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Privacy Notice

Utmost PanEurope dac recognises that protecting personal information, including special categories of data (sometimes referred to as sensitive personal data), is very important to you and that you have an interest in how we collect, use, store and share such information. This data protection privacy notice sets out how we will collect, use and protect your information and any information provided by other parties about you.

If you have any questions, please contact us using the details provided at the end of this document.

Contents

Who is Utmost PanEurope designated activity company
How we collect your personal data
Personal data we may collect
Special categories of data
What your information is used for
Marketing and profiling by us
Legal basis for using your information
Who we share your information with
Where we use your information
How long we keep your information for
What if you don’t provide information to us?
Your rights
How to update the information we hold about you
Changing and updating this privacy notice
Our Data Protection Officer contact details
Complaints

Who is Utmost PanEurope designated activity company

Utmost PanEurope designated activity company (“Utmost PanEurope”) is a life insurance company registered in Ireland and regulated by the Central Bank of Ireland. Where Utmost PanEurope conducts business on a freedom of services basis in another member state we are subject to limited regulation by the host member state regulatory authority. Utmost PanEurope provides wealth management, savings, investments and employee benefits solutions to individuals, corporates and institutions across Europe.

How we collect your personal data

Your personal data (and, if applicable, that of other people insured under your policy of insurance or people making a claim on the policy or beneficiaries you designate for your policy) will be gathered and processed by Utmost PanEurope staff or, where you choose to use them, our online services.

In order to gather the personal data we need in order to provide you with a policy we may:

  • obtain personal information directly from you, your broker (or other representative) or anybody else insured under your policy of insurance;
  • obtain personal information from third parties with whom you and/or anybody insured under your policy of insurance have engaged in accordance with the terms and conditions of the policy, including medical practitioners;
  • carry out credit searches internally or with one or more credit checking or credit reference agencies.

We may request details about you or anybody else insured under your policy of insurance regarding your or their health and in particular any medical conditions affecting you or them

When you use our online services, we gather certain information automatically and store it in files. This information includes IP addresses, browser type, internet service provider, referring/exit pages, date timestamp and click stream path. This data does not contain any personal identifiable information and is used to analyse trends, to administer the site and to track users’ movements around the website during a particular session and to gather demographic data.

It is important that the information you give us is correct. You have a legal obligation to take reasonable care not to provide us with inaccurate, incorrect or incomplete information when taking out an insurance policy. If this happens Utmost PanEurope has certain legal rights which may include the avoidance of the contract of insurance and the possibility of refusing any claims made by you or others in respect of your policy.

Personal data we may collect

We need to collect many categories of personal data (about you and other parties) for the purposes listed below under ‘What your information is used for’. The following category headings and types of data are a non-exhaustive list of data we may collect:

Policy information: Information such as name, address, date of birth, gender, driving licence details, passport details, payment details, tax identification number, employment details, location information, life assured details, beneficiary details, source of funds etc.

Claims information: Identity of a beneficiary including name, address, passport details, proof of relationship with the life assured, evidence that the insured event has occurred including certificate of death etc.

Special categories of data

In addition to the categories of data detailed above Utmost PanEurope may be obliged to collect the following categories of data in certain circumstances:

Sensitive categories of data or Personal Sensitive Data such as health information, trade union membership or criminal convictions will only be collected and processed by us with your express consent i.e. we need your permission before we can process such data.

Information in respect of a minorPersonal data in respect of a minor will be processed with the consent of a parent or legal guardian only. A minor for the purposes of this privacy notice is a person of the age stipulated in the Data Protection Act 2018.

What your information is used for

You have provided or intend to provide Utmost PanEurope with certain information. Below are some examples of how we may use your information:

(1) (a) If you are a policyholder we will use your information as follows:

  • Reviewing transactions and correspondence to enable us to deal with your queries;
  • Managing and administering your policy in accordance with the terms and conditions;
  • Processing transactions you request with respect to your policy including applications for new business, top-ups and surrenders;
  • Managing our relationship with you (for example, updating you on changes to our business or updating your record with us if you change your address and otherwise contacting you);
  • Responding to any complaints you make;
  • Providing your information to third parties who we may appoint in accordance with the terms and conditions of your policy.

