Privacy Policy

Privacy Policy For Alpha International Life Assurance Company (GUERNSEY) LTD ("AILAC")

We take our duty to safeguard your data seriously. Our Privacy Policy sets out our privacy commitment to you and explains your rights.

Who we are

Alpha International Life Assurance Company (Guernsey) Ltd is licensed to write long term insurancebusiness under the Insurance Business (Bailiwick of Guernsey) Law 2002 by the Guernsey FinancialServices Commission.

AILAC is part of Alpha Growth plc (Alpha) and is listed on the London Stock Exchange.

Where we collect personal information from

You may have supplied your personal data to us through:

Your Financial Adviser should tell you when they pass your details on to us and you should have givenyour consent to allow your Financial Adviser to pass your details to us.

Your personal data

'Personal data' means any information that can be used to identify an individual person. This meansinformation that could identify you directly or indirectly, and can include your name, address, date ofbirth, email address, bank details, identification number, location data, online identifier, or one or morefactors specific to your physical, physiological, genetic, mental, economic, cultural, or social identity.As required under the regulations the information we collect will be adequate, relevant, and limited towhat is necessary for the purpose the information is being collected.
All personal data we collect, and hold will be processed lawfully, fairly and in a transparent manner inrelation to you as our data subject.

What is sensitive data?

In some circumstances we may collect sensitive information about you such as:

We do not require data concerning political opinion, membership of a trade union, religious orphilosophical beliefs which are also categorised as sensitive personal data however this information maybe disclosed by you as part of the underwriting process, if you consider it is relevant. We have a verygeneral question on the application form which asks clients to disclose any feature of their lifestylewhich may affect / threaten their life expectancy and through this you may disclose further sensitiveinformation.

AILAC and Kane Solutions will require your explicit consent to process sensitive information. If we do notreceive this consent from you, we will not be able to provide you with your product.

If you make any of your sensitive personal data public such as putting information on social media, wecan process that data as this information will be in the public domain.

We can also further process your sensitive personal data in the exercise or defence of legal claims for oragainst AILAC and/or Kane Solutions or whenever we need to comply with a court order.

How we use your personal information

As the controllers of your personal data AILAC and Kane Solutions may process your data:

  1. to administer and operate your contracts
  2. to fulfil AILAC and Kane Solution's legitimate interests, during the operation, support, and development of our businesses, evaluating customer service, efficiency, cost, and risk and for management purposes
  3. carrying out anti money laundering and conflict of interest checks for the prevention of financial crime or fraud
  4. exercising and defending our legal rights, complying with regulatory authorities and legislation
  5. for audits by national and regulatory enforcement

We will ensure your personal data is processed in a manner that is appropriately secure and we willprotect your information against unauthorised or unlawful processing, accidental loss, destruction, ordamage. We will do this with the implementation of internal policies, procedures, encryption of emailsand data, building security such as swipe cards for building access, CCTV, internal IT testing, IT testing byexternal parties, internal auditing and staff training therefore treating your personal data with integrityand with the utmost confidence.

AILAC and Kane Solutions will not need to obtain consent of the data subject where we cannot bereasonably expected to have obtained that consent for the processing of your data. AILAC and KaneSolutions can process your personal data when we are not aware of you withholding consent.Your data will not be further processed in a manner that is incompatible with the above purposes.

How the law protects you

Data Protection law allows AILAC and Kane Solutions to process and retain your personal informationonly if we have a good reason to do so. This includes sharing your information outside of AILAC and KaneSolutions. We must have one or more of the following reasons to process and retain your data:

The processing of your information is done so within the legitimate interests of business or commercialactivities (these are not overridden by prejudice to your privacy rights). For AILAC and Kane Solutions tocomply with applicable regulations it will be necessary, in some cases, to disclose your personal detailswhich would be classed as a legal duty. We will also process your data for us to assist you with yourcontracts under the general terms and conditions which AILAC and Kane Solutions considers to be alegal contract between you and AILAC and Kane Solutions.

