Privacy Policy
الرئيسية Privacy Policy
INTRODUCTION
Tokio Marine General Takaful S.A.E, (referred to as “we”, “us”, “our” or “TMGT” in this Data Privacy Notice) primarily refers to all the Personal Data that is collected and used about TMGT Customers for the purposes of the Consumer Protection Regulations and Standards and the Egyptian Personal Data Protection Law. TMGT is part of the Tokio Marine Holdings Group.
TMGT is registered in 51 Beirut St. Heliopolis, Cairo, Egypt. PO box 11341
This Data Privacy Notice, herein referred to as the “Notice”, describes the types of Personal Data TMGT collects, how this data is used, stored and shared, and your choices regarding this data. TMGT is the Data Controller for the Personal Data collected in connection with the use of TMGT Services.
SCOPE
This Notice applies to all Customers of TMGT Services, including Customers of TMGT’s mobile application, websites, branches, call centers, and any other Insurance Services (collectively, the “Services”) and through other interactions and communications you may have with us. This Notice specifically applies to:
- Consumers/Customers;
- Personal Data collected/received by TMGT through and in connection with the various Services provided.
TMGT is committed to providing you with exceptional Insurance Services and want you to have confidence in the way TMGT use your Personal Data. TMGT is committed to protecting your privacy and your Personal Data.
Further this Notice explains the various measures TMGT have in place to protect the security of your Personal Data and minimize the potential for its unauthorized use, disclosure, and destruction.
YOUR DATA PRIVACY JOURNEY WITH US
TMGT may act as a “Data Controller” or a “Data Processor” in relation to your Personal Data.
Who is a Data Controller? TMGT will act as a Data Controller when processing your Personal Data. A Data Controller is an entity who solely, or jointly with others, determines the purposes (“why”) and means (“how”) of Personal Data Processing. In most cases, TMGT will act as the Data Controller when Processing your Personal Data – this means TMGT will decide on how to collect, process, and use Personal Data in this role.
Who is a Data Processor? In some other cases, TMGT will act as a Data Processor when Processing your Personal Data on behalf of another TMHD Group entity or TMGT client entity. In these cases, TMGT will perform the Processing of the Personal Data under the specific instructions from the TMHD Group entity or TMGT client entity acting as the Controller.
If you have any questions about how TMGT use your Personal Data, you can contact us by using the “Contact Us” information at the end of this Notice.
CONFIDENTIALITY OF PERSONAL DATA
When TMGT collects Personal Data, TMGT provides a safe, secure, and confidential environment in all our delivery channels to ensure that your Personal Data remains private and used for the purposes for which it is obtained and held.
TMGT has a legal obligation to keep your data confidential, however, TMGT may disclose your data to a third party where:
- TMGT is legally obliged to do so. In circumstances where the disclosure of your data is imposed by a legal and/or regulatory authority, including but not limited to FRA,& courts.
- In circumstances where the disclosure is made with your express consent or through a representative nominated by you.
UNDERSTANDING PERSONAL DATA AND PROCESSING
Personal Data and Processing have specific meanings under EGYPT Applicable Laws. It is important that you understand these terms.
What is Personal Data?
Personal Data as per the Applicable Laws means, any data which relates to a living individual who can be identified directly or indirectly from that data. The definition includes a wide range of personal identifiers that constitute Personal Data, including but not limited to:
- Identification information (e.g., name, date of birth, government-issued National ID)
- Contact information (e.g., address, email address, phone number)
- Financial information (e.g., account numbers, transaction history)
- Employment information (e.g., occupation, employer)
Demographic information (e.g., gender, marital status)
What is Processing?
Processing means any action taken on Personal Data, e.g. viewing, collecting, using, storing, sharing, manipulating, printing, copying, archiving etc.
PERSONAL DATA TMGT COLLECTS ABOUT YOU
Personal Data That You Provide To Us
TMGT collects Personal Data directly from you as our Customer or Prospective Customer. or through Insurance Brokerage firms or freelance brokers. TMGT collects information you provide directly to us through your access or use of TMGT Products and Services. For example, when you apply for a product or Service on our website(s), by telephone or when you enter TMGT premises and share/provide Personal Date with one of TMGT’s employees or provide such information to Insurance Brokers who deals with us.
Personal Data TMGT Collects About You From Other Sources
TMGT may collect Personal Data about you from other sources such as, but not limited to the following:
- Insurance Brokers (Firms or Freelancers)
- Representative(s) of a corporate client.
- Legal representatives (power of attorney) of a client.
- People appointed to act on your behalf.
- Other TMHD Group entities, including their Branches, Subsidiaries, etc.
