Data Protection & Privacy Statement

Royal Crown Insurance is committed to protecting the privacy and security of those with whom we interact.

We recognise the need to respect and protect information that is collected or disclosed to us (called “Personal Information” explained below).  This notice is intended to tell you how we use your Personal Information and describes how we collect and use your Personal Information during and after your relationship with us, in accordance with applicable Data Protection Laws. Royal Crown is committed to handling data fairly and lawfully and takes its data protection obligations seriously. ROYAL CROWN ensures that it processes Personal Information in compliance with applicable data protection laws, including, without limitation, the General Data Protection Regulation 2016/679 (“GDPR”).

WHAT IS PERSONAL INFORMATION AND WHAT PERSONAL INFORMATION DOES ROYAL CROWN COLLECT ABOUT YOU? What is Personal Information? For the purposes of this Data Protection Notice “Personal Information” consists of any information that relates to you and/or information from which you can be identified, directly or indirectly. For example, information which identifies you may consist of your name, address, telephone number, photographs, location data, an online identifier (e.g. cookies identifiers and your IP address) or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity. When we combine other information (i.e. information that does not, on its own, identify you) with Personal Information, we treat the combined information as Personal Information. What Personal Information does ROYAL CROWN collect? We may collect, use, store and transfer different kinds of Personal Information about visitors to our website who may wish to complete our online Proposal Forms. We may also collect information from our consultants and contractors, including our agents, employees and clients who have access to the company specific-category portals. The Personal Information we collect may include as follows:

  • Name
  • Contact details
  • Date of birth
  • Country of Residence/Ethnicity
  • Vehicle Registration numbers
  • Property Insured or to be Insured – Descriptions and Locations
  • Sums Insured or Limits of Liability to be Insured
  • Financial / bank account / payment information
  • Job role, position and company information
  • Employment information
  • Queries and complaints

We may also obtain Special Category Personal Data (as defined in the GDPR) such as healthcare information (for example, medical conditions for the purposes of execution of our Medical Healthcare Policy).  We may also obtain criminal records information or information regarding previous road traffic incident-related information. We may also obtain bankruptcy and insolvency information. Provision of data Our clients are obliged to provide Personal Information to us. This is so we can properly execute our insurance contracts and thereby handle claims. We must collect data in order to provide excellent insurance services. Failure to provide information may mean that we cannot execute the insurance contract and thereby handle any claim in the proper manner. Our potential customers are obliged to provide Personal Information to us. This is so we can verify customer data and so that our potential customers can begin collaboration with us. Failure to provide this information may mean that we cannot perform this contract and you would not have access to our products.

HOW IS YOUR PERSONAL INFORMATION COLLECTED? ROYAL CROWN collects information through you, for example, when you make enquiries with us or through a Proposal Form or a query towards us via the “Contact Us” facility. Other information will be obtained during the course of insurance contract, should that be completed, such as your employees, authorised drivers, to enable us to carry out the purposes of the specific type of insurance contract you select. We also obtain information through the use of technology, such as Cookies, when you use our online portal, and to allow you to access restricted areas of the website without entering your personal details each time. For more information about Cookies, please see the Terms and Conditions on the ROYAL CROWN website.

HOW DO WE USE YOUR INFORMATION? We may use the Personal Information we collect for the following purposes:

  • To administer and manage your insurance contract with ROYAL CROWN
  • To maintain details of your insurance cover, such as vehicle registration numbers and authorised drivers
  • To maintain records of Sums Insured and Limits of Liability in Insurance Contract
  • To maintain Premium Payment Warranty Term Records and connect with you for reminders of premiums due
  • To enhance and improve the ROYAL CROWN’s service and qualifications
  • To provide customer service support and including training and quality purposes.
  • To maintain and review invoices, debit and credit notes and other financial information
  • To fulfil our disciplinary and regulatory functions
  • For marketing purposes

The law allows us to use the Personal Information as set out above on the basis that the processing is necessary for the performance of a contract with you, or we are acting in our “legitimate interests”, for example, for the purposes of providing goods, services, and support as an effective professional association for our clients. Where we collect Special Category Personal Data we will not use this except for the purposes of processing a possible Healthcare Claim towards our company.

Marketing communications ROYAL CROWN will not use your Personal Information to send you marketing communications by mail, telephone or email. For situations where you are a policyholder with us, any information sent to you is for the performance of the contract with you.

TO WHOM DO WE DISCLOSE YOUR INFORMATION? We will only use your Personal Information for our internal business purposes, for example, as set out above.

