis.

What Personal Data would be Collected

For the purpose of this privacy policy, personal data includes all the information we hold or collect on our employees, customers, stakeholders, vendors, marketers and other interested parties, whether directly or indirectly and includes any offline or online data that identifies a person such as; name, identification number, location data, an online identifier, physical, physiological, genetic, mental, economic, cultural or social identity. 

To facilitate our service delivery to you, and improve customer experience, we collect the following personal data from you:

1. Information supplied by you: Note that the data we collect constitute in the most part of information you have supplied to us. We collect information that you give to us when you create an account with us, request for further information about our product, fill a form, apply for a job through our website or you subscribe to newsletters on our website.  Such information includes the following: Name, Address, Gender, Contact Details, Company Name, Business or Profession, Shareholder Number and others. Whether in the course of registration, subscription to our insurance policy offerings or use of this platform, the purpose for which we collect your data is never shrouded in secrecy.

We receive information from you on applications for insurance and relevant onboarding forms to facilitate service delivery. We also receive information from other sources, including eligibility listings from employers, government agencies, schools and providers of administrative services, as the case may be. In this regard, we may receive your name, address, identification number, phone number, marital status, your dependents, financial information, and (as applicable) your academic enrollment status or employment details and benefits coverage information.

We may also receive information regarding existing life insurance coverage. We also receive information from you and others regarding premium payments. This information may include, among other things, credit card numbers, bank account numbers, and other information relating to premium payments you make. We receive information about you in connection with coverage claims from third parties providing benefits and services under your coverage, including providers of medical services and claims administrators. This information may include, among other things, medical record information.

• Information Collected Automatically: Through the use of cookies and other technologies, we also automatically collect digital information from your use and interaction on this platform. Note that the digital information we collect automatically is strictly to improve your experience, and to help us develop our product offerings. Please review our cookie policy

When you visit our website, our web server automatically records details about your visit including your; IP address, the website from which you visited us, the type of browser software used, our website pages that you visit; and the date and duration of your visit to the website.

The Privacy of Children

We respect the privacy of children. We are dedicated to protection of their rights as provided by the Constitution of the Federal Republic of Nigeria 1999, the Childs Right Act 2003 and the Nigerian Data Protection Regulations 2019. We do not deliberately obtain the personal data of children including; name and email address except it is necessary to register them as beneficiaries to a policy or other products. Accordingly, we would not deliberately market or allow children under 18 to purchase our products.

How Will We Use Your Personal Data?

Note that we only collect your personal data in line with practices detailed in this policy. The data collected is used to facilitate our services to you, provide your insurance policy and other services to you. This may include assessing your application for a policy, setting up your account as a policy holder, administering and managing your insurance policy and benefits, handling and paying claims to you or your beneficiaries etc. Other reasons include;

1. for technical administration, research and development of our website;
2. for customer and user administration and marketing;
3. to maintain business relationships;
4. to conduct research and analysis with regard to our business relations;
5. to inform you about our events, services, products and news when you visit the Enterprise Life Website or when you subscribe to our newsletter or mailing lists;
6. to facilitate compliance with securities law, public company listing requirements and related laws and regulations;
7. for fraud prevention and detection;
8. to comply with legal obligations such as when our regulators including the National Insurance Commission (NAICOM), the Securities and Exchange Commission (SEC), the National Health Insurance Scheme (NHIS) direct us to provide records of you in our possession.
9. to efficiently manage and store your data, we may engage a cloud data service within or outside Nigeria.
10. to protect your vital interest, we may process your medical data in our possession, in circumstances of life and death.

For the purposes indicated above, we will process personal data we receive about you from public and commercial databases. We will inform you where we require your consent to process your personal data. Otherwise, we will process your personal data to meet our legitimate business interests (including maintaining contact with clients, providing updates and information about Enterprise Life, organizing and hosting events, and conducting market research and analysis) or where it is needed to comply with a legal obligation. In addition, we may also process your personal data to enter into a contract with you, or to perform our obligations under an existing contract with you. We will respect applicable laws and regulations in our collection, storage, use and application of personal data.

Are Cookies Used on this Website? Please see our Cookie Policy

Our website uses tracking technology such as cookies or tags to gather information as outlined above to understand how visitors use the website. Tracking technology helps us manage and improve the usability of the website, for example, by detecting whether there has been any contact between your computer and us in the past, and to identify the most popular sections of the website. When you save your cookie settings, they should also apply to your future visits to the website. However, for technical reasons beyond our control, this cannot be guaranteed. For example, if you reset your browser, delete your cookies, or access the website from another browser or device, your cookie settings may be lost. To comply with applicable laws and regulations, in some countries you may be asked to confirm your cookie settings when you first visit the website. If you are in a country where you are automatically required to set your cookie settings, you may be asked to set them again on a future visit.

In many cases you can also control tracking technologies using your browser. Please ensure that your browser setting reflects whether you wish to be warned about and/or accept tracking technologies (such as cookies) where possible. The specific capabilities of your browser and instructions on how to use them can usually be found in the manual or help file of your browser. Refusing, disabling or deactivating tracking technologies may result in a reduced availability of the services provided by the website, or parts of the website may no longer function correctly.

Who do we Share your Data With?

We may share your personal data with other members of the Enterprise Life Group, or other third-party processors/controllers outside the group. We reiterate that we would not process or share your information other than as described in this policy, and to effect service delivery to you. Where we share your data, it would be kept strictly confidential, and processors would be under strict obligations to ensure the safety and integrity of your data in compliance with the Nigerian Data Protection Regulations (NDPR).