- Other Financial Institutions.
- Your employer.
- Digital identity solutions.
- Government databases.
- Law enforcement officials.
- Regulatory bodies such as FRA, etc.
- Co-insurers.
- Criminal records check from organizations authorized to provide this data.
- Clients who nominate you as a Beneficiary in an insurance policy or other services.
- Nominated contact person by an existing client.
- Third party providers and partners to help us improve the Personal Data TMGT hold and to provide more relevant and interesting products and Services to you.
- Reference contacts provided in the application form by you.
- Publicly available sources.
Personal Data TMGT May Collect About Other Individuals
In certain circumstances, TMGT may be provided Personal Data by you about individuals who do not have a direct relationship with us. This may happen, for instance, when you provide us with Personal Data about:
- Beneficiaries for your insurance policies.
- Employers of TMGT Customers.
- Legal representatives (power of attorney) of a client.
- Next of Kin.
- Reference contacts provided in the application Representative(s) of a corporate client.
- Shareholder(s)/Director(s) of a corporate client.
- Spouses.
- Successors and right holders.
- Reference contacts requested at the time of availing Services from the Company.
- Ultimate beneficial owners.
- Form by a TMGT (prospective) Customer.
- Contact persons details.
- USE OF YOUR PERSONAL DATA
- Personal Data includes information that TMGT collect and process about you depending on the products or Services you obtain or receive.
- Below is a non-exhaustive list which highlights some, but not all, examples of categories of Personal Data TMGT collect about you:
| Category | Description | Example | Lawful Basis |
|---|---|---|---|
| Account Management | Used to administer your account with TMGT. Used to identify you when you sign in to your account. Used to provide you with Services, and to fulfil your requests for certain products and Services, such as issuance of Insurance policies etc. | To enable TMGT to process your data for the sole purpose of administering your relationship with the Company. | Consent Performance of Contract |
| Account Opening | Used for the setup and management of Customer accounts, including meeting the regulatory requirements such as KYC (Know Your Customer) process. | To enable Customers to create an Account, log in to your instance on the TMGT App, or verify their credentials. | Consent Legal obligation |
| Analytics | Used to collect data about how Customers use the TMGT App or website or how it performs. Used to understand how you use and interact with our Services and the people or things you’re connected to and interested in. | To see how many Customers are using a particular gesture, to monitor app health, to diagnose and fix bugs or crashes, or to make future performance improvements. | Consent |
| App Functionality | Used for Features that are Available on the website or App. Used to improve the design and functionality of TMGT channels for better Customer experience. | To enable app features, or to authenticate Customer. | Consent |
| Decline Onboarding | If your application is declined, TMGT will store your Personal Data in accordance with the TMGT record retention procedures and comply with TMGT legal and regulatory obligations. | To keep track of the reasons for the declining of Onboarding to be used as reference, if and when the Customer approaches the Company again. | Consent Legitimate interest |
| Developer Communications | Used to send news or notifications about the website, app or the developer. | Sending a push notification to inform Customers about an important security update. | Consent |
| Financial Mediations / Debt Recovery | Used to authorize debt Service partners to carry out collection activities on TMGT behalf. Used to recover past due payments and exercise other rights TMGT have under any agreement with TMGT Customers as well as to protect TMGT against harm to TMGT rights and interests in property. | Partners of TMGT engage with Customers / other natural or legal persons who have defaulted, to settle their liabilities with TMGT, or caused the incident which is covered by our products. | Consent Legitimate interest |
| Fraud Prevention, Security and Compliance | Used for fraud prevention, security, or compliance with laws. Used to prevent and detect fraud, money laundering and other crimes such as identity theft. | Monitoring failed login attempts, geolocations, device information (e.g., model number, OS information), IP address, etc., to identify possible fraudulent activity. | Consent Legal obligation Legitimate interest |
| General Correspondence | Personal Data you give to us by filling in any of TMGT forms or by communicating with us, whether face-to-face, by phone, email, online or otherwise. | To contact you if you have asked us to do so including to resolve troubleshooting problems and helping with any issues concerning TMGT website or apps. | Consent |
| Personalized Commercial and Promotional Communications (Marketing) | To send commercial and promotional communications through telematic or conventional means, in relation to similar goods and Services than the ones previously contracted or acquired from TMGT. This also includes for the purpose of conducting market research and accompanying statistical analysis to better understand our Customer base and the markets in which we operate. | TMGT sends Customers a promotional email or SMS relating to a Product or Service on offer. | Consent Legitimate Interest |
