SNA

We care about your personal data

SNA s.a.l. (“we, “us” or “our”) is a Lebanese-authorized insurance company providing insurance products and services. Protecting your privacy is a top priority for us. This privacy notice explains how and what type of personal data will be collected, why it is collected, to whom it is shared or disclosed and your rights in this regard. Please read this notice carefully

1. Who is the data controller?

A data controller is the individual or legal person who controls and is responsible to keep and use personal data in paper or electronic files. We are the data controller as defined by relevant data protection laws and regulation.

2. What personal data will be collected?

We will collect and process various types of personal data about you, as follows:

• Full name
• Age/Date of Birth
• Gender
• Address
• Contact details (e.g., email address and telephone numbers)
• Identification Document number (i.e., passport number)
• Identification Document
• Nationality
• Marital Status
• Driving license details
• Tax Residency
• TIN Number
• Occupation
• Current employment information
• Previous employment information
• Dependents/Spouse/Partner/Family Details
• Signature

We will also collect and process “sensitive personal data” about you, for example, data resulting from medical reports or from death certificates, your medical claims history, details of physical and psychological health or medical conditions, credit/debit card and bank account details.

3. How will we obtain and use your personal data?

We usually collect your personal information from you or your agents. We may also collect your personal data from:

• Our agents, brokers, and business partners;
• Other insurers and insurance reference bureaus;
• Medical providers;
• Loss adjustors or surveyors;
• People who are involved in a claim or assist us in investigating or processing claims, including third parties claiming under your policy, witnesses, and medical practitioners;
• Fraud prevention agencies;
• Search information providers;
• Your employer;
• Third parties who may be arranging insurance cover for a group that you are part of;
• Law enforcement;
• Dispute resolution, statutory, and regulatory bodies;
• Lawyers
• Marketing lists and industry databases; and
• Publicly available sources.

We will use your personal data provided to us for a number of purposes including but not limited to the below:

• For insurance contract administration (e.g., quotation, underwriting, and claims handling);
• For conducting market research and analytical purposes, and to assist us improving our processes, services, and products;
• To inform you about our events, services, products, and news
• For fraud, money laundering, and terrorist financing detection and prevention; and
• To comply with any legal obligations (e.g., tax, accounting, and administrative obligations).

We will inform you where we require your consent to process your personal data. Otherwise, we will process your personal data to meet our legitimate business interest or where it is needed to comply with a legal obligation. In addition, we may also process your personal data to enter into a contract with you or to perform our obligations under an existing contract with you. We will need your personal data if you would like to purchase our products and services. If you do not wish to provide this to us, we may not be able to provide the products and services you request, that you may be interested in, or to tailor our offerings to your particular requirements.

4. Who will have access to your personal data?

We will ensure that your personal data is processed in a manner that is compatible with the purposes indicated above. For the stated purposes, your personal data may be disclosed to the following parties who operate as third party data controllers:

• Public authorities;
• IT developer companies;
• Our agents;
• Other insurers, co-insurers, re-insurers, and insurance intermediaries/brokers;
• Medical providers;
• Insurance fraud investigators;
• Screening providers; and
• Banks

For the stated purposes, we may also share your personal data with the following parties who operate as data processors under our instruction:

• Technical consultants, experts, lawyers, loss adjusters, auditors and medical doctors; and
• Service companies to discharge operations (e.g., claims, IT, postal, and document management); and
• Advertisers and advertising networks to send you marketing communications, as permitted under local law.

We do not share your personal data with non-affiliated third parties for their own marketing use without your permission. Finally, we may share your personal data in the following instances:

• In the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including any insolvency or similar proceedings); and
• To meet any legal obligation, including to the relevant ombudsman if you make a complaint about the product or service we have provided to you.

5. Where will your personal data be processed?

Your personal data may be processed both inside and outside Lebanon by the parties specified in Section 4 above, subject always to contractual restrictions regarding confidentiality and security in line with applicable local data protection laws and regulations.

6. What are your rights in respect of your personal data?

Where permitted by applicable law or regulation, you have the right to:

• Access your personal data held about you and to learn the origin of the data, the purposes and ends of the processing, the details of the data controller(s), the data processor(s) and the parties to whom the data may be disclosed;
• Withdraw your consent at any time where your personal data is processed with your consent;
• Update or correct your personal data so that it is always accurate;
• Request to delete your personal data from our records if it is no longer needed for the purposes indicated above;
• Request that your personal data will be restricted from processing in certain circumstances, for example where you have contested the accuracy of your personal data, for the period enabling us to verify its accuracy;
• Obtain your personal data in an electronic format;
• File a complaint with us and/or the relevant data protection authority; and
• Object to us processing your personal data, or tell us to stop processing it (including for purposes of direct marketing).

You may exercise these rights by contacting us as detailed in Section 9 below providing your name, email address, account identification, and purposes of your request.

7. How long do we keep your personal data?

We will retain your personal data for ten years from the date the insurance relationship ends unless a longer retention period is required or as permitted by law.

8. How can you contact us?

If you have any queries about how we use your personal data, you can contact us by email or post as follows: SNA s.a.l. Data Protection Officer Building 190, Street 702, Hazmieh - Beirut Lebanon
Email: [email protected]

9. How often do we update this privacy notice?

We regularly review this privacy notice. We will ensure the most recent version is available on our website http://www.sna.com.lb/ This privacy notice was last updated in September 2023.