(b) If you are a claimant we will use your information as follows:

  • Managing and administering your claim in accordance with the policy’s terms and conditions;
  • Responding to any complaints you make.

(2) To meet legal and regulatory obligations

As a regulated life insurance company we are required to comply with a range of different legal obligations such as tax reporting, data protection and financial crime prevention. Sometimes we have to share your information with regulatory authorities, for example:

  • Sharing information with Financial Services Ombudsmen in relation to complaints you make;
  • Reporting information to tax authorities including, for example, reporting under the Foreign Account Tax Compliance Act (“FATCA”) and Common Reporting Standard (“CRS”) requirements;
  • Meeting obligations we have in relation to the prevention and detection of crime such as money laundering, the reporting of suspicious transactions and requirements to check our records against financial sanctions lists and to report any matches.

(3) To improve our business

From time to time we may request feedback from our customers in order to improve the service we offer, for example by conducting customer satisfaction surveys.

Marketing and Profiling by us

We will communicate with you only to share important information about your policy or changes to our business. We will not conduct any marketing activity with you without your explicit consent to do so.

Legal basis for using your information

We will only collect, use and share your information where we have a valid reason to do so under data protection legislation. We have four main reasons for collecting and using your information which are set out below. Often we will need your information for more than one reason, for example, in order to perform our contractual and legal obligations.

1. Contractual obligationsWe need to process your personal details and in some cases sensitive data before we can enter into an insurance contract with you as part of the application process. Once the contract is in place, the processing of your personal information is necessary for the performance of this contract, for example using your bank account details to process payments.

2. Legal obligationswe may need certain information from you in order to meet our legal obligations; for example, we require proof of identity (e.g. certified copy of a passport) to meet our anti-money-laundering obligations.

3. Our business interestswe strive continually to improve how we do business with you and how to develop our service to you; for example, we may undertake a survey of our policyholders to determine how we can improve our relationship with you.

4. Consentwe need your consent to use sensitive information about you; for example, health information which we obtain from you. You have the right to withdraw your consent at any time. Please see the section on ‘Your rights’ for further information.

Who we share your information with

1. Group companies

We may share your data with other companies in our corporate group as part of our commitment to offer you financial products and services that may be of interest to you. However, we will not conduct any marketing activity with you without your explicit consent to do so.

We may also share your data with other group companies in order to meet our legal obligations and service your policy for functions like policy administration, underwriting, claims handling, customer service and investment administration.

2. Service Providers

We use third party companies to provide services so we can administer your policy and deliver a service to you. For example:

  • an asset manager we appoint to manage the assets linked to your policy;
  • service providers to perform underwriting, claims or customer service;
  • IT system companies that hold or analyse your information

3. Reinsurers

A reinsurer is another insurance company who takes on the risk of when and how much we have to pay customers on their policy. Like other insurance companies, we use reinsurers to help us manage our risk.

4. Anyone you ask us to share your information with

If you ask us to share your information with a third party such as a financial advisor or solicitor, we will. If a third party asks for your information in these circumstances we will check with you to confirm that it is at your request and we have your authority to release it.

5. Other parties

As outlined above, under “What your information is used for” we have a legal obligation to provide information from time to time to regulatory bodies such as tax authorities, law enforcement agencies and Ombudsmen.

6. Professional advisers

We use professional advisers to provide services to us, for example legal advice, accountancy services and consultancy services. We will only share your personal information with such advisers where it is necessary for them to provide their services.

7. Courts and those involved in any legal process

If a court requires us to disclose your information or if it needs to be disclosed as part of a legal process.

8. Anyone in the future who may buy or merge with our business

If we merge with another company or are sold to another organisation then we may need to share your information with them.

Where we use your information

We are based and operate primarily in Ireland. However, information that we collect from you in Ireland may be viewed from, transferred to, or stored, outside the European Economic Area (EEA).

On occasion we or a service provider may transmit certain aspects of your personal data outside the European Economic Area. In such circumstances, we will ensure that such transmissions are carried out securely and in accordance with data protection law.

The non-European Economic Area countries to which we currently might send personal data are i) Switzerland, ii) the United States of America, iii) Canada, iv) Singapore, v) Guernsey and vi) the Isle of Man.

We allow your information to be processed outside the EEA only in the following situations:

  • appropriate safeguards are in place;
  • it is necessary to implement pre-contractual measures taken at your request.

