- Policy prepared by
- Approved by management on
- 7 June 2019
- Policy became operational on
- 7 June 2019
- Next review date
- Release of POPIA
This data protection policy ensures that Club Marine insurance brokers:
- Complies with data protection law and follow good practice;
- Protects the rights of staff, customers / clients and partners;
- Is open about how it stores and processes individual’s and juristic person’s data; and
- Protects itself from the risks of a data breach.
2. Data Protection Legislation
The Protection of Personal Information Act, 4 of 2013 describes how organisations, including Club Marine insurance brokers, must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The Protection of Personal Information Act (POPIA) is underpinned by eight important conditions, and eight additional rights and obligations:
- Processing limitation;
- Purpose specification;
- Further processing limitation;
- Information quality;
- Security safeguards;
- Data subject participation;
- Processing of special personal information;
- Processing of personal information of children;
- Direct marketing by means of unsolicited electronic communications;
- Automated personal information processing;
- Trans-border information flows;
- Outsourcing personal information processing;
- Appoint and duties of the information officer; and
- Prior authorization.
3. People, Risks and Responsibilities
This policy applies to:
- The main office of Club Marine insurance brokers;
- All staff and volunteers of Club Marine insurance brokers; and
- All contractors, suppliers and other people working on behalf of Club Marine insurance brokers.
4. Types of Information we collect
It applies to all data that Club Marine insurance brokers collects and holds relating to identifiable individuals and juristic persons, more specifically, any information that can be used to identify y you or that we can link to you, even if that information technically falls outside of the Protection of Personal Information Act, 2013. This can include, but is not limited to:
- Names of individuals;
- Postal addresses;
- Email addresses;
- Telephone numbers; plus
- Any other information relating to individuals.
5. Information you provide to us
You generally can use our digital media without providing us with personal information.
We collect information that you voluntarily provide to us, including when you communicate with us via email or other channels; when you request that we contact us when making enquiries for services, when you apply for a position with us and when you respond to our communications or requests for information. The information you provide may include your name, contact information, title, and information about the organisation with which you are affiliated.
6. Information we may collect automatically
We use browser cookies and similar technologies (collectively, “Cookies”) to collect and store certain information when you use, access, or interact with our digital media.
We may, for example, collect information about the type of device you use to access the digital media, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the content you view and features you access on the digital media, the web pages you view immediately before and after you access the digital media, whether and how you interact with content available on the digital media, and the search terms you enter on the digital media.
7. Information we collect from other sources
We may receive information about you from other sources, including third parties that help us: update, expand, and analyse our records; identify new customers; or prevent or detect fraud.
We may also receive information about you from social media platforms including but not limited to when you interact with us on those platforms or access our social media content.
The information we may receive is governed by the privacy settings, policies, and/or procedures of the applicable social media platform, and we encourage you to review them.
8. Precise location information
When you access the digital media via a mobile device, we may collect precise location information if you permit the digital media to access such information. We use this information to provide you with content based on your location and your proxim ity to our offices.
9. How we use the information we collect
We may use the information we collect:
- To respond to your inquiries;
- To provide you with FAIS compliance and other services that you request;
- To operate, troubleshoot, and improve the digital media;
- To send you newsletters, legal updates, marketing communications, and other information or materials that may interest you;
- To maintain our list of contacts;
- To understand how people, use our digital media, including by generating and analysing statistics;
- For Club Marine insurance brokers business purposes, including data analysis; submitting invoices; detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement;
- To assess the effectiveness of our events, promotional campaigns, and publications;
- To evaluate, recruit, and hire personnel; and
- As we believe reasonably necessary or appropriate to comply with our legal obligations; respond to legal process or requests for information issued by government authorities or other third parties; or protect your, our, or others’ rights.
10. How we may share the information we collect
Club Marine insurance brokers is a financial services provider (FSP). Our offices share information with each other for business purposes such as internal administration and providing you or your organisation with financial services.
11. We may also disclose information we collect
- To our third-party service providers that perform services on our behalf, such as web-hosting companies, mailing vendors, analytics providers, event hosting services, and information technology providers.
- To law enforcement, other government authorities, or third parties (within or outside the Republic of South Africa) as may be permitted or required by the laws of any jurisdiction that may apply to us; as provided for under contract; or as we deem reasonably necessary to provide financial services. In these circumstances, we take reasonable efforts to notify you before we disclose information that may reasonably identify you or your organisation, unless prior notice is prohibited by applicable law or is not possible or reasonable in the circumstances.
- To service providers, advisors, potential transactional partners, or other third parties about the consideration, negotiation, or completion of a transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
12. Grounds for using your personal information
We rely on the following legal grounds to process your personal information, namely:
- Performance of a contract – W e may need to collect and use your personal information to enter into a contract with you or to perform a contract that you have with us. For example, when you use our digital media, we will use your personal information to respond to your requests and provide you with such services.
- your browser or mobile application settings. Where required by applicable laws, we will rely on your consent for direct marketing and to collect information from your device or computer.
13. Third-party services and content
We engage third parties that support the operation of our digital media, such as analytics providers. These third parties may use technologies to track your online activities over time and across different websites and online platforms.
14. Protection and storage of the information we collect
We deploy administrative, technical, and physical safeguards designed to comply with applicable legal requirements and safeguard the information that we collect. This includes, when required or appropriate and feasible, obtaining written assurances from third parties that may access your data that they will protect the data with safeguards designed to provide a level of protection equivalent to that adopted by Club Marine insurance brokers.
However, no information system can be 100% secure. So, we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the Internet and wireless networks.
The digital media are controlled and operated by Club Marine insurance brokers from the Republic of South Africa. We may store the information we collect in the Republic of South Africa or in other countries where we or our service providers have facilities. We may transfer information to countries outside of South Africa, which may have data protection laws and regulations that differ from those in South Africa.
We retain the information we collect no longer than as reasonably necessary to fulfill the purposes for which we collect the information and to comply with our legal obligations.
15. Your choices and rights
If you no longer wish to receive marketing communications from us, you can let us know by sending us an email via our Contact Us page. And the electronic marketing communications we send you may contain opt-out mechanisms that allow you to register your marketing preferences.
Subject to law, you may have certain rights regarding information that we have collected and that is related to you. We encourage you to contact us to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate. You can also ask us to see what personal information we hold about you, to erase your personal information and you may tell us if you object to our use of your personal information.
16. How to contact us
We welcome your inquiries and comments. But please note that if you are not a client, we may not be able to treat the information you send us as confidential or privileged. If you wish to contact us regarding financial services, please use our website www.clubmarinesa.com.
If you would like to contact us with questions about our privacy or data protection practices, please send us an email via our Contact Us page.
2. About Cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
The names of these cookies change from time to time and sometimes from session to session. If you have a query about a specific cookie, please contact us with the name and value of the cookie so that we can identify its purpose.
4. Managing Cookies
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to bro wser, and from version to version. If you block cookies for this website, you may not be able to use all the features available on the site.