Security and Privacy Statement

At laya healthcare, we are committed to protecting and respecting your data protection and privacy rights. Please take a moment to read this Privacy Policy to find out more about why and how we process your Personal Information. Personal Information (data) is the information we hold in relation to you and other dependents on your policy. You should show this notice to anyone who may be covered by your insurance policy with laya healthcare and (where possible) get their permission to share their Personal Information with us.

 Our aim is the responsible and secure handling of Personal Information, balancing the benefits of activities like research and data analytics to improve our products and service delivery, with our other commitments, including fairness, transparency and non-discrimination.  We do so in accordance with the Data Protection Act 1988 and 2003 and the General Data Protection Regulation (GDPR) (EU) 2016/679.

 This Privacy Policy will be supplemented by additional privacy notices tailored to our specific relationships with you where this is useful to provide you with a full picture of how we collect and use your Personal Information.

In this Privacy Policy, we refer to the Site, the Apps and Social Media Content together as laya healthcare digital services.

Unless otherwise indicated, the laya healthcare digital services are not intended for use by individuals under the age of eighteen (18), and we request that if you are under eighteen (18) you do not provide Personal Information through the laya healthcare digital services.

Personal Information may be provided to us by you directly or by a third party.  For example, an insurance policyholder such as a spouse or dependent may provide Personal Information about you so that you can benefit under their insurance policy.

 

Data we process

The Personal Information we collect, and hold depends on our relationship with you. We process the identification and contact information and the data you input into our online forms or provide to us over the phone when you request a quote or when you join laya healthcare.

 

This may include:

  • application, proposal and claim forms, and other forms
  • telephone calls, emails, meetings and other communications
  • service providers, brokers and agents, claims investigators, witnesses, medical professionals and other third parties
  • this website (the Site)
  • the software applications made available by us on computers, smart phones and other mobile devices (the Apps)
  • our social media pages, other social media content, tools and applications (our Social Media Content).

 

It is also necessary for us to collect sensitive information/special categories of information (such as medical conditions) about you and others named on the insurance policy. We may seek and obtain from your physician or a hospital, information about you relating to any treatment or other services provided to you or other members of the insurance policy.

 

This may include:

  • records of physical or mental illness or ill health
  • medical histories
  • records of treatments obtained by you
  • length of any stay in a hospital
  • other treatments or services, including wellness services, received by you or your dependant(s).

 

Other sensitive information we collect to provide you with products and services you require may include:

 

  • Payment card number (credit or debit card)
  • bank account or other financial account number and account details
  • credit history
  • credit reference information and credit score
  • assets, income, and other financial information
  • account log-in information and passwords for accessing insurance policy, claim and other accounts, and laya healthcare digital services.

 

The above sensitive information/special categories of information are not used to offer or determine any products for you or any other members of your insurance policy, and are only used to administer claims on that policy. We also collect and record certain information about you when you browse our website. For more information, please see our Cookies Policy below.

 

Type of Personal Information

Examples

Contact information

Name, address, email and telephone number

General information

Gender, marital and family status, date and place of birth

Education and employment information

Educational background, employer details and employment history, skills and experience, professional licences, memberships and affiliations

Insurance and claim information

Policy and claim numbers, relationship to policyholder, insured, claimant or other relevant individual, date and cause of property damage, loss or theft, injury, disability or death, activity records (for example, driving records), and other information relevant to insurance policy issuance, and claim assessment and settlement. For liability insurance, this will include details of the dispute, claim or proceedings involving you.

Government and other official identification numbers

Social security or national insurance number, passport number, tax identification number, driver’s licence number, or other government issued identification number

Financial information and account details

Payment card number (credit or debit card), bank account number, or other financial account number and account details, credit history, credit reference information and credit score, assets, income, and other financial information, account log-in information and passwords for accessing insurance policy, claim and other accounts, and laya healthcare digital services

Medical condition and health status

Current or previous physical, mental or medical condition, health status, injury or disability information, medical diagnosis, medical procedures performed, and treatment given, personal habits (for example, smoking or consumption of alcohol), prescription information, and medical history

Other sensitive information

Information about religious beliefs, ethnicity, political opinions or trade union membership (for example, if an insurance application is made through a third-party marketing partner that is a professional, trade, religious, community or political organization), sexual life and orientation, or genetic or biometric information

We may obtain information about criminal records or civil litigation history (for example, for preventing, detecting and investigating fraud)

Information provided voluntarily to us (for example, preferences expressed regarding medical treatment based on religious beliefs, where collected in accordance with applicable law)

