INTRODUCTION At BOI Insurance Brokers Limited (BOIIB), the privacy of our Data Subjects’ Personal Data is of utmost importance to us. We have developed this Privacy Policy to help you understand how we may process any personal information obtained from you and to explain your privacy rights. BOIIB is committed to ensuring that the privacy and personal information of its clients and employees (data subjects) collected and processed are protected and the responsibility is not outsourced to any third party. This Privacy Policy therefore constitutes our commitment to your privacy on all our platforms. It is designed to provide information regarding our privacy practices and prepared in line with the Nigeria Data Protection Act, 2023. Data Subject: is any person whose personal data would be collected, held and processed by BOI Insurance Brokers Limited (BOIIB) and includes clients, customers, business partners and employees. Data Administrator: means a persons or organization that processes data. For the purpose of this policy, BOI Insurance Brokers Limited is the Data Administrator. Data Controller: means a person who either alone, jointly with other persons or in common with other persons or as a statutory body determines the purposes for and the manner in which personal data is processed or is to be processed. For the purpose of this policy, the Managing Director of BOIIB is the Data Controller or whoever he so delegates. Data Protection Officer: is appointed by the data controller to ensure that the strategy and implementation of data protection requirements are in compliance with the data protection policy and the relevant extant laws. Responsibilities of the Data Administrator, Data Controller and Data Protection Officer are clearly outlined in the Nigeria Data Protection Act 2023. PERSONAL DATA COLLECTED By providing your personal information to us, you have signified your acceptance of our Privacy Policy and agree that we may collect, use and disclose your personal information for specified purposes as described in this Privacy Policy and they include the following: Personal Identification Information – When filling out a KYC form, we will request for your full name, age, nationality, gender, signature, utility bills, photographs, phone number, home address, and email address, etc. Formal Identification Information – These include National Identification Number (NIN), International Passport details, Drivers’ License details, Voter’s card details. Financial Information – We may process information related to payments that Data Subjects make or receive in the context of an insurance policy or claim. These include information such as Bank Verification Number (BVN) and information obtained from credit reference agencies. Contractual Information – We may process details about the policies a data subject holds and with whom the data subject holds them. We also collect personal data in the following ways: Information from our social media sites: We may collect information through your engagement with us on our social media sites, this includes your replies to our posts, your comments, enquiries and support messages. However, we will only ask for information required to help us be of service to you. Other information we collect related to your use of our site or services: We may collect additional information from or about you when you contact us with an enquiry, register on the web site, request us to provide you with information, request a quote or take advantage of a promotion. Third Parties: We may also receive your information from third parties such as financial institutions and service providers. We do not collect the information of minors. If you are below 18, do not provide us with your personal information. CONDITION FOR PROCESSING PERSONAL DATA BOIIB will obtain your consent before using and processing your data for one or more specific purposes made known to you. We collect your personal data to provide you an efficient and secure customer experience. Specifically, we may use your personal data for several reasons such as: For Contractual purposes Managing claims Assessing, improving and developing our services Fulfilling legal or regulatory obligations and protecting ourselves and you against fraud. Such regulators include NAICOM, Nigerian Financial Intelligence Unit (NFIU) and other relevant regulatory agencies. To contact you about our Products and Services. Responding to inquiries and complaints. To keep and update our records. To carry out Customer Due Diligence/ Know your Customer measures. For the protection of public interest such as investigation of fraudulent claims and Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) compliance checks. For archiving purposes in the public interest or statistical purposes. TRANSFER OF PERSONAL DATA We may share your Personal Data or other information about you with others for the following reasons: With other companies that provide services to us; we may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. With other third parties for our business purposes or as permitted or required by law; We may share information about you with other parties for our business purposes or as permitted or required by law, including: if we need to do so to comply with a law, legal process or regulations; to law enforcement authorities or other government officials, or other third parties pursuant to a court order or other legal process or requirement applicable to us or our corporate family; data processors for credit reference checks and anti-fraud and compliance purposes; To investigate violations To support our audit, compliance, and corporate governance functions. SOCIAL MEDIA PLATFORMS The data subject may wish to participate in various blogs, forums, and other social media platforms hosted by BOIIB (“Social Media Platforms”) which are made available to the data subject. The main aim of these Social Media Platforms is to facilitate and allow the data subject share content. However, BOIIB cannot be held responsible if the data subject shares personal information on Social Media Platforms that is subsequently used, misused or otherwise appropriated by another user. The data subject is required to consult the Privacy Statements of such services before using them. HOW WE PROTECT YOUR DATA We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorised access, disclosure, and alteration. USER RIGHTS The right to request for access to your Personal Data where those requests are reasonable and permitted by law or regulation. BOI Insurance Brokers Limited shall provide reasonable and accessible means for you to submit your requests. The right to request that BOI Insurance Brokers Limited erase your Personal Data if it is no longer valid or necessary for the purposes for which it was collected or if it is incomplete. The right to rectify or amend inaccurate or incomplete Personal Data. The right to withdraw your Consent at any time. The right to object at any time to the processing of your Personal Data if we process it based on our legitimate interests and the right to object at any time if we process your Personal Data for direct marketing purposes. The right to receive your Personal Data in a commonly used and machine-readable format and the right to transmit these data to another Data Controller when the processing is based on (explicit) consent or when the processing is necessary for the performance of a contract. Requests to Object to Automated Decisions you have the right to object to any decision producing a legal effect concerning you or which otherwise significantly affects you if this is based solely on the automated processing of your Personal Data. This includes automated decisions based on profiling. We may refuse your request if the decision in question is: Necessary to enter into a contract with you, or for the performance of your contract with us; Permitted by regulations, or Based on your consent. The right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) where you believe our processing of your data violates the requirements of the Nigeria Data Protection Regulation 2019 (NDPR). BREACH OF PRIVATE POLICY VIOLATION In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information, BOIIB shall within 72 (seventy two) hours of having knowledge of such breach report the details of the breach to NITDA. Furthermore, BOIIB shall within 7 (seven) days of having knowledge of the occurrence of such breach take steps to inform the Data Subject of the breach incident, the risk to the rights and freedoms of the Data Subject resulting from such breach and any course of action to remedy said breach. PRIVACY POLICY COMPLAINTS AND ENQUIRIES If you have any questions or complaints about our Privacy policy, kindly contact us via: Call or Text: 08150970591 [email protected] www.boiinsurancebrokers.ng