1. Data Sharing Within the Enterprise Life Group: To provide services to you, and ensure the quality-of-service delivery, we share data with other members of the Enterprise Life Group. Note that data shared in this regard is necessary to deliver value to you.
2. Data Sharing Outside the Enterprise Life Group (Third Parties): We would disclose to third parties only data necessary to facilitate our service delivery to you. We would also make disclosures when we are under legal obligation to, and to third parties which you have named as your next of kin or alternative contact when you are incapacitated. We share information with our third-party services providers such as IT suppliers, actuaries, auditors, lawyers, marketing agencies, research specialists, document management providers and tax advisers. Our pledge is that at all times we share or disclose your information to third parties, we would ensure and insist on the highest degree of respect to your privacy. Note that we do not share or give personal data obtained from you and in our possession to third parties except as stipulated in this policy. We also do not trade your data to third parties for data mining or marketing purposes.

How are Social Media Plug-ins Used on our Website?

Our Website uses the following social media plug-ins ("plug-ins"):

• Share button on Facebook, powered by Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA;
• Tweet button, powered by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA;
• Button Xing, operated by XING AG, Gänsemarkt 43, 20354 Hamburg, Germany;
• Share Button on LinkedIn, operated by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, United States.

All plug-ins are indicated with the brand names of the respective operators Facebook, Google, Twitter, Xing and LinkedIn ("Operator"). To increase the level of data protection and in accordance with applicable laws and regulations, we have implemented the additional programs by means of a so-called 2-click solution. This procedure ensures that when you visit our website, no direct connection of your browser to the servers of the Operator is established. Only if you activate the plug-ins by clicking on them and thereby grant your consent to the data transfer, your browser establishes a direct connection to the server of the respective Operator. The content of the plug-ins is then transmitted by the Operators directly to your browser and integrated by them into the website.

By accepting the plug-in, the Operator receives the information that your browser has accessed our website. If you logged in to your account when you visited our website, the Operator can connect your visit to your account directly. If you interact with the plug-in, e.g. by clicking on the Facebook button, the +1 button and the Tweet button or the LinkedIn "Share" button, the data will be transferred directly from your browser to the Operator and saved by the Operator. In addition, the information will be published on the relevant social network or on your Twitter account and will be visible to your contacts. If you do not want this data transfer to the Operators, you must log out of your respective account before you click on the plug-ins and activate them. XING AG uses your data only to offer the shared functions (e.g. calculation / counter display) and not to store your personal data or to evaluate your user behaviour.

For more information on the purpose and scope of data collection, processing and use, please refer to the privacy statements below:

Facebook: https://de-de.facebook.com/about/privacy/
Google: https://developers.google.com/+/web/buttons-policy
Twitter: https://twitter.com/privacy
XINGAG: https://www.xing.com/app/share?op=data_protection
LinkedIn: https://www.linkedin.com/legal/privacy-policy

What are your Rights in Respect of your Personal Data?

The law guarantees your right to privacy and puts a burden on us to secure your personal data to the highest standards possible. Accordingly, you have the following rights-

1. We shall take appropriate measures to provide any information relating to processing of your data in a concise, transparent, intelligible and easily accessible form, using clear and plain language. The information shall be provided in writing, or other means, including, where appropriate, by electronic means.
2.  Where we do not act on your request for information, we shall inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action.
3. Except as otherwise provided by any public policy or Regulation, information provided to you, any communication and any actions taken shall be provided free of charge. Where requests from you are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: a) Charge a reasonable fee considering the administrative costs of providing the information or communication or taking the action requested or, b) communicate our refusal to act on the request to you.
4. Where necessary we may request the provision of additional information necessary to confirm your identity from you.
5. You have the right to request us to delete your personal data without delay, and we shall oblige where-
6. Retaining your personal data is no longer necessary in relation to the purposes for which they were collected or processed;
7. You withdraw your consent on the purpose for which the processing is based.
8. You object to the processing and there are no overriding legitimate grounds for the processing;
9. Your personal data has been unlawfully processed; and
10. Your personal information must be erased for compliance with a legal obligation.

What Security Measures have we Implemented to Protect your Data Collected Through our Website?

We have implemented reasonable technical and organizational security measures to protect your personal data and keep it safe. We have in place appropriate security standards and policies to ensure that your data is only exposed to our staff and third parties on a need-to-know basis. We process and retain possession of your data only for the minimum period required by law, until it is no longer required by us. We take steps to destroy the data in a safe and secure manner.

All electronic messages sent to and from us are protected by reasonable technical and organizational measures and may only be accessed in justified cases in line with applicable laws and regulations (e.g. court order, suspicion of criminal conduct, violation of regulatory obligations) to specific persons in defined functions (e.g. Legal, Compliance, Risk). Every step of the process, as well as the search criteria used, are logged in an audit trail. All emails are disposed of after the applicable retention period has expired.

How Long is Your Personal Data Retained For?

We will not retain your personal data for longer than is necessary and we will hold it only for the purposes for which it was obtained in compliance with the law and relevant data protection and privacy regulations.

Governing Law

This Privacy Policy is made pursuant to the Nigeria Data Protection Regulation (2019) and other relevant Nigerian laws, regulations or international conventions applicable to Nigeria. Where any provision of this Policy is deemed inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation or convention.

How Can You Contact Us?

If you have any queries or complaint about how we use your personal data, you can contact us by post or email via the details specified below:

• Enterprise Life Nigeria
• 46-48 Awolowo Road Ikoyi
• Lagos, Nigeria
• privacy.lifeng@myenterprisegroup.io

Updates

We regularly review this privacy notice. We will ensure the most up-to-date version is published here.

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