PURPOSE. Fraser Fontaine & Kong Limited (FFK) provides insurance brokerage, risk management, employee benefits, and related services to clients. FFK values your trust in us and is committed to protecting your privacy and the confidentiality of your Personal Information.
The purpose of this Privacy Statement is to inform you on how we treat your personal information.
INFORMATION WE COLLECT AND HOW WE USE IT. The types of personal information we may collect (directly from you or third parties) depend on the nature of the relationship that you have with FFK. Regardless of the source, we only collect information relevant for the purposes of processing information to which you have consented, except where required by law, to protect the interests of FFK or in the discharge of public duty.
Below are some of our sources for collecting personal information and, once collected, how we use it.
Customers. In order to service your business, FFK obtains information (including financial and health) about you from some or all the following sources:
- Information you provide on the insurance application and other forms;
- Information from your transactions with us;
- Individually identifiable information when you apply for an insurance policy
- Information from our website, such as site visit data and information collection devices (cookies).
From these sources we may obtain information such as:
- Name, address (e-mail address, if applicable), telephone number, date of birth, government identifier;
- Driver’s License Number, and accident and violation history;
- Credit Card and Banking information to facilitate payment
- Health information as submitted on claims forms;
- Payment and account history, including claims
- Information about beneficial owners, intermediaries and other third parties such as your spouse, where this information is required by law
- For legal entities such as companies, partnerships, trusts, estate, we may collect the information referred to above for each authorized person, partner, trustee, executor and club member, as appropriate
Websites. We collect two types of information about users of our sites:
- Information that users provide through optional, voluntary These are voluntary submissions from disclosures regarding customers’ profile and participation in polls, surveys, completion of online forms and subscriptions for services.
- Information that we gather through aggregated tracking and information derived mainly by tallying page views through out our sites.
We shall not disclose any information collected from any user unless such disclosure is permitted by law, required by an order of a court of competent jurisdiction or the disclosure is consented to by the owner of the information.
Collection of information from websites
- Optional Voluntary We offer the following services, which require some type of voluntary submission of personal information by users:
- Insurance products
- Usage We track user traffic patterns throughout our site. However, we do not correlate this information with data about individual users. We break down overall usage statistics according to a user’s domain name, browser type, and MIME (Multipurpose Internet Mail Extension) type by reading this information from the browser string (information contained in every user’s browser).
Use of information. We use information provided by users through analytics to enhance their experience on our site, whether to provide interactive or personalized elements on the site; to better prepare future content based on the interests of our users or to develop new leads for potential sales.
Sharing of the Information. We use the information provided by users to tailor our content to suit your needs. We will only share information about individual users with any third party in circumstances where we are legally permitted or required for business operations to provide information.
Network Security. We operate secure data networks which comply with the industry standards for information systems security. Our security and privacy policies are periodically reviewed and enhanced as necessary and only authorized individuals have access to the information provided by users. Notwithstanding the foregoing, every reasonable effort will be made to secure your data, but we cannot guarantee that the information you share will be secure during transmission to our web-servers.
INFORMATION WE SHARE. We will not disclose our current and former customers´ information to affiliated or nonaffiliated third parties, except as permitted by law. To the extent permitted by law, we may disclose to either affiliated or non-affiliated third parties all of the information that we collect about our customers, as described in this section.
In general, any disclosures to affiliated or non-affiliated third parties will be for the purpose of them providing services for us so that we may more efficiently administer your policy or product and process the transactions and services you request. Our agreements with third parties require them to use this information responsibly and restrict their ability to share this information with other parties. We do not sell information to either affiliated or non-affiliated parties.
We do not internally or externally share health information other than, as permitted by law, to process transactions or to provide services that you have requested or to facilitate transparency or risk mitigation.
RETENTION OF YOUR INFORMATION. We will only retain your personal information as long as it is necessary or as required by law. When we destroy the information, we will use safeguards to prevent unauthorized parties from gaining access to the information during the process.
