We only process personal data for legitimate business purposes and
when a legal ground as set out in data protection law is applicable.
There are a number of legal grounds that may apply of which the
listing below describes the ones most likely to be relevant to you.
Consent
Wherever applicable and possible we will collect and process your
data with your consent. We will ensure that consent is requested
from you in an explicit manner. It involves direct and unambiguous
action, such as checking a box that is not pre-checked. When
collecting your personal data, we will always make clear to you,
which data is necessary in connection with a particular service. All
data provided by you will be used for legitimate purposes only and
the EHS undertakes to use such information only in connection with
services you will normally expect from us.
Consent for minors
For children under 18, informed consent is given by the child’s
parent or guardian and we will most probably process their data in a
different manner from that of adults.
Contractual obligations
In certain circumstances, we need your personal data to comply with
our contractual obligations. For example, if you request a quotation
for any of our insurance products, we would require you to furnish
us with your medical history.
Vital Interest
In specific situations, we may be required to process your data to
protect or save your life.
Legal compliance
If the law requires us to, we may need to collect and process your
data. We will also be legally required to store information and
personal data for a limited amount of time, as established by
applicable law.
Legitimate interest
In specific situations, we process your data to pursue our
legitimate interests in ways which might reasonably be expected and
which do not materially impact your rights.
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 rely 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 updated Privacy Statement.
Downloads
Executive Healthcare - Privacy Policy
Download
Request for Restriction or Objection to the processing of Personal
Data
Download
Request for rectification
Download
Request for access to Personal Data
Download
Request for access to Data Portability
Download
Request for erasure of Personal Data
Download
