1. Overview

Sanlam Allianz Life Insurance Ghana LTD takes the privacy of its customers seriously. Based on our value of care, we are committed to safeguarding your privacy while we empower you to be financially confident, secure and prosperous. This Privacy Notice aims to provide you with information of how SanlamAllianz Life collects, uses, discloses, retains and protects your personal information in accordance with the Ghana Data Protection Act, 2012 (Act 843) and other relevant laws.

The Privacy Notice applies to any website, application, form, document, product or service which references this Privacy Notice. It should be read together with the Terms and Conditions of Use for other SanlamAllianz Life products and services. Where there is a conflict, this notice will prevail.

In this Statement:

• “SanlamAllianz Life” or “We” or “our” refers to Sanlam Allianz Life Insurance Ghana LTD operating in Ghana

• “You” means as a customer- the person who subscribes to, uses or purchases any of our products and services or accesses our websites and includes any person who accesses any of the products and services you have subscribed to

• “SanlamAllianz Group” refers to Sanlam Allianz Africa (Pty) Ltd (SanlamAllianz) and all SanlamAllianz Group companies comprising the SanlamAllianz Group

• “Processing” refers to the collection, organisation, alteration, use, disclosure of personal information
• “Privacy policy” or “Privacy statement” and therefore some documents or forms may still refer to this Privacy Notice as a “privacy policy” or “privacy statement”

2. How we collect your data

We collect personal information about you and any other person whose details you provide to us in accordance with the relevant laws, either:

• Directly from you when you complete a product or service application form, electronically, telephonically or by way of a hard copy;
• Indirectly from you when you interact with us electronically by way of our website, apps, or social media channels, which may include the collection of metadata (data about data);
• From employers and other contracted entities in the context of medical schemes and group insurance policies; and
• Where relevant, from third-party sources, such as other entities within SanlamAllianz, financial intermediaries that are representatives of SanlamAllianz Group entities or have intermediary agreements with SanlamAllianz Group entities, public databases, data aggregators, other financial institutions, credit bureaus, Anti-Money Laundering screening platforms and fraud prevention agencies.

We will also collect your information where you have only partially completed and/or abandoned any information which you began to apply to our website and/or other online forms. Given that we already consider you a customer at this stage, we may use this information to contact you to remind you to complete outstanding information.

Where we require personal information to provide you with our products and services, your failure to provide us with the necessary information, may result in SanlamAllianz Life being unable to provide you with our products and services. Where such services include financial advice, the appropriateness of the advice may be compromised if you do not provide complete and accurate information. You are responsible for informing SanlamAllianz Life if your information changes

3. What data we collect

Your relationship with SanlamAllianz Life determines the nature of the personal information we process, and the purpose for which such personal information is collected and used. However, in many cases, if we are handling your personal information as part of our role as an insurer, the personal information we may process includes the following:

• Personal information
• Name, age, gender, date of birth, nationality, occupation, lifestyle information, current status of health, medical history and any existing conditions of each person insured

In the event that you make a claim, we may also collect personal information from you about the claim and any relevant third parties. We acknowledge that information about your health is special personal information. Note that we will use that information strictly in accordance with applicable laws and for insurance purposes (including assessing the terms of the insurance contract, dealing with changes to the policy and/or dealing with claims).

• Contact information
• phone number, email address, residential address and postal address
• Online Information
• cookies and IP address (your computer’s internet address), if you use our websites, apps and/or social media channels.
• Financial Information –
• Income, bank account details, mobile money account details
• Recorded call, e-mail records, CCTV, online identifiers such as cookies and IP addresses
• Data from third parties such as Government Identification databases, sanction list and Anti-Money Laundering (AML) screening platforms for identification verification, fighting fraud and to comply with statutory and regulatory mandates such as AML/CFT requirements

In certain instances, we may need consent to process your personal information. If you give us your consent for a specific context, you are free to withdraw this consent at any time. Please note that where you have withdrawn your consent, this will not affect the processing that took place prior to such withdrawal and it will not affect the processing of your personal information where consent is not required.

You may refuse to provide us with your personal information in which case we may not be able to provide you with a relevant service or would have to terminate our business relationship. The supply of certain items of personal information, especially those collected to comply with regulation, is legally mandatory.

4. How we use your data

For us to provide you with the superior financial products and services you have requested and to notify you of important changes to such products and services, we need to collect and process your personal information, your representatives, controlling persons of entities, business contacts, staff and service providers.

To the extent permissible under applicable laws, we may use your information:

• To provide you with our financial products, and services, and maintain our relationship with you;
• To conclude and administer your application, which may include underwriting;
• To execute a transaction in accordance with your request; including claims
• To meet our contractual obligations with you or take steps necessary for the conclusion of a contract with you;
• To comply with legislative and regulatory requirements, including codes of conduct and requirements of our regulators such as Customer Due Diligence and AML checks
• For purposes of proof and legal proceedings
• For other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our services, products, marketing and your overall experience

5. Security, storage & retention

SanlamAllianz Life intends to protect the integrity and confidentiality of your personal information.
Security safeguards are of utmost importance to us and for which reason we have implemented appropriate technical and organizational information security measures to protect your information; including, but not limited to, using encryption for transmission of financial information. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You must take appropriate steps to protect your own information in this case.

Where third parties are required to process your personal information in relation to the purposes set out in this notice and for other lawful requirements, we ensure that they are contractually bound to apply the appropriate security practices.

We take reasonable measures to securely store your data and have put in place appropriate security measures to prevent loss, misuse or unauthorised access of your personal data. We will retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for and as required by the Data Protection Act, 2012 (Act 843) and other relevant laws.

