ANSA Merchant Bank Limited (‘AMBL’) with its registered office situate at the ANSA Centre, 11 Maraval Road, Port of Spain, Trinidad; Trinidad and Tobago Insurance Limited with its registered office situate at 11 Maraval Road, Port of Spain; and Trinidad and TATIL Life Assurance Limited (‘TATIL Life’) with its registered office situate at TATIL Building, 11A Maraval Road, Port of Spain, Trinidad, collectively hereinafter referred to as the ‘ANSA Companies’, are affiliated companies, all incorporated and continued under the laws of Trinidad and Tobago.
This privacy statement (the ‘Privacy Statement’) details to the terms and conditions on which Trinidad and Tobago Insurance Limited (the ‘Company’) and the other ANSA Companies collect, use and share the information that obtained about you (the ‘Customer’) in the course of doing business.
Thank you for choosing the Company. We value you, respect your privacy and work hard to protect your personal information.
The Privacy Statement:
- explains how the ANSA Companies collect, use and share the information that obtained about the Customer in the course of doing business;
- describes the choices available to the Customer regarding the use of, access to and updating and correcting the Customer’s personal information.
1. Our Privacy Assurance
1.1 We confirm that the ANSA Companies:
1.1.1 do not sell the Customer’s personal information to anyone.
1.1.2 do not share the Customer’s information with non-affiliate companies that would use it to contact him/her about their products and services; save with the Customer’s express written consent to such sharing in accordance with a joint marketing agreement.
1.1.3 require persons or organisations that represent or assist us in servicing your policy and claims to keep the Customer’s information confidential.
1.1.4 require our employees to protect the Customer’s personal information and keep it confidential.
1.2 In addition to the privacy protection practices described above, the ANSA Companies use a variety of physical, technical and administrative security measures that help to safeguard the Customer’s personal information. For the Customer’s date of birth, payment information, and other sensitive personal information, this includes restricting the access of our employees, agents and other persons to such information only for the purposes of providing the Customer with products and services; handling the Customer’s claims and/or complying with the law.
1.3 While the Company collects payment information from the Customer for the purpose of individual transactions, such information shall only be used for the relevant transaction in respect of which it was provided and immediately thereafter shall be deleted.
1.4 The Company’s privacy protection practices continue to apply to the Customer’s personal information even if he/she ceases to be a customer.
2. Customer’s Obligations
2.1 The Customer agrees to at all times provide the Company with complete, accurate and truthful information.
2.2 If any personal information changes or becomes inaccurate or out of date, the Customer shall immediately advise the Company of any such occurrence, so its records can be updated.
2.3 The Company reserves the right to refuse to enter into or continue any relationships or conduct transactions with the Customer for legal reasons, or if the Customer insists on anonymity or provides false, inconsistent or conflicting information where the inconsistency or conflict cannot be resolved after reasonable inquiry by the Company.
2.4 If the Customer needs to update his/her personal information, delete inaccuracies, or modify his/her profile information, the Customer may do so by:
2.4.1 attending a branch office of the Company during business hours or
2.4.2 by logging into your account at any time on the Company’s website.
3. Personal Information Stored; Source(s) and Uses
3.1 Personal Information Collected
The Company collects personal information from the Customer and from outside sources including but not limited to:
3.1.1 the Customer’s name;
3.1.2 phone number(s);
3.1.3 home and e-mail addresses;
3.1.4 driver’s license and other identification number(s);
3.1.5 date of birth, marital status;
3.1.6 family member information;
3.1.7 occupation / type of business;
3.1.8 payment information;
3.1.9 source of funds (including the Customer’s annual income, assets and liabilities and credit history);
3.1.10 loan, deposits, investments, policy coverage, premiums, and payment history;
3.1.11 healthcare information;
3.1.12 preferences and interests.
3.2 Third-Party Information
The Company may also collect and maintain appropriate records of third-party information from the Customer to provide the relevant products, perform the necessary services and/or carry out requests, for example, adding another driver to an existing policy. If the Customer provides us personal information about a third-party, or if a third-party provides the Company with the Customer’s information, the Company will only use that information for the specific purposes listed at Clause 3.4.
- Evaluate marketing campaigns;
- Analyse how customers use our websites and applications;
- Develop new services;
- Know and track how many visitors have seen or clicked on our advertisements.
Also, the ANSA Companies’ business partners assist us with monitoring information including, but not limited to, IP addresses, domain names and browser data, which can help the ANSA Companies to better understand how visitors use our websites.