Telephone recordings

Recordings of telephone calls with our representatives and call centres

Photographs and video recordings

Images (including photographs and pictures) or video recordings created in connection with our insurance or other business activities, including for claims assessment, administration and settlement, claim disputes, or for other relevant purposes as permitted by law, as well as CCTV recordings captured by equipment on our premises

Information to detect, investigate or prevent crime, including fraud and money laundering

Insurers commonly collect, hold and share information about their previous dealings with policyholders and claimants with the intention of the detection, investigation and prevention of fraud, money laundering and other criminal activities

Information enabling us to provide products and services

Location and identification of property insured (for example, property address, vehicle licence plate or identification number), travel plans, age categories of individuals to be insured, details of the risks to be insured, prior accident or loss history, and cause of loss, status as company officer or director, or partner, or other ownership or management interest in an organisation, history of disputes, civil or criminal proceedings or formal investigations involving you, and information about other insurance held

Marketing preferences, marketing activities and customer feedback

Marketing preferences, information relating to competitions, prize draws or other promotion entry, or responses to voluntary customer satisfaction surveys

To improve our marketing communications, we may collect information about interaction with, and responses to, our marketing communications

Online activity information

We will receive Personal Information about you when you use laya healthcare digital services; this may include your social media account identifier and profile picture, your IP address and other online identifiers (to the extent that they are Personal Information), and other Personal Information that you provide to us online

If you choose to connect your social media account provided by another social media service provider to your account on any of the laya healthcare digital services, Personal Information from your other social media account may be shared with us, which may include Personal Information that is part of your social media account profile, or the profiles of your friends and other connected individuals

Supplemental information from other sources

We and our service providers may supplement the Personal Information we collect with information obtained from other sources (for example, publicly available information from online social media services and other information resources, third party commercial information sources, and information from our group companies and business partners). We will use any such supplemental information in accordance with applicable law (including obtaining your consent where required)

 

Why do we process your data? 

We collect and use the information you disclose to us, to provide you with your chosen products and services; including wellness services. Without collecting and using your Personal Information, it would not be possible for us to offer you a quote, help you choose the best plan for you, manage and administer your policy nor to underwrite or handle your claims.

 

More specifically, we use the information about you (both personal and sensitive personal data/ special categories of personal data) that we hold for the following purposes:

 

  • for managing and administering your insurance policy
  • for underwriting and claims handling
  • for money laundering prevention purposes
  • to analyse and examine the claims processes and treatment/over-night stay/convalescence options applied/utilised by medical service providers
  • to audit medical service providers generally
  • to examine the handling of claims by a medical service provider
  • for the efficient payment of Stamp Duty, payable on your Health Insurance contract under section 125A of the Stamp Duties Consolidation Act 1999.

 

We also process your information in order to comply with legal obligations to which we are subject and for the purposes of our legitimate interests such as to prevent fraud, for marketing and audit purposes for systems development and for managing and improving our services.

 

From time to time we would like to contact you to:

  • invite you to events we are sponsoring
  • invite you to various events we run exclusively for our members
  • gauge satisfaction with the service you received from us
  • perform market research.

 

Once you consent to us contacting you for the above purposes we will do so. If you later opt out of such communications, we will adhere to your preferences.

 

How do we use your data?

We use Personal Information for different purposes depending on our relationship with you.

The main purposes are to: 

  • Communicate with you and other individuals, dependents and members
  • Make assessments and decisions (automated and non-automated, including by profiling individuals) about the provision and terms of insurance; the settlement of claims and the provision of other services.
  • Provide insurance, claims and assistance services, and other products and services including claim administration, settlement and dispute resolution.
  • Assess your eligibility for payment plans, and process your premium and other payments
  • Improve the quality of our products and services, provide team training and maintain information security (for example, for this purpose we may record or monitor phone calls).
  • Prevent, detect and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks.
  • Carry out research and data analysis, including analysis of our customer base and other individuals whose Personal Information we collect, complete market research, including customer satisfaction surveys, and assess the risks faced by our business, in accordance with applicable law (including obtaining consent where required).
  • Provide marketing information in accordance with preferences you have told us about or shared with us (marketing information may be about products and services offered by our third-party partners subject to your expressed preferences). We may carry out marketing activities in accordance with your preferences by using email, SMS and other text messaging, post or telephone.
  • Allow you to participate in competitions, prize draws and similar promotions, and to administer these activities. These activities have additional terms and conditions, which will contain more information about how we use and disclose your Personal Information where this is useful to provide you with a full picture of how we collect and use Personal Information, so we recommend that you review those too.
  • Personalise your experience when you use laya healthcare digital services or visit third party websites by presenting information and advertisements tailored to you, identify you to anyone to whom you send messages through the laya healthcare digital services, and facilitate sharing on social media.
  • Manage our business operations and IT infrastructure esytems, in line with our internal policies and procedures, including those relating to finance and accounting; billing and collections; IT systems operation; data and website hosting; data analytics; business continuity; records management; document and print management; and auditing
  • Manage complaints, feedback and queries, and handle requests for data access or correction, or the exercise of other rights relating to Personal Information
  • Comply with applicable laws and regulatory obligations (including laws and regulations outside your country of residence), for example, laws and regulations relating to anti-money laundering, sanctions and anti-terrorism; comply with legal process and court orders; and respond to requests from public and government authorities (including those outside your country of residence)
  • Establish, enforce and defend legal rights to protect our business operations, and those of our group companies or business partners, and secure our rights, privacy, safety or property, and that of our group companies or business partners, you, or other individuals or third parties; to enforce our terms and conditions; and pursue available remedies and limit our damages. 

