Privacy Policy

In this Policy “We”, “Our” and “Us” means Insurance Company of North America, a Chubb Company (Chubb Philippines). “You” and “Your” refers to Our customers and prospective customers as well as those who use Our website. “Chubb Group of Companies” means other Chubb entities who may be located outside the Philippines, such as the offices of Chubb located in Singapore, UK or USA.

What is Personal Information?

Personal Information is defined in the Data Privacy Act of 2012 (Republic Act No. 10173) and refers to any information whether recorded in a material form or not, from which the identify of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.

Personal Information includes sensitive personal information. Sensitive Personal information refers, among others, to personal information:

1.  About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations;
2. About an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings; and
3. Issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns.

We value Our partners and Our customers’ trust in Us and We are committed to maintaining the confidentiality and privacy of Your Personal Information. This Policy details how We collect, disclose and handle Your Personal Information in accordance with the requirements of the Data Privacy Act, its Implementing Rules and Regulations and other issuances of the National Privacy Commission.

In dealing with Us, You agree to provide Us with Your Personal Information, which will be stored, used and disclosed by Us in accordance with this Policy. You do not have to provide Us with Your Personal Information. However, should You choose not to, it is important for You to understand that this may mean that We may not be able to provide You or Your organization with insurance, respond to any claim, or offer other products and services to You or Your organization.

Anonymity and pseudonymity

Where possible, You have the option of interacting with Us anonymously or using a pseudonym. For example, You may use some of Our online facilities without having to reveal any Personal Information, however it will generally be impracticable for You to deal with Us anonymously or use a pseudonym if You wish to use Our services or have Us arrange an insurance product for You.

Our Policy may change from time to time and where this occurs, the updated Policy will be posted to Our website.

In the course of providing insurance products and processing insurance claims, We may collect Your Personal Information to administer Our associated business functions and activities. Generally, We collect Your Personal Information for the following reasons:

1. maintaining and administering Our insurance products and services (for example: processing requests for insurance quotes, applications for insurance, underwriting and pricing policies, issuing You with a policy, managing claims, complaints handling , processing payments, etc.);
2. marketing services and products provided by Us or those We have an association with, that might be of interest to You (for example: direct marketing);
3. improving Our services and products (for example: training and development of Our representatives, product and service research, data analysis and business strategy development, etc.);
4. to gather data about the usage of Our website, products, applications and other platforms for research, marketing, product development and other purposes (for example: the data may be used to enhance user experience so that You do not have to provide certain information every time You return to Our website).

The Personal Information We collect and hold depends on the type of product and/or service sought, but generally includes:

1. contact information (for example: Your name, address details, contact numbers, email address, etc);
2. details relating to Your employment and employment history (for example: compensation, hours worked, duties performed, etc.);
3. Your date of birth and gender;
4. Your financial situation;
5. Your prior insurance history;
6. information relevant to Our products or services;
7. other information such as Your opinions, statements and endorsements collected from You or through surveys and questionnaires that You have completed through third parties engaged by Us; and
8. any relevant payment or billing information, such as bank account details, direct debit and credit card details or premium funding and insurance payment arrangements.

We will request your consent to collect sensitive personal information about You when determining Your eligibility for insurance cover, providing You with a quote for an insurance policy, updating an insurance policy or administering a claim under an insurance policy.

The type of sensitive information We are likely to collect can include details of Your:

1. criminal record;
2. health/medical information; and
3. membership of a professional or trade association.

Directly

We collect Your Personal Information from You in various ways and at various points of interaction with Us, such as when you apply for one of Our products or services or make a claim. We will collect Your Personal Information via Our website or partner websites, Our partners’ mobile phone applications, by telephone, facsimile or email, when you enter a competition or voluntarily participate in a survey or when you provide us with information (such as on an application form or claim form).

We will generally collect Your Personal Information directly from You except when it is unreasonable or impracticable for Us to do so, or as otherwise provided under this Policy.

Indirectly

In so far as they relate to Our services and activities, We may collect Personal Information about You indirectly from other parties that are relevant to our business, a policy or claim, such as:

1. insurance intermediaries and service providers engaged by Us or a third party who partners with Us, including Our distributors, brokers, clubs, associations, member loyalty or rewards program providers and other relevant organizations;
   
2. policyholders or others who are authorized or noted on the policy as having a legal interest in it (such as Your employer, in the case of group policies);
3. family members, agents or anyone else You have authorized to deal with Us on Your behalf;
4. medical providers and health care workers;
5. witnesses in relation to claims;
6. partner websites;
7. Our partners’ mobile phone applications.