In the course of normal business activities, the Company collects from the Customer and from outside sources, uses, verifies, stores and maintains appropriate records of, shares and exchanges the Customer’s personal information with persons within and outside of the Company for purposes, which include but are not limited to:
3.4.1 Confirming the Customer’s identity;
3.4.2 Understanding the Customer’s requirements and needs, ensuring the Customer is eligible to access the Company’s services and to ensure its products and services are meet the Customer’s requirements;
3.4.3 Providing the product or perform the services requested by the Customer including but not limited to-
- fulfilling a transaction that the Customer requested;
- administering the Customer’s account; servicing the Customer’s insurance policy; investigating and adjudicating the Customer’s claim or providing other services requested;
- responding to the Customer’s service-related requests;
3.4.4 Marketing and cross-selling the products and services of the ANSA Companies to the Customer, for example, by sending the Customer by e-mail or regular mail promotional communications about products, features, and options that we believe may be of interest to the Customer, newsletters and other service related correspondence;
3.4.5 Preventing or detecting fraud or criminal activity or settling any actual or potential loss in connection with fraud or criminal activity;
3.4.6 Complying with requests from regulatory and law enforcement authorities including where the Company is required –
- to disclose personal data in response to lawful requests by public authorities, to meet national security or law enforcement requirements;
- by law, such as to comply with a subpoena or other legal process, when the Company believes in good faith that disclosure is necessary to protect its rights, protect the Customer’s safety or the safety of others, investigate fraud, or respond to a government request;
3.4.7 Participating in support organisations, which engage in the practice of assembling or collecting information about persons for the primary purpose of providing information to a financial institution for transactions, such as consumer reports for use in connection with a transaction and for the purpose of detecting or preventing fraud, material misrepresentation or material nondisclosure.
3.5 Persons with whom the Company can share Personal Information
3.5.1 The persons or organisations with whom the Company may share the Customer’s personal information may include, but are not limited to:
- The Customer’s agent, broker or any other ANSA Companies;
- Companies that perform services for the Company, such as marketing, credit/debit card processing, and communication services on its behalf;
- Business partners that assist the Company in tracking how visitors use the ANSA Companies’ websites;
- Other financial institutions and service-providers involved in a transaction with the Customer;
- Other insurance companies involved in an insurance transaction with the Customer, independent claims adjusters, recommended claims-related service-providers and vendors;
- Business(es) that conduct actuarial or research studies;
- Regulatory and law enforcement authorities; law enforcement representatives and private investigators and
- Person who lawfully are entitled to the information pursuant to a subpoena or other legal process.
3.5.2 Without prejudice to the generality of Clause 3.5.1(a) above, the Customer consents to and authorises the Company to disclose and give the Customer’s personal and other information to any ANSA Companies for any marketing purposes so that these persons can directly inform him/her about their products and services (to the extent permitted by the law). The Customer acknowledges that the Company’s affiliates, subsidiaries and/or associates include companies engaged in services such as long-term deposits, loans and other personal financial services; mortgage loans; trust and custodial services; insurance services; investment management and financial planning services; and mutual funds investment services. The Company will only share the Customer’s personal information with such third parties for the purposes detailed in and will require the service providers to protect the information so received in a manner that is consistent with this Privacy Statement The Customer’s consent provided here shall also apply to any companies that become the Company’s affiliates, subsidiaries and/or associates in the future.
3.5.3 The Company may not directly provide all the services related to products and/or services ultimately provided to the Customer. The Company may utilise third-party service providers to process or handle information on its behalf and to assist with various services such as data processing, administration, marketing, providing customer support or performing statistical analysis of its services. Without prejudice to the generality of Clause 3.5.1(b) above, the Customer acknowledges that the Company may release information about him/her to such third-party service providers and fully authorises such disclosure. The Company will only share the Customer’s personal information with such third parties for the purposes detailed in and will require the service providers to protect the information so received in a manner that is consistent with this Privacy Statement.
3.5.4 The Customer hereby expressly authorises the Company to give the Customer’s personal and other information to any of the persons or organisations stipulated in Clause 3.5 whom the Company contacts in this regard to provide such information to it.
3.6 The sharing by the Company of the Customer’s personal information, as contemplated by this Clause 3, will at all times be done as required and permitted by law.
4. The Internet and Information Security
The Company’s Website
4.1.1 The Company’s website provides information about it, its products, and its representatives. You may also perform certain transactions on the website.
4.1.2 This Privacy Statement applies to users of the Company’s website, regardless of whether the user is a customer of the Company.
4.1.3 The website gathers certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP) data, referring/exit pages, operating system data, date/time stamp, and/or clickstream data.