 

Laya healthcare may share your data with others in order to provide you with great healthcare and quality benefits; and so as to comply with our legal obligations. As part of your health insurance cover with us we might share your information with our service providers such as Spectrum Health Limited who provide our healthcoach benefit and health and wellbeing programmes, Ed Advanced Medical Services Limited t/a Advanced Medical Services for who provide our HeartBeat cardiac screening benefit, Webdoctor and Bupa who provide our CareOnCall services, Congate Health who provide our occupational health programmes and/or other partners.

 

We may also share your Personal Information with hospitals and/or consultants to aid the efficient processing of claims.

 

We are also obligated under the Health (Provision of Information) Act 1997 to provide information to the National Cancer Registry Board, the Minister for Health or a health board, hospital or other body or agency participating in any cancer screening.

 

In the event you switch to another insurer, we will share your information with the new insurer in accordance with the Health Insurance Act 1994 (Determination of Relevant Increase under section 7A and Provision of Information under section 7B) Regulations 2014 to confirm information that you have provided on taking out a policy with the new insurer.

 

Our agents or subcontractors may also have access to your data on a strictly confidential basis.

 

In order to provide you with products and services, this information will be held in the data systems of laya healthcare or by our agents or subcontractors.

 

When you request a quote from us, you may receive a phone call or text message and/or email in relation to that quote. If you would prefer not to receive such communications, please contact us to let us know.

 

 

How do we use data to detect, investigate and prevent fraud?

We may use Personal Information to detect, investigate and prevent fraud, and this may include sharing Personal Information with other insurers and law enforcement agencies. We are committed to detecting and preventing fraud, and other financial crime.  We take this commitment very seriously and use Personal Information in a number of ways for this purpose. 

 

For example, if relevant to our relationship with you we may (where permitted by applicable law):

  • submit your Personal Information (including details of any claims you make, for example, details of injuries) so that they appear on registers of claims which are shared between different insurance providers

  • search registers of previous claims when assessing a claim

  • share your Personal Information with other insurers and law enforcement agencies. 

 

Are automated decisions made using data?

Sometimes we use automated decision-making tools (i.e. where a person is not involved in the decision). We typically use these tools when making straightforward decisions about you (for example, in certain claims handling and medical screening processes).   

 

Sometimes, as part of our business operations, decisions about you are taken using automated computer software and systems.  These decisions do not involve human input, and the software and systems apply pre-defined logic programming and criteria to make a decision and assess how we deal with you in connection with the provision of services.

 

For example, we sometimes use automated decision making as part of a process to:

 

  • decide whether an outpatient claim should be paid as requested (for example, if pre-specified criteria are met by responses that you provide, the claim will be paid automatically without the need for additional human intervention)
  • identify known pre-existing medical conditions to decide whether we can offer life insurance to you and on what terms.

 

We provide you with more information in relation to any automated decision processes before or at the time that we intend to make decisions in this way. You have the right in certain circumstances not to be subject to a decision which is based solely on automated processing.

 

Who is responsible for Personal Information?

Laya healthcare, proudly part of AIG is responsible for looking after the Personal Information we collect, hold and use. Laya Healthcare Limited trading as laya healthcare is underwritten by Elips Insurance Ltd.

 

The AIG group comprises a number of companies, including, but not limited to, the AIG parent company American International Group, Inc., AIG Europe Limited (AEL) and AEL country branches in Europe, Laya Healthcare Limited and AIG Life Limited. 

 

Each AIG group company that processes your Personal Information is responsible for looking after it in accordance with the AIG Privacy Policy, their internal standards and procedures, and the requirements of data protection law.

 

For more precise information about the specific company or companies in the AIG group that have access to and are responsible for your Personal Information (including the identity of the relevant AIG companies that are the data controller(s) for your Personal Information), please contact us.