| Regulatory Requests | To handle requests and instructions from regulators, law enforcement Agencies, etc. that require specific information about individuals. | To meet the legal and regulatory obligations TMGT has, as a Licensed Financial Institution, governed by the FRA. | Consent Legal Obligation |
| Satisfaction Surveys | To contact you for your opinions about TMGT Services including through surveys and other market research. | Sending Customer satisfaction surveys. | Consent Legitimate Interest |
| Service Communications | Used to keep Customers informed of the products and Services they are availing of. Used to tell you about important updates and changes to TMGT channels, including to TMGT Notice and other Policies and Terms. | Sending Customers reminders to update their Personal Data in the App such as their mobile number and home address. | Consent |
| Video Protection (CCTV) | Used at TMGT premises for security purposes. | To protect TMGT Customers, employees, visitors, and its premises. | Legitimate Interest |
DISCLOSURE OF YOUR PERSONAL DATA BY US
TMGT only discloses your Personal Data outside of TMGT in limited circumstances. Third parties for the purpose of this section would mean any entity separate from TMGT, such as third party service providers, business partners, regulatory authorities, etc. If TMGT does share the Personal Data outside of TMGT, we will put in place appropriate controls and data sharing/processing agreements that require recipients to protect your Personal Data, unless TMGT is legally obliged to share that Personal Data. All contractors or recipients that work for TMGT will be contractually obligated to follow TMGT instructions. TMGT does not sell your Personal Data to third parties.
TMGT may disclose your Personal Data to TMGT third-party Service providers, agents, and subcontractors (Suppliers) for the purposes of providing Services to us or directly to you on TMGT’s behalf within and outside EGYPT.
When TMGT uses Suppliers, TMGT only discloses to them the Personal Data that is necessary to provide their Services and only where TMGT has a contract in place which requires them to keep your Personal Data secure and not to use it other than in accordance with TMGT’s specific instructions.
TMGT takes steps to ensure that any third-party service providers who handle your Personal Data comply with the Applicable Laws and protect your Personal Data to the same extent that TMGT does. TMGT will aim to anonymize your Personal Data or use aggregated non-specific data sets where possible. Find below the supporting Schedule with a list of categories of third parties with whom TMGT may share your data.
All sharing of Personal Data with third parties shall be based on the consent from you, unless obliged to do so, to comply with the Applicable laws and other legal and regulatory requirements.
| Category of Third Party | Description of Service Provided | Lawful Basis of Processing |
|---|---|---|
| TMHD Group Entities | TMGT may share your Personal Data with companies within the TMHD Group who may support us in any of the purposes set out in this Notice to improve and enhance the Customer experience. | Consent |
| Analytics Providers | TMGT may share your Personal Data with analytics providers that assist us in the optimization of TMGT website and apps including by measuring the performance of TMGT online campaigns and analyzing visitor activity. | Consent |
| Asset Purchasers | TMGT may share your Personal Data with any third party that purchases, or to which TMGT transfers, all or substantially all of TMGT assets and business. Should such a sale or transfer occur, TMGT will engage best efforts to try to ensure that the entity to which TMGT transfers your Personal Data uses it in a manner that is consistent with this Notice. | Consent |
| Re- Insurance | TMGT may share your Personal Data with Re- Insurance party to which TMGT re insure, its business. TMGT will engage best efforts to try to ensure that the entity to which TMGT transfer your Personal Data uses it in a manner that is consistent with this Notice. | Consent Legitimate Interest Contractual obligations |
| Third Party Administrators Repair Workshops | TMGT may Share your Personal Data with TPAs and repair work shops or other claim management service providers to ensure that your claims is managed swiftly, efficiently and effectively. | Consent Legitimate Interest Contractual obligations |
| Courts, Regulators, and Government Authorities | TMGT may share your Personal Data with these parties where TMGT believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect TMGT rights or the rights of any third party. To investigate or address claims or disputes relating to the use of TMGT’s Services, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, or pursuant to legal process or governmental request, including from law enforcement. To perform the role of collaborators, where Services require their involvement. | Legal Obligation |
| Debt Collection Agencies | TMGT may share your Personal Data with any entity used for the recovery or collection of receivables to the Company from delinquent or defaulted Customers. | Legitimate Interest |
| Postal Services and Couriers | TMGT may share your Personal Data with any entity used for the purpose of postal and courier services. | Consent |
| Co-Insurance Providers | TMGT may share your Personal Data with co-insurance providers, including underwriters, brokers and associated parties. | Consent Legitimate Interest |