SAFEGUARDING YOUR INFORMATION. FFK has security practices and procedures in place to prevent unauthorized access to your nonpublic personal information. Our practices of safeguarding your information help protect against the criminal use of the information. FFK administrative, technical and physical safeguards are designed to protect personal information that is received against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
We restrict access to information about you to only those employees who need to know that information to perform their job. We maintain physical, electronic, and procedural safeguards, which comply with local laws and regulations to guard your information.
QUESTIONS. You have a right to know the information we have about you. You must request this in writing. If you believe any of the information is erroneous, please explain in writing. If we do not agree that it needs correction, we will notify you and you will be entitled to provide a statement of disagreement which we will file with the information.
For requests about your information, or questions about this Privacy Statement, please write or call: Fraser Fontaine & Kong Limited
Attention: I.T Manager
28 Pawsey Place
PRIVACY NOTICE REGARDING PERSONAL INFORMATION FOR DATA SUBJECTS WHO RESIDE IN THE EUROPEAN UNION
EU GENERAL DATA PROTECTION REGULATION (“GDPR”). Although we do not market or sell products or services in the European Economic Area (“EEA”), in order to continue serving an existing business relationship, we may incidentally collect or transfer personal information from individuals (“Data Subjects”) located within the EEA. Personal information that may be collected by us from a Data Subject in the EEA may include:
- PHONE NUMBER
- EMAIL ADDRESS
- SPECIFIC INFORMATION GATHERED ON AML QUESTIONNAIRE
- OTHER DATA ELEMENTS
LAWFUL GROUNDS TO PROCESS AND OBTAIN CONSENT. Data subjects whose personal information is collected in the EEA may withdraw consent at any time where consent is the lawful basis for processing his/her information. Should a data subject withdraw consent for processing or otherwise object to processing that impedes FFK’s ability to comply with applicable regulations, a data subject may be unable to avail him/herself of the products or services that FFK provides.
DATA SUBJECTS’ RIGHTS. All individuals whose personal information is held by FFK have the right to:
- Ask what information FFK holds about them and why;
- Ask for a copy of such information or access to such information;
- Be informed how to correct or keep that information up to date;
- Be informed on how FFK is meeting its data protection
Furthermore, for data collected in the EEA, data subjects have the right to:
- Ask for a copy of such information to be sent to a third party;
- Ask for data to be erased if possible and required under the GDPR;
- Ask for processing of personal information to be restricted if possible and required under GDPR;
- Object to processing of personal information if possible and required under GDPR;
- Object to automated decision-making where applicable; and
- Contact a supervisory authority in the EEA to lodge a complaint regarding FFK processing of your personal
AUTOMATED DECISION-MAKING. FFK does not engage in automated decision-making as defined by the GDPR.
NON-DISCLOSURE OF INFORMATION. FFK does not share any nonpublic personal information with any non-affiliated third parties, except in the following circumstances:
- As necessary to provide the service that the customer has requested or authorized, or to maintain and service the customer’s account;
- As required by regulatory authorities or law enforcement officials who have jurisdiction over FFK or as otherwise required by any applicable law; and
- To the extent reasonably necessary to prevent fraud and unauthorized
- To the extent reasonably necessary to facilitate business
FFK employees are prohibited, either during or after termination of their employment, from disclosing nonpublic personal information to any person or entity outside FFK, including family members, except under the circumstances described above. An employee is permitted to disclose nonpublic personal information only to such other employees who need to have access to such information to deliver our services to the customer.
SECURITY AND DISPOSAL OF INFORMATION. FFK restricts access to nonpublic personal information to those employees who need to know such information to provide services to our customers. All electronic or computer files containing such information shall be secured and protected from access by unauthorized persons. Electronic and paper records used for business purposes must not be left in places where they are visible to unauthorized persons. Data printouts and files must be disposed of securely when no longer needed.
FFK’s information safeguarding standards encompass all aspects of its business and are adopted in its Information Security Standards document, which include the following key Standards.
FFK CONTACT INFORMATION FOR PERSONS LOCATED WITHIN THE EEA.
If you are located in the European Economic Area (“EEA”) or Switzerland and have questions or concerns regarding the processing of your personal information, you may contact our EU Representative at: firstname.lastname@example.org; or write to us at:
Fraser Fontaine & Kong Limited Attention: I.T Manager
28 Pawsey Place