 

We may also share your information with third parties.  Those third parties will assume certain responsibilities under data protection law for looking after the Personal Information that they receive from us:

 

  • Where permitted by applicable law, AIG may share Personal Information with other third parties, for example, other insurers, reinsurers, insurance and reinsurance brokers, other intermediaries and agents, appointed representatives, distributors, affinity marketing partners and financial institutions, securities firms and other business partners.

 

  • External third party service providers, such as medical and security professionals, accountants, actuaries, auditors, experts, lawyers and other professional advisors; travel and medical assistance providers; call centre service providers; IT systems, support and hosting service providers; printing, advertising, marketing and market research, and data analysis service providers; banks and financial institutions that service our accounts; third party claim administrators; document and records management providers; claim investigators and adjusters; construction consultants; engineers; examiners; jury consultants; translators; and other third party vendors and outsourced service providers that assist us in carrying out business activities.

 

  • Where you have friends and other connections associated with your social media account, other website users and your social media account provider may receive your Personal Information in connection with your social sharing activity (for example, if you connect a social media account provided by another social media service provider to your laya healthcare digital services account or log into your laya healthcare digital services account from another social media account).  By connecting your laya healthcare digital services account and your other social media account you authorize us to share information with the provider of your other social media account and you understand that the use of the Personal Information we share will be governed by the other service provider’s privacy policy.  If you do not want your Personal Information shared with other users or with your other social media account provider, please do not connect your other social media account with your laya healthcare digital services account and do not participate in social sharing while using laya healthcare digital services.                                           

 

  • We may also share Personal Information with: (a) government or other public authorities (including, but not limited to, workers’ compensation boards, courts, regulatory bodies, law enforcement agencies, tax authorities and criminal investigations agencies); and (b) third party participants in legal proceedings and their accountants, auditors, lawyers, and other advisors and representatives, as we believe to be necessary or appropriate.

 

  • We may share Personal Information with payees; emergency providers (fire, police and medical emergency services); retailers; medical networks, organisations and providers; travel carriers; credit bureaus; credit reporting agencies; other people involved in an incident that is the subject of a claim; as well as purchasers and prospective purchasers or other parties in any actual or proposed reorganisation, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our businesses, assets, companies or stock (i.e. company shares). 

 

  • Where permitted by applicable law, Personal Information (including details of injuries) may be put on registers of claims and shared with other insurers. We may search these registers when dealing with claims to prevent, detect and investigate fraud. 

 

  • If you benefit from another party’s insurance policy or service arrangement with laya healthcare (for example, a policy taken out by your employer), Personal Information relating to the administration of that insurance policy or service may be shared with that other party.

 

Personal Information may also be shared by you on message boards, chat, profile pages and blogs, and other laya healthcare digital services to which you are able to post information and materials (including, our Social Media Content). 

 

Please note that any information you post or disclose through these services will become public information, and may be available to visitors and users of the laya healthcare digital services and to the general public.  We urge you to be very careful when deciding to disclose your Personal Information, or any other information, when using the laya healthcare digital services.

 

  

 Where do we process Personal Information?

We may process Personal Information both nationally and internationally. This may include transferring Personal Information outside the European Economic Area (EEA). Rest assured, we are committed to protecting and respecting your data protection and privacy rights. We take additional steps to ensure the security of Personal Information when we transfer it outside the EEA.

Depending on the nature of our relationship with you, we will transfer Personal Information to parties located in other countries in the EU an EEA. 

For example, we may transfer Personal Information in order to process international travel insurance claims and provide emergency medical assistance services when you are abroad.  We may transfer information internationally to our group companies, service providers, business partners, government or public authorities, and other third parties. 

When making these transfers, we will take steps to ensure that your Personal Information is adequately protected and transferred in accordance with the requirements of data protection law. 

This typically involves the use of data transfer agreements in the form approved by the European Commission and permitted under Article 46 of the EU General Data Protection Regulation (GDPR) (the relevant data protection law). If there is no data transfer agreement in place, we may use other mechanisms recognised by the GDPR as ensuring an adequate level of protection for Personal Information transferred outside the EEA (for example, the US Privacy Shield framework or any framework that replaces it).

 

 How do we keep your data secure?

Information security is extremely important to us. Laya healthcare uses appropriate technical, physical, legal and organisational measures, which comply with data protection laws to keep Personal Information secure.  If, despite our efforts, you believe that Personal Information is no longer secure, please tell us so that we can resolve any security issue. 

As most of the Personal Information we hold is stored electronically we have implemented appropriate IT security measures to ensure this Personal Information is kept secure.  For example, we may use anti-virus protection systems, firewalls, and data encryption technologies. We have procedures in place at our premises to keep any hard copy records physically secure.  Our team receive regular training on data protection and information security. 