We do share your information with third parties, for example with other insurance companies regarding your claims history. We do this for the execution of the insurance contract with us or where we have another lawful basis for doing so. We may share your information with third parties such as our external auditors, actuaries and other professional bodies. We would do this for the effective performance of your insurance contract with us, and/or so that we can comply with any legal obligations. We may also share your information with third parties where we outsource certain functions, including but not limited to, our assessment service providers, Road and Accident Services, lawyers and other service products that we use. We would do this, for the effective performance of your insurance contract with us, and for our legitimate interests, such as the effective financial and business management of ROYAL CROWN as well as your own interest and best possible service to be provided to you. We may also disclose Personal Information to establish, exercise or defend our legal rights including providing information to others and/or in connection with any ongoing or prospective legal proceedings. We may also disclose Personal Information to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personal Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal Information. We never sell any of your Personal Information to third parties.

WHAT DO WE DO TO KEEP YOUR INFORMATION SECURE? We have put in place appropriate physical and technical measures to safeguard the Personal Information we collect in connection with our services. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. However, please note that although we take appropriate steps to protect your Personal Information, no website, product, device, online application or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Information.

DATA RETENTION – HOW LONG WE WILL STORE/KEEP YOUR PERSONAL INFORMATION ROYAL CROWN retains Personal Information for as long as necessary to fulfil the purposes for which your Personal Information has been collected as outlined in this Data Protection and Privacy Statement unless a longer retention period is required by law. When your Personal Information is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law. As a general Rule, your Personal Information is kept for the duration of the Insurance Contract.

ACCESSING YOUR PERSONAL INFORMATION AND OTHER RIGHTS YOU HAVE ROYAL CROWN will collect, store and process your Personal Information in accordance with your rights under any applicable Data Protection Laws. Under certain circumstances, you have the following rights in relation to your Personal Information: I. Subject Access – you have the right to request details of the Personal Information which we hold about you and copies of such Personal Information. II. Right to Withdraw Consent – where our use of your Personal Information is based upon your consent, you have the right to withdraw such consent at any time. In the event you wish to withdraw your consent to processing, please contact us using the details provided in clause 16 below. III. Data Portability – you may, in certain circumstances, request us to port (i.e. transmit) your Personal Information directly to another organisation. IV. Rectification – we want to ensure that the Personal Information about you that we hold is accurate and up to date. If you think that any information we have about you is incorrect or incomplete, please let us know. To the extent required by applicable laws, we will rectify or update any incorrect or inaccurate Personal Information about you. V. Erasure (‘right to be forgotten’) – you have the right to have your Personal Information ‘erased’ in certain specified situations. VI. Restriction of processing – you have the right in certain specified situations to require us to stop processing your Personal Information and to only store such Personal Information.  VII. Object to processing – You have the right to object to specific types of processing of your Personal Information, such as, where we are processing your Personal Information for the purposes of direct marketing. VIII. Prevent automated decision-taking – in certain circumstances, you have the right not to be subject to decisions being taken solely on the basis of automated processing.

Please keep in mind that any of the above actions may result in difficulty of execution of the insurance contract and the handling of any claim you may submit to us or that may be submitted by a third party and involves you personally. Complaints If you are concerned that we have not complied with your legal rights under applicable Data Protection Laws, you may contact the Cyprus Commissioner for Data Protection Office. (http://www.dataprotection.gov.cy/)

COOKIES What are cookies? ROYAL CROWN as well as certain other third parties that provide content, advertising, or other functionality on our Services, may use cookies and other technologies, including web beacons, action tags, pixel tags. Cookies are small text files that can be read by a web server in the domain that put the cookie on your hard drive. Cookies are assigned to and stored in a user’s internet browser on a temporary (for the duration of the online session only) or persistent basis (cookie stays on the computer after the internet browser or device has been closed). Cookies collect and store information about a user’s preferences, product usage, content viewed, and registration information which allows for ROYAL CROWN to provide users an enhanced and customised experience when engaging with our Products. We may use cookies to store your preferences and settings, help you with signing in, provide targeted ads, and analyse site operations.

Further information on cookies For further information on what cookies are, how ROYAL CROWN and other third parties use them, and for details of how cookies can be disabled, please see allaboutcookies.org

DATA PROTECTION OFFICER The ROYAL CROWN has appointed Mr. Haris Neoptolemou, Chief Financial Officer of ROYAL CROWN INSRUNCE COMPANY LTD as Data Protection Officer to advise and guide the ROYAL CROWN to ensure continued compliance with Data Protection Laws.

CHANGES TO THIS DATA PROTECTION NOTICE It is also important that you check back often for updates to the Data Protection and Privacy Statement, as we may change this Data Protection and Privacy Statement from time to time. The “Date last updated” legend at the bottom of this page states when the Data Protection and Privacy Statement was last updated and any changes will become effective upon our posting of the revised Data Protection and Privacy Statement.  We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. We will provide this notice by email or by posting a notice of the changes on our website.

CONTACT US / FURTHER INFORMATION If you have any queries at all in relation to your data and how we protect your data rights, please contact us: Contact: Anthie Zachariadou Position: General Counsel Address: Mnasiadou 20 Nicosia 1065 Cyprus Email: anthie@royalcrowninsurance.eu

Date last updated: 25th May 2018