Sharing your personal information

AILAC and Kane Solutions will not share the personal data they hold about you to any non-groupcompany or third party other than where:

If false or inaccurate information is provided and fraud is identified, details will be passed to fraudprevention agencies to prevent fraud, money laundering and terrorist financing. A record of suchdisclosures will be maintained.

If AILAC and Kane Solutions suspects that false or inaccurate information has been furnished, they mayrecord and report suspicion together with any other relevant information.

Third party data processing for administration purposes

We can process your personal information if it is necessary for the purpose of carrying on businesswhich consists of effecting or carrying out a contract or is personal data which relates to a data subjectwho is not a party to the contract or seeking to become a party to the contract and can reasonably becarried out with the consent of the data subject.

Again, as above, processing can be carried out without obtaining consent of the data subject where wecannot be reasonably expected to obtain consent for the processing of that information for instance anominated beneficiary of a contract who does not know that they have been nominated. AILAC andKane Solutions can process the data subject's personal data when AILAC and Kane Solutions is not awareof you withholding consent. AILAC and Kane Solutions use the services of third parties to provideservices on its behalf, which does include processing personal data about you.

Sending data outside the European Economic Area (EEA)

Your personal data may be transferred to another country, which may also include countries outside ofthe EEA. Most notably South Africa is not considered to be an equivalent jurisdiction for the transfer ofpersonal data.

In those cases where the relevant country has been checked to ensure it has an equivalent level of dataprotection by the European Commission, or we need to make the transfer to perform a contract in yourinterests, we will ensure that the transferred personal data is protected by a data transfer contract.Further details can be obtained by making a request in writing to our Data Protection Officer (DPO). Wecan provide you with copies of any data transfer agreements on request.
To ensure we are only transferring data to countries which have the correct adequacy ratings weregularly check the EU website.

How we use your information to make automated decisions

AILAC and Kane Solutions does not use automated decision-making processes.

If you provide information about another person

When you give information about another person, you confirm that they have appointed you to act forthem; they consent to the processing of their personal data, including sensitive personal data; that theyconsent to the transfer of their information and to receive on their behalf any data protection notices.

If you choose not to give personal information

AILAC and Kane Solutions may need to collect personal information by law, or under the terms of acontract we have with you.
If you choose not to provide your personal data, it may delay or prevent us from meeting ourobligations. It may mean that we cannot perform services to run your contracts which could result in aneed to cancel a contract or service you have with us.
Any data collection that is optional would be made clear at the point of collection.

How long we keep your personal information

We will retain your personal data in a form which can identify you for seven years after your contracthas finished. Reasons to retain data can include:

Should you wish to have a look at our document retention schedule stating what documents are keptand for how long please contact our DPO who can give you a copy of our document retention schedule.We may extend retention periods if we are required to preserve personal data in connection withinvestigations, proceedings, and litigation.

How to obtain a copy of your personal information

You have a right of access to your information completely free of charge (if it is a simple request). If wedo need to charge you, we will confirm what the charge is and why it is necessary to charge you. Usually,we will only charge if the information is clearly unfounded or excessive. Therefore, if you keeprequesting information then it may be necessary to charge you. We will take into consideration the costof obtaining your information and the length of time it will take to respond to your request. If yourequest additional copies we can also charge for the additional copies.
Should you wish to have access to your personal data you can write to the DPO to request copies. This iscalled a subject access request. If you wish to have more details as to how this works please contact ourDPO.
If you request information that is too much or if we hold a lot of information about you, we will ask youto be specific about the information you are looking for in order that we can locate it and get it to you.If we consider that you are asking for too much information, we do have the right to say no. If we doconsider your request to be excessive, we will send you a letter or an email setting out why.For your protection we may ask for identification confirming that it is you asking for the information. Ifyou request copies of your information, we must provide you with your information within one monthfrom the date we receive your identification documents.
You have a right to an electronic copy of your personal data which we can send to you encrypted.If your request to have a copy of your personal data adversely affects the rights and freedoms of others,we will not be able to provide this however we will send a letter to you confirming this.