6. Your Rights

The Data Protection Act, 2012 (Act 843) provides some basic rights to you. These include:

• Right to be informed – It is your right to be informed of the processing of your personal information
• Right to give and withdraw consent - Where we rely on your consent to process your personal data, you have the right to withdraw it at any time
• Right to have access to your personal information - You have the right to request a copy of the data we hold about you at any time
• Right to amend (rectify), blocking and erasure – It is your right to request for an update to your personal data where it is inaccurate or incomplete. As well, you have the right to block us from further processing of your personal data where we do not have any legitimate or legal basis for doing so
• Right to prevent processing - Under this right, you can give us notice in writing to cease or not or not start processing your personal data for a specific purpose or manner which will cause or is likely to cause any unwarranted damage or distress. You can also prevent us from processing your information for direct marketing purposes.
• Right to object - You have the right to object to us processing your data under certain conditions
• Right to complain and compensation - You may write to complain if you believe any of your rights have not been met and where legitimate you have the right to duly compensated accordingly.

Notice to Exercise right

You can at any time give notice in writing to us to exercise your rights. We will within twenty-one (21) days after receipt of a notice, inform you in writing that we have complied or intend to comply with your notice or the reasons if we cannot comply with the request. If you would like to exercise this right, please contact us as set out below or you may reach out to the Data Protection Commission (DPC) via their contact mail at info@dataprotection.org.gh or visit their website at https://www.dataprotection.org.gh/

7. Sharing your data

We will only share your personal information with third parties if there is a legitimate reason to do so. We may disclose the personal information you provide to us to the following entities:

• Our third-party service providers and other SanlamAllianz Group entities who are involved in the delivery and/or administration of financial advice products and services;
• Other third parties in relation to the purposes set out under the previous section (How we use your information);
• Other insurers, public bodies and law enforcement (either directly or through shared databases) for fraud detection and prevention; and
• Reinsurers who provide reinsurance services to SanlamAllianz Life. Reinsurers will use your personal information to decide whether to provide reinsurance cover, assess and deal with reinsurance claims, and to meet legal obligations.

SanlamAllianz Life will not sell, rent, or trade your personal information to any third party. SanlamAllianz Life will share information about you with financial advisers that are our representatives or who have intermediary agreements with us.

8. Marketing

We will not process of your personal information for the purposes of Direct Marketing without your express consent. Where you provide your personal information to a SanlamAllianz Life in the context of a sale of one of our products or services, you agree to us sending you information on news, trends, services, events and promotions for our own similar products and or services, always subject to your right to opt out of receiving such marketing at the time your information is collected and on each subsequent marketing communication thereafter.

Where you choose to exercise your right to opt out of direct marketing, please contact us as set below.

9. Clickstream data

In the interests of better customer service, SanlamAllianz Life may collect anonymous information from visitors to its websites. For example, SanlamAllianz Life keeps track of the domains from which people visit its website and also measures visitor activity on its website. In the process, SanlamAllianz Life ensures the information cannot be used to identify you. This information is sometimes known as "clickstream data". SanlamAllianz Life or its analytics vendors may use this data to analyse trends and statistics and to provide better customer service.

The information, referred to as traffic data, which may be collected includes :

• Your IP address;
• The search terms you have used;
• The pages accessed on the website and the links you’ve clicked on;
• The date and time you visited the website;
• The referring website (if any) through which you clicked through to our website; and
• The type of website browser you use.

As mentioned, the traffic data is aggregated and not personally identifiable and our website analysis will also respect any ‘do not track’ setting you might have on your web browser.

10. Cookies

A cookie is a small text file that is downloaded onto ‘terminal equipment’ (for example, a computer or smartphone) when you access a website. It allows the website to recognise your device and store some information about your preferences or past actions.

What cookies do we use?

Some cookies which we use are essential to the functioning of our website. Some cookies help us with the performance and design of our website. This allows us to measure how many times a page has been visited, whether a page has been visited on the website through an advertisement or by other means. Other cookies help us to remember your settings which you may have selected or assist with other functionality when you browse and use our website. This helps us to remember what you have selected, so on your return visit - we remember your preferences. On certain pages of the website, we use cookies to help us understand your interests as you browse the internet, so we can tailor and render to you more personalised content and services in the future. This assists us in delivering relevant advertising to you during various advertising campaigns we may run from time to time through participating third-party sites.

In addition, we also use cookies on certain pages of our website to communicate with third-party data suppliers in order to extrapolate your digital behaviour. This helps us to understand and target more relevant advertising in the future. The information we receive is all aggregate and anonymous, but will include statistics such as demographics, online behaviour, product interests and lifestyle.

How do I disable cookies?

If you do not want to receive a cookie from the website, you have the option of setting your browser to notify you when you receive a cookie, so that you may determine whether to accept it or not. However, please be aware that if you do turn off 'cookies' in your browser, you will not be able to fully experience some of the features of the website. For example, you will not be able to benefit from automatic log-on and other personalisation features.

10. Children privacy

Our Service are targeted at persons from 18 years and over. We do not knowingly collect personally identifiable information from anyone under the age of 18 years. SanlamAllianz Life is committed to complying with all applicable laws aimed at the protection of children and in particular the protection of their personal information.

12. Changes to this policy

We may update our privacy notice from time to time. A notice will be posted on the SanlamAllianz Life website home page whenever the Privacy Notice is materially changed and the “Last updated” date at the top of this Privacy Policy will be updated as well

13. Our contact

Below are our contact details:

• Sanlam Allianz Life Insurance Ghana LTD
  2nd Floor, Allied Heights,
  Olusegun Obasanjo Highway, Abelemkpe - Accra
  P.O. Box AD 190, Adabraka - Accra

• Tel: +233 (0)302 228 047
• Website: https://gh.sanlamallianz.com/
• E-mail address: care@gh.sanlamallianz.com