Our website

By using Our website You also agree to Our Terms of Use and acknowledge that We may use cookies to provide a number of services to you. Cookies are text files which are stored on Your computer so that each time You visit a web page Your IP address and the name of the website You visited is recorded. The next time You visit the same web site, the text file communicates that You have been there before and the website may tailor the content, such as pop ups, to You. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from Chubb websites and apps and elsewhere on the internet and use that information to provide measurement services and target advertisements to you.

Your cookie choices

You can enable or disable cookies by adjusting your browser settings. This allows you to reject the placement of all cookies (except strictly necessary cookies). You can also delete cookies which have already been placed on your device.

Please remember that disabling or deleting some or all cookies may prevent some web services (including on this website) from functioning correctly, and may lead to a less smooth or less personalized browsing experience.

You should visit the "Help" section of your browser for how to manage your cookie settings, or follow the links below:

• Microsoft Edge: https://support.microsoft.com/en-us/help/4027947/microsoft-edge-delete-cookies
• Internet Explorer: https://support.microsoft.com/en-us/help/260971/description-of-cookies
• Mozilla Firefox: https://support.mozilla.com/en-US/kb/Cookies
  
• Google Chrome: https://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647
• Safari: https://support.apple.com/kb/PH5042
• Opera: https://www.opera.com/browser/tutorials/security/privacy/

For further general information on cookies and more detailed advice on how to disable and enable them please go to https://www.allaboutcookies.org.

Third party platforms

Sometimes We use third party platforms (for example: a partner website or mobile device application) to deliver and collect information. These are platforms hosted and managed by organizations other than ourselves. Before deciding to contribute to any third party platform, You should consult the privacy policies relevant to that third party site.

Unsolicited Personal Information

Unsolicited Personal Information can be characterized as information that We receive but have not taken active steps to collect. An example would be documents You attach to an insurance application or claim form not requested or needed by Us.

Where We receive unsolicited Personal Information, We will destroy or de-identify the information as soon as it is practicable, but only if it is lawful and reasonable to do so.

We will only use and disclose Your Personal Information for the purpose it was given to us, or as otherwise permitted by law, and will not share it with any other party except in accordance with this Policy and under the following circumstances:

1.  if disclosure is required by an industry body or by law or requested by a statutory, regulatory or government authority;
   
2. where You have consented to the use or disclosure – which may be given expressly or may reasonably be implied by Your conduct. For example, where access to Our products has been facilitated through a third party, You consent through your actions that We may share Your information with that third party (Third parties can include an insurance broker, marketing agency, airline, travel agent, authorized representative, distributor, mortgage broker, sporting association, member club or association, credit facility/provider, etc.);
3. where it is necessary for a third party to assist Us in providing Our services, provide professional advice to Us or provide additional services to You (for example: a mailing house, reinsurers, insurance intermediaries, insurance reference bureau, lawyers, accountants, loss adjusters and others involved in the claims handling process, non-insurance related partner service providers, etc.);
4. for purposes related to: research (including market research), planning, service development, security, testing and risk management;
5. if disclosure is required for the purpose of conducting business analysis in order to improve or promote Our products and services including direct marketing (see below).

Related and unrelated third parties to whom Your Personal Information is disclosed are required to keep the information confidential and only use it for the same purposes We are permitted to use it. This can include third parties promoting services and products provided by Us or those We have an association with, that might be of interest to You. These third parties may also combine the Personal Information We disclose to them with information they already hold about You subject to their own privacy policy, in order to provide You with more relevant advertising about Our or their own products and services.

Direct Marketing

We may from time to time engage in direct marketing activities to advise You about or offer You products or services that may be of interest to you. Personal Information You or an associated party have provided us will be held on file for marketing purposes until you opt out of receiving such information.

We may use or disclose Your Personal Information for direct marketing purposes if:

1. the information has been collected from You directly;
   
2. You would reasonably expect that the Personal Information would be used or disclosed for that purpose;
3. We have provided You with a simple means by which You can easily request not to receive direct marketing communications; and
4. You have not made such a request not to receive direct marketing communications.

Third party marketing service providers may combine the personal information We disclose to them with information they already hold about You, in order to serve You with more relevant advertising about Our products and services.