Letting us know if your personal information is incorrect

You have the right to question any information we have about you that you think is wrong orincomplete.
We will endeavour to ensure that all information we retain for you is accurate, complete, and up todate. Please do let us know if you have a change of personal details such as surname or contact detailsand help us keep your details up to date. If you become aware that the information, we hold isincorrect and have let us know we will take every reasonable step to ensure that your personal data isrectified without delay. It is a good idea to regularly check the information we have for you.

What if you want us to stop using your personal information?

You have the right to object to our use of your personal information, or to ask us to delete, remove orstop using your personal information. This is your 'right to object' or 'right to be forgotten'. However, indoing so this may stop us being able to provide you with your contract or disrupt our service levels toyou.
There may be circumstances where we are able to restrict the use of your data, i.e. restrict its use tocertain things, such as legal claims or to exercise legal rights. In these circumstances, we would not useor share your information for other purposes while restricted.

Restriction of processing can be requested when:

How to withdraw your consent

You can withdraw your consent for us holding your personal information at any time. Should you withdraw your consent this may impact your contracts, the service we provide, or stop us being able toassist you with your contract.

How to complain

You can lodge complaints about our processing of your personal data with our Data Protection Manager, Jamie Sutton at Impact Solutions, whose email address is jamie@impactiom.com.

Should your complaint about our processing of your personal data not be resolved to your satisfactionyou can then send your complaint to the Office of the Data Protection Authority following this link: Make a Complaint · ODPA .

Use of our Online Services

You can access your information online via your AILAC and Kane Solutions IMS account. This facilityprovides you with access to your contract details, including valuations etc. When accessing onlineservices, you will be asked to provide some personal data which may include your name and emailaddress.

Recording of phone calls

If you call AILAC and Kane Solutions the telephone line may be recorded. The records will be AILAC andKane Solutions' property and accepted by you as evidence of the orders or instructions given. A copy ofthe recording will be available on request for a period of seven years.

Cookies

'Cookies' are text files, which are sent to your computer or other devices when you visit a website. Tofind out more about how we use cookies please see our below.

Who at AILAC and Kane Solutions uses your information?

What happens when I surrender my contracts?

If you chose to cash in your contracts, surrender your contracts or no longer wish to use our services wewill retain your information for seven years. After the seventh-year anniversary of the surrender or youleave us we will completely delete your data and we will no longer be able to provide any copies shouldyou wish to review your personal data that we held.

Marketing

We do not use your personal data to directly market our products to you, unless it is to inform of you onsimilar new products to your existing one.

Data held by us about children

If you are not yet 18 years old, you can ask us to give you copies of information we hold about you. Youcan call, write, or email our DPO who will help you. We also have a separate policy which sets outinformation which you might find clearer and easier to read.

Finally

This is our main statement. You will find parts of this statement broken down into smaller sections inour literature and in the General Terms and Conditions. Not all parts of the statement will relate to eachclient. Therefore, your application forms and literature you receive about us will be tailored to suit you.The most important thing is that you feel in control of your personal data. We will help you to do thiswith us as much as we can.
If you are unsure or if you feel something is not clear you can contact our DPO who will be able toanswer your questions.

Our Data Protection Officer can be reached in writing to:

Alpha International Life Assurance Company (Guernsey) Ltd at: PO Box 68, Albert House, SouthEsplanade, St Peter Port, Guernsey, GY1 3NBY.

Or via E-mail: contact@alphaintlife.com.

COOKIE POLICY

Use of cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widelyused in order to make websites work, or work more efficiently, as well as to provide information to theowners of the site.