When laya healthcare engages a third party (including our service providers) to collect or otherwise process Personal Information on our behalf, the third party will be selected carefully and required to use appropriate security measures to protect the confidentiality and security of Personal Information.  

Unfortunately, no data transmission over the Internet or electronic data storage system can be guaranteed to be 100% secure.  

If you believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have sent to us has been compromised), please contact us immediately.

 

What is the legal justification for our use of data?

We are obliged to advise you on the legal justification we rely on for using your Personal Information. 

Data protection law seeks to ensure that the way Personal Information is used is fair. We may be required to obtain Personal Information from you to comply with applicable legal requirements, and certain data may be needed to enable us to fulfil the terms of our contract with you (or someone else), or in preparation of entering into a contract with you (or someone else). We may inform you of this at the time that we are obtaining the data from you.  In these circumstances, if you do not provide the relevant data to us, we may not be able to provide our products and benefits to you. 

For more sensitive special categories of Personal Information we will rely on either your consent or one or more of the other legal justifications set out in the table below and typically one of the following two additional justifications (however other legal justifications may be available): 

 

  • the use is necessary for the establishment, exercise or defence of legal claims, or whenever courts are acting in their judicial capacity (for example, when a court issues a court order requiring the processing of Personal Information) 
  • the use is necessary for the purposes of preventive or occupational medicine, medical diagnosis or the provision of health or social care or treatment.

 

These more sensitive special categories of Personal Information include Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning an individual’s sex life or sexual orientation. 

Additional legal justifications may also be available in the country in which you are based and we may also rely on these justifications from time to time. 

Processing of Personal Information relating to criminal convictions and offences is subject to the relevant legal requirements. 

Where we rely on our legitimate business interests or the legitimate interests of a third party to justify the purposes for using your Personal Information, those legitimate interests will be set out in a supplemental privacy notice (which is tailored to our relationship with you where this is useful to provide you with a full picture of how we collect and use Personal Information). In any event our legitimate interests will usually be:

 

  • pursuit of our commercial activities and objectives, or those of a third party (such as direct marketing)

 

  • compliance with legal and regulatory obligations, and any guidelines, standards and codes of conduct (such as detecting or investigating fraud or money laundering)

 

  • improvement and development of our business operations and service offering, or those of a third party

 

  • protection of our business, shareholders, employees and members, or those of a third party (such as ensuring IT network and information security, enforcing claims, including debt collection)

 

  • analysing competition in the market for our services (such as research, including market research).

 

We may need to collect, use and disclose Personal Information in connection with matters of important public interest, for instance when complying with our obligations under anti-money laundering and terrorist financing laws and regulations, and other laws and regulations aimed at preventing financial crime.  In these cases, the legal justification for our use of Personal Information is that the use is necessary for matters of public interest. Additional justifications may also apply depending on the circumstances.

 

Do we record calls and monitor email communications with us?

To ensure that we can meet the needs of our members we may record telephone calls in an effort to:

  • improve the standard of service that we provide by providing our team with feedback and training
  • address queries, concerns or complaints
  • prevent, detect and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks
  • comply with our legal and regulatory obligations

 

We may also monitor electronic communications between us (for example, emails) to protect you, our business and IT infrastructure, and third parties including by:

 

  • identifying and dealing with inappropriate communications
  • looking for and removing any viruses, or other malware, and resolving any other information security issues

 

How long do we keep data for?

We will typically keep your Personal Information for a period of seven years after the expiration date of your policy.   

As a regulated financial services institution, there are laws and regulations that apply to us which set minimum periods for retention of Personal Information.

 

For example:

 

  • where we hold Personal Information to comply with a legal or regulatory obligation, we will keep the information for at least as long as is required to comply with that obligation.

 

  • where we hold Personal Information in order to provide a product or service (such as an insurance policy and claims handling), we will keep the information for at least as long as we provide the product or service, and for a period of seven years after expiry of the policy and the handling of any related claim. 

 

The number of years varies depending on the nature of the product or service provided – for example, for certain insurance policies it may be necessary to keep the Personal Information for several years after the expiry of the policy.  Among other reasons, we retain the information in order to respond to any queries or concerns that may be raised at a later date with respect to the policy or the handling of a claim.  

Typically, for consumer insurance products, the retention period is seven years. 

For further information about the period of time for which we retain your Personal Information, please contact us.

 

Telling us about your marketing preferences

We will provide you with regular opportunities to tell us your marketing preferences, in our communications to you. 

You must consent to receiving marketing communication from us. Similarly, should you wish to opt out or change your marketing preferences at any time please contact us. 