Where We have collected Your Personal Information from a third party, that Personal Information may be used or disclosed for direct marketing if:

1. You have consented to its use or disclosure, or if it was impracticable to obtain Your consent; or
   
2. You were provided with the option to opt-out of direct marketing communications or were otherwise made aware that You could make such a request; and
3. You did not make such a request to opt-out of direct marketing communications.

If You request confirmation of the source of Your Personal Information used by Us for direct marketing purposes, We will endeavour to provide it to You within a reasonable period, unless it is impracticable or unreasonable for Us to do so.

We will not use or disclose Your sensitive information for direct marketing purposes without Your consent.

Overseas Entities

In some circumstances, in order to provide Our services to You, We may need to disclose Your Personal Information to other entities within the Chubb Group of Companies who may be located outside the Philippines, such as the offices of Chubb located in Singapore, UK or USA. We may also need to transfer Your Personal Information to third parties with whom We or the Chubb Group of Companies have subcontracted to provide specific services for Us (such as claims handling) who may be located outside the Philippines. These entities and their locations may change from time to time. Please contact us, if you would like a full list of the countries in which these third parties are located.

In circumstances where We disclose Your Personal Information to the Chubb Group of Companies or third parties outside of the Philippines, We have contractual provisions in place requiring these entities to comply with the requirements of the Data Privacy Act of 2012 and its Implementing Rules and Regulations in order to protect Your Personal Information against unauthorized disclosure, misuse or loss.

Storage

We hold Personal Information within Our own data storage devices or with a third party provider of data storage including those outside of the Philippines.

Security

We recognize that You may be concerned about the security and confidentiality of the Personal Information provided to Us. We will take such steps as are reasonable in the circumstances to protect the security of Personal Information from:

1. misuse, interference or loss; and
   
2. unauthorized access, use, modification or disclosure.

These steps include password protection for accessing Our electronic IT systems, securing paper files in locked cabinets and physical access restrictions.

In relation to data stored on Our own servers, We take all reasonable steps to ensure data security. In relation to data stored on third party providers of data storage, We have contractual provisions in place requiring these entities to comply with the requirements of the Data Privacy Act of 2012in order to protect Your Personal Information against unauthorized disclosure, misuse or loss.

Document Destruction

We will take such steps as are reasonable in the circumstances to destroy or de-identify Personal Information, in a secure manner, when it is no longer needed or required to be retained by law or court/tribunal order in accordance with our internal policy and procedure.

When We deal with You We will take reasonable steps to confirm the details of the Personal Information We hold about You and ask You if there are any changes required.

The accuracy of Personal Information depends largely on the information You provide to Us, so We rely on You to:

1. promptly inform Us of changes to Your Personal Information (such as Your name or address); and
   
2.  let Us know if You become aware of any errors in Your Personal Information that We hold.

Generally, You can access the Personal Information We hold about You and if required request corrections. This right is subject to some exceptions set out in the Data Privacy Act of 2012, its Implementing Rules and Regulations and other issuances of the National Privacy Commission.

When You seek to access or correct any Personal Information We hold about You, You should contact Us by using and completing the Personal Information Request Form and submit it to Our Data Protection Officer. In all cases We will need to verify Your identity before actioning any request. We will respond to a request for access or correction within a reasonable period after receipt of the request.

If We refuse to give You access or access in a manner requested by You, We will provide written reasons together with guidance on how You can make a complaint about the refusal.

If We do not agree to make the requested changes to the Personal Information held, We will provide You with Our written reasons and You will have an opportunity to provide a statement as to why the information should be changed or corrected. Where We have previously disclosed Your Personal Information to a third party and You request Us to notify that third party of the correction, We will take reasonable steps to provide the notification, unless it is impracticable or unlawful for Us to do so.

Cost of access and corrections

We will not usually charge for a request to access or change Your Personal Information. However, if We decide to apply a charge for providing the information, this will be limited to Our reasonable costs in locating and compiling the information.

Please contact Our Data Protection Officer, if you have a query relating to Our treatment of Your personal information or Our Privacy Policy.

The Data Protection Officer
Insurance Company of North America (a Chubb Company)
Address    24th Floor Zuellig Building
                  Makati Avenue corner Paseo De Roxas
                  Makati City 1226, Philippines
Email        DPO.PH@chubb.com