Our websites may automatically collect information from your computer using Cookies which provide uswith limited personal information. We will use this data primarily for the following purposes:

The tables below explain all the cookies we use and why. The list below shows the websites included inthis privacy policy. Please see the relevant table for the website you are visiting:

AILAC and Alpha Growth plc may use your data for assessment and statistical analysis purposes.Alpha International Life Assurance Company Ltd.'s public website: www.alphaintlife.com

Cookie Name Purpose
Google Analytics _utma
_utmb
_utmc
_utmz
These cookies are used tocollect information about howvisitors use our site. We use theinformation to compile reportsand to help us improve the site.
The cookies collect informationin an anonymous form,including the number of visitorsto the site, where visitors havecome to the site from and thepages they visited.
Adviser check advisor_verification This cookie remembers thechoice made by a user whenentering the adviser section ofthe site. The cookie only storesthe fact that a user hasidentified themselves as anadviser and means that theywill not see the question onfuture visits to the site.
CMS ASPSESSIONIDSAABRRQD system (CMS) that is used toupdate the content on the siteuses cookies to record whetherusers are logged into thatsystem. Only users who canupdate content will have thiscookie placed on their machine.No personal data is stored.

Cookie Types

Strictly necessary These are cookies that are required for the operation of our website.
Analytical/performance These cookies allow us to recognise and count the number of visitors and tosee how visitors move around our website when they are using it. Thishelps us, and third parties, to improve the way our website works.
Functionality These cookies are used to recognise you when you return to our website.
This enables us to personalise our content for you.
Targeting These cookies record your visit to our website, the pages you have visitedand the links you have followed. We may also share this information withthird parties.

Cookie Scope

Cookies can expire at the end of a browser session (from when a user opens a browser window to whenthey exit the browser) or they can be stored for longer.

Session Cookies allow websites to link the actions of a user during a browser session. These sessioncookies expire after a browser session so would not be stored long term. For this reason, session cookiesmay sometimes be considered less privacy intrusive than persistent cookies.

Persistent cookies are stored on a user's device in between browser sessions, which allows thepreferences or actions of the user across a site (or in some cases across different websites) to beremembered. Persistent cookies may be used for a variety of purposes including remembering users'preferences and choices when using a site or to target advertising.

Some cookies that we use will collect personal information about you. Any personal information that iscollected will be used in accordance with our Privacy Notice.

Cookie Sources - First vs. Third party

Whether a cookie is 'first' or 'third' party refers to the website or domain placing the cookie.

First party cookies in basic terms are cookies set by a website visited by the user - the website displayedin the URL window. Our website may place, and access certain first party cookies on your computer ordevice.

First party cookies are those placed directly by us and are used only by us. We use cookies to facilitate,and improve your experience of our website. We have carefully chosen these cookies and have takensteps to ensure that your privacy and personal information is protected and respected at all times.

Third party cookies are cookies that are set by a domain other than the one being visited by the user. If auser visits a website and a separate company, sets a cookie through that website this would be a thirdparty cookie. We have no control over how third party cookies act, or whether that third party uses anyother cookies. We advise you to check the privacy notices of any such third parties before providing anydata to them.

Managing Cookies

By using this website, you agree that we can place cookies on your computer or other device. You mayrefuse the use of cookies on www.alphaintlife.com by selecting the appropriate settings in yourbrowser, but you may lose some useful functionality.

Google privacy & analytics opt-out

View an overview of privacy at Google. To opt out of being tracked by Google Analytics across allwebsites visit http://tools.google.com/dlpage/gaoptout .

Google Analytics

This website uses Google Analytics, which is a web analytics service provided by Google. GoogleAnalytics enables us to recognise repeat visitors to the site and to analyse how users use the site. Theinformation generated by the cookie about your use of the website will be transmitted to and stored byGoogle. Google uses this information for the purpose of evaluating your use of the website, compilingreports on website activity for website operators and providing other services relating to websiteactivity and internet usage. Please note that Old Mutual has switched on the IP Anonymisation featurein Google Analytics, which enables us to anonymize or mask our user's IP addresses before sending thewebsite activity information to Google Analytics.

Advertising cookies

We may use advertising cookies to help us deliver more relevant, targeted online advertising. Thismeans that based on the pages you visit on our site, you may see our advertisements on selected otherwebsites. The information collected is anonymous and does not contain any personal information.

YouTube cookies

We embed videos from our official YouTube channel using YouTube's privacy-enhanced mode. Thismode may set cookies on your computer once you click on the YouTube video player, but YouTube willnot store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode. To find out more please visit YouTube's embedding videos information page.