Synergi Insurance Advisors, Agents and Sub-Agents Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our legal obligations and your rights under the law.
What does this notice cover?
This Privacy policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
What is personal data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out, below.
What are my rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.
b) The right to access the personal data we hold about you.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details below.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including automated decision-making and profiling. 1 Synergi Europe 332 Agiou Andreou St Patrician Chambers, 3035 Limassol, Cyprus Tel: +357 77788890 E-mail: info@synergi-europe.com Website: www.synergi-europe.com
Further information about your rights can also be obtained from the Cyprus Office of the Commissioner for Personal Data Protection.
What personal data do you collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
• Name
• Date of birth
• Gender
• Address
• Email address
• Telephone number
• Marital Status
• Dependants
• Nationality
• Passport Number
• Tax Identification
• Profession
• Salary
• Payment information
• Bank details
• Financial information
How do you use my personal data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
• Providing advice and managing our relationship. Your personal details are required in order for us to enter into a contract with you.
• Communicating with you. This may include responding to emails or calls from you.
How long will you keep my personal data?
We will not keep your personal data for any longer than is legally required in light of the reason(s) for which it was first collected.
How and where do you store or transfer my personal data?
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
• Secure servers based in the EU
• Encrypting our data
• Staff training on data security 2
• Internal governance structure that includes technical and organisational measures that ensure compliance with GDPR.
Do You Share My Personal Data?
We provide advice relating to third party products and services via companies with whom you will contract with directly to share your data, however in some cases we are asked to confirm or validate this data for example policy numbers when we place trades on your behalf, we may also transmit the applications you make to them on your behalf.
If any of your personal data is required by a third party as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EU. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How Can I Access My Personal Data?
If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing via email or post to the company. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month and, in any case, not more than two months from receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of two months from the date we receive your request. You will be kept fully informed of our progress.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of the General Manager)
Email address: info@synergi-europe.com Telephone number: +357 77788980
Postal Address: 332 Agiou Andreou St, Patrician Chambers, 3035, Limassol, Cyprus