Similarly, you can also opt-out of receiving marketing communications, such as:

 

  • Receiving email messages and text messages from us. If you no longer want to receive marketing emails or text messages from laya healthcare, you can opt-out of receiving these marketing-related messages by clicking on the link to “unsubscribe” provided in each email message, following the stop instructions in a text message, or by contacting us.

 

  • Receiving telephone communications and postal mail from us. If you no longer want to receive marketing via telephone communications or postal mail from laya healthcare, you may opt-out of receiving these marketing communications by contacting us. You may also be able to contact a "Do not call" registry in your country to opt-out on a general basis from receiving marketing communications by telephone, although we may still contact you if you are listed on such a register if you have given your consent.

 

  • Sharing of your Personal Information with our group companies for their marketing purposes. With your consent we may share your Personal Information with our group companies for their own marketing purposes.  If you change your mind, you may opt-out of this sharing by contacting us.

 

  • Sharing of your Personal Information with selected third-party partners for their marketing purposes:  If you have provided your consent we may share your Personal Information with our third-party partners for their own marketing purposes. If you change your mind, you may opt-out of this sharing by contacting us.

 

  • We aim to comply with your opt-out requests within a reasonable time-period and in any event within any period prescribed by law.  Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the databases of third parties with whom we have already shared your Personal Information (i.e. to those to whom we have already provided your Personal Information as of the date on which we respond to your opt-out request). 

 

  • Please also note that if you do opt-out of receiving marketing communications from us, we may still send you other important service and administration communications relating to the services which we provide to you, and you cannot opt-out from these service and administration communications.

  

What are your Personal Information rights?

You have a number of rights in relation to your data, all of which apply in different circumstances:

 

  • Right of access to Personal Information - you have the right to receive a copy of the Personal Information we hold about you and information about how we use it. This right is applicable at all times when we hold your Personal Information (subject to certain exemptions).   

 

  • Right to rectification of Personal Information - you have the right to ask us to correct Personal Information we hold about you where it is incorrect or incomplete. This right is applicable at all times when we hold your Personal Information (subject to certain exemptions)

 

  • Right to erasure of Personal Information - this right is sometimes referred to as 'the right to be forgotten'.  This right entitles you to request that your Personal Information be deleted or removed from our systems and records.  However, this right only applies in certain circumstances.          

 

Examples of when this right applies to Personal Information we hold include (subject to certain exemptions):

  • when we no longer need the Personal Information for the purpose we collected it
  • if you withdraw consent to our use of your information and no other legal justification supports our continued use of your information
  • if you object to the way we use your information and we have no overriding grounds to continue using it
  • if we have used your Personal Information unlawfully
  • if the Personal Information needs to be erased for compliance with law.
  •  Right to restrict processing of Personal Information - you have the right to request that we suspend our use of your Personal Information.  However, this right only applies in certain circumstances.

 

Where we suspend our use of your Personal Information we will still be obliged to store your Personal Information, but any other use of this information while (subject to certain exemptions) our use is suspended will require your consent.

 

You can exercise this right if:

  • you think that the Personal Information we hold about you is not accurate, but this only applies for a period of time that allows us to consider if your Personal Information is in fact inaccurate

 

  • the processing is unlawful and you oppose the erasure of your Personal Information and request the restriction of its use instead

 

  • we no longer need the Personal Information for the purposes we have used it to date, but the Personal Information is required by you in connection with legal claims

 

  • you have objected to our processing of the Personal Information and we are considering whether our reasons for processing override your objection. 

 

  • Right to data portability - this right allows you to obtain your Personal Information in a format which enables you to transfer that Personal Information to another organisation.  However, this right only applies in certain circumstances.

 

You may have the right to have your Personal Information transferred by us directly to the other organisation, if this is technically feasible.       

 

This right will only apply:

 

  • to Personal Information you provided to us

 

  • where we have justified our use of your Personal Information based on your consent

 

  • the fulfilment by us of a contract with you

 

  • if our use of your Personal Information is by electronic means.

 

Right to object to processing of Personal Information - you have the right to object to our use of your Personal Information in certain circumstances.  

You can object to our use of your Personal Information where you have grounds relating to your particular situation and the legal justification we rely on for using your Personal Information is our (or a third party's) legitimate interests. However, we may continue to use your Personal Information, despite your objection, where there are compelling legitimate grounds to do so or we need to use your Personal Information in connection with any legal claims.  

This right is different where it relates to direct marketing and you can read about how to exercise your right to opt-out of receiving any direct marketing in the 'How can you tell us about your marketing preferences?' section of this Privacy Policy. 

You can also object to the use of your Personal Information for direct marketing purposes at any time (including if we are carrying out profiling related to direct marketing). 

Rights relating to automated decision making and profiling - you have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. However, this right only applies in certain circumstances.

