Executive Healthcare Solutions – Privacy Policy

Personal information you provide is processed fairly, lawfully and in a transparent manner. Personal data that we may process, as appropriate throughout the insurance and claim process is, but is not limited to:

• Name and contact details (such as telephone number, e-mail address and postal address).
• Date of birth.
• Profession
• Gender.
• Marital status.
• Dependant details.
• Bank accounts.

We may also process sensitive or special personal data where relevant to the insurance and claim processes, including where necessary to accommodate any disability needs

When exercising our rights and obligations under the insurance contracts, it may be necessary to process sensitive data categories. Such sensitive may include but not limited to.

• Claim record.
• Video, photographic images or audio recordings submitted or made as part of the medical claim process.
• Medical reports and medical history.
• Previous claim experience available.

The personal information we require about you (and, if applicable, other people insured under your insurance policy) will be gathered and stored as set out in this Data Privacy statement

Whilst there are several ways, we collect Personal Data we mainly obtain your information through the following means:

Approved Intermediaries

We may collect data directly or through our approved and authorized insurance intermediaries and those appointed or acting on your behalf.

Service providers

We collect your data through various service providers that include but not limited to.

• Insurance companies, locally and internationally.
• Our external advocates
• Medical practitioners and medical institutions

Our marketing teams

If you are an insurance intermediary/consultant or business partner, we may also collect your information from our day-to-day business activities with you, business referrals and your attendance at events, categories being collected and processed are as per Data Protection Act 2019 laws of Kenya and the GDPR.

Our marketing team will collect documents from you and transmit the same to the company for processing of your insurance policy and claims where appropriate. This data will be used as per the intended purpose and in an event the data shall be used for commercial purpose, the same will be done in strict adherence of section 37 of the Data Protection Act of 2019.

Your Personal Data may also be collected from third parties during claim processing such as references from previous insurer and government authorities/bodies.

If you are a customer, we mainly use your personal information so that we can provide a quote, set up, administer and manage your policy, including carrying out a risk survey, and to assess and pay claims as part of an insurance contract. However, there are several other reasons why we use your personal information as set out below

• To consider whether to enter into an insurance relationship with you.
• To comply with any legal right or obligations to which we are subject to
• For Processing of any claim in respect of an existing policy of insurance.
• Subrogation/Recovery and includes but is not limited to the following:
  • Processing your insurance policy
  • To determine whether you have an insurable interest in the subject matter.

If you are an intermediary/consultant or business partner, we mainly use your personal information for day-to-day business activities with you and to provide you with information relevant to our services in accordance with our marketing strategy, including a periodic newsletter, invitations to events and communication of new products.

Executive Healthcare Solutions limited operates a branch network hence any authorized persons working in our network may come into contact with your data.

Your Personal Data may be disclosed to any of the following for any of the purposes outlined above:

Professional advisers, third party service providers, agents or independent contractors providing services to Executive Healthcare Solutions limited.

To any person in connection with litigation or other legal proceedings, to obtain legal advice or for establishing, exercising, or defending legal rights.

Any person to whom disclosure is allowed or required by Law and/or Regulation, Any court, tribunal, Regulatory Authority or Governmental Entity.

Any criminal records bureau, credit bureau or credit reference agency when conducting background checks.

To third parties to provide references at your request or with your consent; and

Third parties to whom we may transfer our rights and/or obligations under any agreement, including but not limited to a potential merger or acquisition of all or part of the Group’s business.

Subrogation

In some circumstances, we may provide your personal data to a third party who will determine how and why it will be processed

Personal Data is retained as long as necessary for the purpose for which it is collected and to meet legal, regulatory and operational requirements. Retention periods may differ for each insurance policy taken. At the end of the retention period, non-identifiable data is kept for management information/statistical purposes. Executive Healthcare Solutions limited has also put in place a Data retention policy in line with The Data Protection Act of 2019 and the GDPR.

Executive Healthcare Solutions limited may also retain your contact information for the purposes of inviting you to renew any of your insurance policy from time to time and may use your contact to send you notifications notifying you of our various products, renewal notice and claim updates.

The security of your Personal Data is important to us, and Executive Healthcare Solutions limited implements technical and organizational measures to safeguard your personal data.

As a responsible organization, Executive Healthcare Solutions limited manages its client’s data and only authorized personnel may access your Personal Data

When using external service providers, we require that they adhere to security standards mandated by Executive Healthcare Solutions limited and regardless of where personal data is transferred, we take all steps reasonably necessary to ensure that it is kept securely.

When transferring your data to European Union (“EU”) and your personal data is processed in a country outside of the EU, we will put in place contractual clauses approved by Data Protection Commissioner as provided for under the law and by the EU Commission as providing an adequate level of protection.

MINORS

Executive Healthcare Solutions limited do not issue insurance policy to a minor. Any personal data belonging to a minor where a policy of insurance has been taken out by a parent or guardian on behalf of the minor, shall be processed/handled in accordance with section 33 of the Data Protection Act 2019.

In some circumstances you may have the right to object to how Executive Healthcare Solutions limited processes your Personal Data or restrict its processing, but this does not mean you can decide or choose how we process your Personal Data.

Where it is stated that we process your personal information on the basis of a legitimate interest, you are entitled to object to the processing in question on grounds relating to your situation, we will then stop processing the information unless we can demonstrate compelling legitimate grounds.

Executive Healthcare Solutions limited will update your data from time to time as advised by you, you are obligated to ensure that Executive Healthcare Solutions limited is always holding accurate and updated personal data.

The Executive Healthcare Solutions limited Privacy Statement may be updated from time to time, and it is your responsibility to visit our websites and other communication platforms regularly for the most recent version.

In accordance with Section 26 of the Data Protection Act, Laws of Kenya, data subjects have the right to: be informed of the use to which their personal data is put; access personal data held by a data controller or processor; object to the processing of all or part of their data; request correction of false or misleading data; and request deletion of such data.

To exercise any of these rights, kindly access the Data Subject Rights Request Forms available on our website. These include:

• Request for Access to Personal Data
• Request for Restriction or Objection to Processing
• Request for Rectification
• Request for Data Portability
• Request for Erasure of Personal Data

Once completed, please submit the form along with any supporting documentation to dpo@executive-healthcare.com or by delivery in person or Postal Mail to:

Executive Healthcare Solutions limited.

C/O Data Protection Officer
6th Floor, 9 West, Ring Road Parklands
P.O. Box 14680-00800
Nairobi, Kenya

You understand that by using our site services and our products you agree to be bound by this statement of privacy. If you agree to this statement on behalf of an entity, you represent and warrant that you have the authority to bind that entity to our privacy statement, by using our products and/or accessing our site, if you do not accept it in entirety you must inform us immediately indicating what part of our privacy statement you are not agreeable to.

By providing your personal information or personal information of someone included in your policy to Executive Healthcare Solutions limited, you acknowledge that we may use it only in the ways set out in this Privacy statement.

For certain uses of your personal information, we may ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information. Withdrawal of consent would not invalidate any processing we carried out prior to your withdrawal of consent. Please note in some cases we may not be able to process your insurance if you withdraw your consent

We do not generally rely on consent for processing personal information in relation to insurance contracts; we generally relay on other legal grounds, such as the basis that processing is necessary for the performance of a contract to which you are party.

If you have concerns in relation to the way Executive Healthcare Solutions limited processes your personal data, you can either contact our Data Protection Officer by writing or email under aforementioned contact data

From time to time, we may need to make changes to this Privacy Statement, for example as a result of government regulations new technologies or other developments in data protection laws or privacy generally. We encourage you to review periodically to see the most update Privacy Statement