How long we keep your information for

We do not keep your information for longer than is necessary. Different information will need to be held for different periods of time; this may be due to a variety of reasons including legal obligations and to enable us to provide you with a good level of service. We have outlined the retention period in the table below:

PRODUCT TYPE OF INFORMATION RETENTION PERIOD
Savings & Investments Quote information where a policy is not taken out 12 months from issuance of the quote
Policy information The life of the policy plus 10 years
Claims information 10 years from the date the claim is finalised or declined
Employee Benefits Quote information where a policy is not taken out 12 months from issuance of the quote
Policy information Personal data and any sensitive personal data will be retained by us indefinitely so we can effectively administer any late claims, long-running disputes or for system back-ups required for disaster recovery
Claims information

What if you don’t provide information to us?

We try not to ask you for personal information that we don’t need. If we ask you for personal information that seems unnecessary to you, please contact our Data Protection Officer for an explanation.

If you do not provide certain information we may not be able to provide our service to you; for example, if you don’t provide the information requested on a surrender form we may not be able to process your surrender.

Your rights

We have set out a summary of your key rights below, but have not included all the circumstances or conditions which apply to them. If you have any questions on your rights, you can contact our Data Protection Officer for help.

Right to stop us using your informationif you don’t want us to use your information for administering policies you can ask us to stop and we will do so unless there is an important reason why we need to continue using it.

Right to stop us marketing to you you can ask us not to send you marketing messages.

Right to access your informationyou have the right to ask for a copy of the information that we hold about you and this will usually be provided free of charge. For your security, we will take reasonable steps to confirm your identity before providing you with any personal information we may hold about you.

Right to transfer your information you can request that we transfer certain information we hold about you to you or to a third party in electronic form.

Right to ask us to delete your informationin certain circumstances you can ask us to stop using or holding your information. If we can delete your information we will, but sometimes we have to maintain records for legal reasons. If we cannot comply with your request, then we will contact you and explain why. If you ask us to stop using your information we will still keep it where we are legally obliged to, but we will not use it for other purposes.

Right to give or withdraw your Consent – if you have given consent for us to use your information then you have the right to withdraw your consent at any time. However, if you do withdraw your consent we may not be able to continue to provide the product or service you have contracted us to provide; for example, if you withdraw consent to use health information you provided in a claim form we may not be able to process your claim or continue payment of your claim.

If we have shared the personal information in question with another company, we will also let them know that you have asked us to stop using or keeping your information unless it is very difficult or not possible for us to do so.

Automated decision making and your right to objectWe may use customer details for automated decision-making when choosing whether to accept the risk.

Where we use automated decision making which produces legal effects for you or otherwise significantly affects you, you will have the right to obtain human intervention and to contest and make representations in relation to the decision in question.

How to update the information we hold about you

It is important that the information we hold about you is accurate and up to date. Please let us know if your information changes, or if the information we hold about you is incorrect. You can ask our customer services team to update or correct your information.

If we have disclosed the personal information in question to another company (including another company within the group), we will also let them know about the changes unless it is very difficult or not possible for us to do so.

Changing and updating this privacy notice

We may change this privacy notice from time to time to keep it up to date, or to comply with legal requirements. In that case a revised version of this privacy notice will be published on our website.

Our Data Protection Officer contact details

If you have any questions or concerns about our use of your information or would like a copy of the information we hold about you or want to action your rights as described above, please contact our customer services team or alternatively our Data Protection Officer:

Name: Data Protection Officer
Utmost PanEurope dac
Address: Navan Business Park
Athlumney, Navan
Co. Meath C15 CCW8
Ireland
Email: Dataprotection@Utmost.ie
Phone: +353 (0) 46 909 9700

Complaints

If you are unhappy with any aspect of the way we handle your personal data, you can make a complaint using the email address below or alternatively contact our Data Protection Office as indicated above.

Email: complaints@Utmost.ie

You also have the right to complain to the Data Protection Commissioner, contact details as follows:

Postal
Address
Data Protection Commissioner
Canal House
Station Road
Portarlington
R32 AP23 Co. Laois
E-mail info@dataprotection.ie
Telephone +353 57 8684800
Lo Call
Number
1890 252 231
Website www.dataprotection.ie
https://www.utmost.ie/privacy-notice/