This right is not applicable if:

 

  • we need to make the automated decision in order to enter into or fulfil a contract with you

 

  • we are authorised by law to take the automated decision

 

  • you have provided your explicit consent to the decision being taken in this way using your Personal Information.

 

  • Right to withdraw consent to processing of Personal Information - where we have relied upon your consent to process your Personal Information, you have the right to withdraw that consent.  This right only applies where we process Personal Information based upon your consent. 

 

  • Right to complain to the relevant data protection authority - if you think that we have processed your Personal Information in a manner that is not in accordance with data protection law, you can make a complaint to the data protection regulator.  If you live or work in an EEA member state, you may complain to the regulator in that state. This right applies at any time.

 

  • Right to provide instructions regarding the management of your Personal Information after your death (only where such right applies under applicable law)

 

You may have the right to inform us of instructions on how we manage the Personal Information we hold about you after your death. This right is applicable at all times when we hold your Personal Information (only where such right applies under applicable law).

 

If you wish to exercise any your rights, please contact us.

 

 Who to contact about your Personal Information?

If you have any questions or concerns about the way your Personal Information is used by us, please don’t hesitate to contact us.

 

 What user and device data do we collect through Laya healthcare digital services?

Along with our third-party service providers we may collect user and device data in a variety of ways when you use laya healthcare digitals services including: 

  • internet browser and electronic device information
  • app usage data
  • information collected through cookies, pixel tags and other technologies
  • demographic information
  • data grouped together so that it is not possible to link the data to a particular individual, known as aggregated data.  

This information may not reveal your specific identity and therefore may not be Personal Information which is used as described in the earlier sections of this Privacy Policy.

 

 

Method of Data Collection

Examples

Through your internet browser or electronic device

Certain information is collected by most websites or automatically through your electronic device, such as your IP address (i.e. your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, internet browser type and version, electronic device manufacturer and model, language, time of the visit, pages visited, and the name and version of the Laya healthcare services (such as the App) you are using. We use this information to ensure that the Laya healthcare services function properly.

Through your use of an App

When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your electronic device accesses our servers and what information and files have been downloaded to the App based on your device number.

Using cookies and online tracking

We may use cookies and other online tracking tools (with your consent where required by applicable law). Cookies are pieces of information stored directly on the device you are using. Cookies allow us to recognize your device and to collect information such as internet browser type, time spent using Laya healthcare services, pages visited, language preferences and relevant country website. We may use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience while using the Laya healthcare services. In addition, we may use the information to gather statistical information about the usage of the Laya healthcare services in order to understand how they are used, continually improve their design and functionality, and assist us with resolving questions about them. Cookies further allow us to present to you the advertisements or offers that are most likely to appeal to you. We may also use cookies to track your responses to our advertisements and we may use cookies or other files to track your use of other websites.

You can refuse to accept the cookies we use by adjusting your browser settings. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Site and some online products.  We do not respond to browser do not track signals at this time. Third parties may collect information about your use of Laya healthcare services and your use of other websites or online services. For more detailed information about the cookies we use on our laya healthcare site, see below.

Using pixel tags, web beacons, clear GIFs or other similar technologies

We may use pixel tags, web beacons, clear GIFs and other similar technologies with your consent (where required by applicable law). These may be used in connection with some Laya healthcare services and HTML-formatted email messages to, among other things, track the actions of users of Laya healthcare services and email recipients, measure the success of our marketing campaigns and compile statistics about usage of laya healthcare digital services and response rates.

We may use interest-based advertising service providers to customize, target, serve and report on AIG advertisements served across the web and mobile applications, based on information relating to our offline interactions with you, our online interactions with you (on any of your devices) and information received from third parties.  To do this, these service providers may use cookies, pixel tags and other technologies to collect information about your and other users’ use of the Laya healthcare services and third-party sites and mobile applications.  They may also use these technologies along with information they collect about your online use, to recognise you across the devices you use, such as a mobile phone and a laptop.  Our service providers may also match Personal Information we provide to them with your IP address and serve Laya healthcare advertisements to you across the web, based on your IP address.  If you would like to opt out of having your information used for these purposes, visit the self-regulatory program opt out pages at www.aboutads.info/choices/ or www.networkadvertising.org/managing/opt_out.asp to opt out in desktop and mobile web browsers on the particular device from which you access the opt-out options.  Download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile applications.

Physical location

Subject to applicable law (and your consent where required by applicable law), we may collect the physical location of your electronic device by, for example, using satellite, mobile/cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content.

Subject to your marketing preferences and applicable law, we may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. 

In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.