| Intermediaries/Brokers through whom you are our Customers | TMGT may share your Personal Data with third parties who have introduced you to us (e.g. an intermediary or broker) in order for them to manage their records about you, to ensure that the type of business that they refer to us is appropriate and to help TMGT to resolve any complaint made by you and/or any dispute between you and TMGT. This type of processing allows us to ensure that the intermediary or broker is fulfilling the terms of their contract with us and for us to fulfil our legal and regulatory obligations. | Consent Legitimate Interest Contractual obligations |
| IT Service Providers | System-based processing of personal details as part of organizational/ operational requirements. E.g. cloud hosting Services; application development and support Services; IT Infrastructure Services; email Services; communication Services providers, call recording | Consent Legitimate Interest |
| Services. Help maintain the safety, security, and integrity of TMGT Services and Customer. | ||
| Law Enforcement Agencies & Authorities | To assist law enforcement agencies for the purposes of preventing, detecting, investigating, or prosecuting criminal offences. | Legal Obligation |
| Legal/Professional Advisors | The provision of business consulting, audit and legal Services including access to and analysis of Personal Data as part of business initiatives, statutory audits, legal claims, and ad-hoc consultancy advice. | Consent Legitimate Interest Legal obligations |
| Payment Processing Services | TMGT may share your Personal Data with providers of payment-processing Services and other businesses that help us process your payments to the extent required for us to meet the contractual and legal requirements. | Consent Legal Obligation Contractual Obligation |
| Representatives | TMGT may share your Personal Data with anyone who provides instructions or operates any of your accounts on your behalf, including advisers (such as solicitors and accountants), intermediaries and those under the power of attorney or Letter of Authorization. | Consent |
| Social Media Agencies | TMGT may share your Personal Data with social media companies so they can display messages to you about TMGT products and Services or make sure you do not get irrelevant messages. | Consent |
| Other Third Parties | Provide, maintain, and improve TMGT Services, including, for example, to facilitate payments, send receipts, provide products and Services you request (and send related information), develop new features, provide User support to Customer, develop safety features, authenticate Customer, and send product updates and administrative messages. | Consent |
| Perform internal administration and operations, including, for example, to prevent fraud and abuse of TMGT Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends. Sending you communications TMGT think will be of interest to you, including information about products, Services, promotions, news, and events of TMGT, where permissible and according to local applicable laws. Notify you about changes to TMGT terms, Services or policies and other communications that aren’t for the purpose of marketing the Services or products of TMGT or its partners. |
AUTOMATED PROCESSING
The way TMGT analyses Personal Data relating to TMGT Services may involve profiling or other automated methods to make decisions about you that relate to the following:
- Underwriting Risk factors ) – TMGT will consider several factors including but not limited to:
- Age, Gender, Health Information, Driving Record, Credit Score, Occupation, Location, Coverage Amount, Type of Insurance, Smoking Habits
- Various checks from a Compliance standpoint.
- Monitoring your account for fraud and other financial crime – TMGT will assess your transactions to identify any that are unusual.
IS IT OBLIGATORY OR VOLUNTARY FOR ME TO PROVIDE MY PERSONAL DATA?
- TMGT needs your Personal Data to provide you with the Services or products requested by you, to be able to process the Personal Data for fulfilling TMGT’s contractual and legal obligations.
- If you do not provide us with the requested Personal Data TMGT may have to decline your request for our Product(s) and/or Service(s), or if TMGT is already providing you with the product(s) and Service(s), TMGT may need to suspend or stop providing you with the product(s) or Service(s), which can lead to closure of your Insurance relationship with us, subject to compliance with TMGT’s legal obligations to retain data.
- SOCIAL MEDIA
- TMGT operates channels, pages and accounts on some social media sites to inform, assist and engage with customers.
- TMGT is not responsible for any information posted on those sites other than information TMGT has posted Itself. TMGT does not endorse the social media sites themselves or any information posted on them by third parties.
COOKIES
TMGT collects Personal Data about your internet activity using technology known as cookies, which can often be controlled through internet browsers and by using TMGT cookie preference center on the TMGT website and app.
- Technical information, such as your IP address and device ID.
- Information about your visit, such as your URL and website interaction.
- Location data, with your approval, used to show you the location of the nearest branch or ATM based on your IP address, coordinates or a unique device code.
- Networks and connections, when you interact with us and the people and groups that you are connected to (for example, through social media).
- INTERNATIONAL DATA TRANSFERS
- TMGT is part of a global organization, and your Personal Data may be stored or processed in any country where TMHD has facilities or in which TMGT engages Service providers and subcontractors. TMGT has put in place appropriate safeguards in accordance with applicable legal and data protection requirements to ensure that your data is adequately protected.