4.2.2 Cookies and other similar tracking services enable the website to label the customer as a particular user but it does not identify the Customer by name or address unless he/she has provided us with such information (over the Internet or otherwise) or set up the preferences in the website browser to do so automatically.
4.2.3 Cookies allow us to provide the Customer with a more customised service and are used to track and measure website usage. This information may be used to manage and customise its website’s content, layout, and services in order to improve the website, enhance customer service and provide tailored messages.
4.2.4 The Customer may opt out of accepting cookies by changing the settings on his/her website browser. However, by rejecting cookies the Customer may be prevented from using certain functions and may have to repeatedly enter information to take advantage of services or promotions.
4.2.6 The Company believes that each of the websites to which it targets its advertisements or from which it collects data should post on its website a privacy statement that fully describes the advertising and data collection activities. However, the Company cannot guarantee that those websites will post such a privacy statement and assumes no liability in respect of the advertising and data collection activities on such third-party websites.
Where the Customer wants the Company or any of the ANSA Companies to cease sending promotional or other e-mails or communications, the customer may opt-out of receiving such communications by following the unsubscribe link located at the bottom of each communication or by contacting us at the following address: [ ].
6. Security Procedures
Security Procedures to Guard Against Information Loss, Misuse or Theft
6.1.1 The Company uses security software to encrypt the information before and during its transmission over the Internet to help ensure the security of the Customer’s personal and financial information that he/she submit to the Company’s website, (other than via an e-mail message).
6.1.2 The Company only allow information to be submitted for transmission if the Customer’s browser is compatible with the Company’s security software. If the Customer’s browser is not compatible, he/she will receive a message indicating the transaction can be completed but at a lower level of security. However, in either case, no method of transmission over the Internet, or method of electronic storage, is one hundred percent (100%) secure. Therefore, the Company cannot guarantee the security of nor shall it be responsible for the confidentiality of any information sent by the Customer to it over the Internet.
6.2 Use of E-mail
6.2.1 The Company’s security software does not encrypt e-mail messages. The Customer acknowledges that e-mail messages traveling through the Internet are subject to viewing, alteration, and copying by potentially anyone on the Internet and e-mail messages are not secure.
6.2.2 The Customer shall exercise discretion with respect to the submission of any personal or financial information via e-mail. If the Customer is concerned about the security of his/her communication, the Company encourages the Customer to send his/her correspondence through the postal service or use the telephone to speak directly to a representative of the Company’s. The Company shall not be responsible for the security or confidentiality of any communications sent by the Customer to it over the Internet using e-mail messages.
6.3 Steps the Customer can take to Help Maintain the Security of Information
The Customer can take certain steps to maintain the security of his/her information including but not limited to the following:
6.3.1 Utilising the latest, updated version of web browser;
6.3.2 Keeping his/her user identification (User ID) and personal identification number (PIN) or password confidential;
6.3.3 Utilising a unique PIN or password and, if possible, change it frequently;
6.3.4 Ensuring that others are not watching the entry of the User ID, PIN or password on the keyboard;
6.3.5 Not providing any confidential information (including User IDs, passwords, Account/Policy information, PINs) to persons via phone, e-mail or mobile messages;
6.3.6 Not leaving the computer unattended while logged onto the Company’s website; and
6.3.7 After finished accessing information, exit or close the browser window.
7.2 We hope you have found this Privacy Statement informative. If you have questions or would like more information, please do not hesitate to contact the [ ] at [ ]. If the Customer has a concern with any of the terms or policies described in this Privacy Statement, we kindly ask that he/she discontinue use of the website until such time as that concern has been resolved.
8.1 No Waiver
Any failure by either Party to enforce the other Party’s strict performance of any provision of this Agreement will not constitute a waiver of its right to subsequently enforce such provision or any other provision of this Agreement.
If at any time any one or more of the provisions of this Agreement is or becomes invalid, illegal or unenforceable in any respect under any law or regulation, or is held by a court of competent jurisdiction to be invalid, illegal or unenforceable, the validity, legality or unenforceability of the remaining provisions shall remain in full force and effect and shall not in any way be affected or impaired thereby.
All obligations contained in this Agreement shall extend to and be binding upon the Parties to this Agreement and their respective heirs, successors and assigns.
8.4 Governing Law
This Agreement shall be governed by the laws of Trinidad and Tobago. Each of the Parties hereto irrevocably submits to the exclusive jurisdiction of the courts of Trinidad and Tobago in respect of any claim, dispute or difference arising out of or in connection with this Agreement or the interpretation thereof.