In addition, we may obtain the precise geolocation of your device when you use our mobile applications for travel or other assistance services.  In connection with providing travel or other assistance services, we may share your device’s precise geolocation information with our clients and other entities with whom we work.  You may opt-out of our collection and sharing of precise geolocation information by deleting the mobile application from your device, by disallowing the mobile application to access location services through the permission system used by your device’s operating system, or by following any additional opt-out instructions provided in the privacy notice available within the mobile application.

In some circumstances, physical location information may become your Personal Information if you are identifiable in relation to the physical location information. In such cases, the physical location information will be handled as Personal Information as described in the earlier sections of this Privacy Policy.

Using information provided by you

Some information (for example, your location or preferred means of communication) is collected when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you. 

By aggregating information

We may group information together so that it does not link to a specific individual, i.e. aggregate, and use that information (for example, we may aggregate information to calculate the percentage of our users who have a particular telephone area code).

  

What cookies are used on our website?

We use a number of cookies and tracking technologies on our website. Among other things, cookies help us to understand user behaviour, make our website work better and target online advertising.

Type of Cookie

What it does

What data it collects

What we use the data for

Geolocation cookies

When a visitor visits one of our sites for the first time we read their location from their IP address and use this information to assume the country site that they want to visit. This method is not entirely accurate, however, so when they navigate to a particular country site we use this cookie to store this information and to store the language that they chose to view the site in.

Information relating to which country site and language you have chosen to view.

To ensure that you are presented with the same country site and language as you chose on your last visit to our site without needing to re-select these options

Site catalyst cookies (by Adobe)

This cookie enables us to collect and analyse data about how visitors arrive at our site and then how they interact with our site. The cookie is placed on a visitor’s device on a temporary basis only

Information relating to how you arrived at our site and how you interact with it (e.g. content you view, products you search for and steps taken towards a sale).

To adapt our sites to better serve users’ needs and provide more relevant information. To allow us to undertake anonymous statistical analysis.

DoubleClick cookies

A form of tracking pixel cookie which is stored on site visitors’ devices and tells us whether you have previously visited our site.

The fact that you have previously visited one of our sites.

We use these cookies to know that a visitor has been on our site before which allows us to display an appropriate banner ad on an affiliated network website. One of the advertisement companies that we use is Google, Inc., trading as DoubleClick. For more information on the DoubleClick cookie, or to opt-out from the DoubleClick advertisement cookie please visit: http://www.google.com/privacy/ads/

Affiliate cookies

A form of tracking pixel cookie which tells us which affiliate website you used in order to get to our site.

The transaction ID (which identifies which affiliate website you came through) and a date/time stamp.

To ensure that affiliates who refer sales to us are credited for this.

Optimost cookies

Optimost is a service provided by Hewlett-Packard to analyse customer behaviour when visiting our site.

The cookie has an anonymous “visitor ID” which is a random number generated to identify a visitor and to distinguish between unique and/or repeat visitors.

To analyse visitors’ interaction with our sites to enable us to test and implement improvements to them. To view the Optimost privacy policy, please visit: https://asp.optimost.com/avatar/privacy-policy

Oracle cookies

We use the services of Oracle (www.oracle.com) to serve a persistent cookie on visitors’ browsers when they first visit our web pages. This will not be served if you already have an Oracle cookie on your browser through your use of a third party site.

The fact that you have visited our site for the first time and your browsing activity. Your browsing activity on our sites will not be combined with your activity on third party sites which also use Oracle cookies.

To understand which pages of our sites visitors use or do not use so that we can improve the user experience. For further information, please read the Oracle privacy policy available at www.oracle.com

SessionCam

We also use the SessionCam web site recording service.SessionCam is a product that has been developed by www.servicetick.com

Information relating to mouse clicks/movement, page scrolls and text typed into forms. Information is for internal use only. No bank details or sensitive information is collected.

Information collected is used to improve our website usability and is stored and used for aggregated and statistical reporting.

 

 

Who is responsible for third party services accessed via laya healthcare digital services?

We are not responsible for the privacy, information or other practices of any third parties, including any third party operating any site or service to which the laya healthcare digital services link. 

 

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which laya healthcare digital services link.  The inclusion of a link on laya healthcare digital services does not imply endorsement of the linked site or service by us or by our group companies.

 

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the information security practices) of other organizations, such as Facebook®, Twitter®, Apple®, Google®, Microsoft®, RIM/Blackberry® or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or electronic device manufacturer, including any Personal Information you disclose to other organizations through or in connection with laya healthcare digital services.

 

 

When was this Privacy Policy last updated?

This Privacy Policy was last updated in May 2018. We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business activities, legal requirements, and the manner in which we process Personal Information.  We will place updates on this website and where appropriate we will give reasonable notice of any changes.