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 insurance business under the Insurance Business (Bailiwick of Guernsey) Law 2002 by the Guernsey Financial Services 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 given your 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 means information that could identify you directly or indirectly, and can include your name, address, date of birth, email address, bank details, identification number, location data, online identifier, or one or more factors 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 to what 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 in relation 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 or philosophical beliefs which are also categorised as sensitive personal data however this information may be disclosed by you as part of the underwriting process, if you consider it is relevant. We have a very general question on the application form which asks clients to disclose any feature of their lifestyle which may affect / threaten their life expectancy and through this you may disclose further sensitive information.

AILAC and Kane Solutions will require your explicit consent to process sensitive information. If we do not receive 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, we can 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 or against 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 will protect your information against unauthorised or unlawful processing, accidental loss, destruction, or damage. We will do this with the implementation of internal policies, procedures, encryption of emails and data, building security such as swipe cards for building access, CCTV, internal IT testing, IT testing by external parties, internal auditing and staff training therefore treating your personal data with integrity and with the utmost confidence.

AILAC and Kane Solutions will not need to obtain consent of the data subject where we cannot be reasonably expected to have obtained that consent for the processing of your data. AILAC and Kane Solutions 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 information only if we have a good reason to do so. This includes sharing your information outside of AILAC and Kane Solutions. 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 commercial activities (these are not overridden by prejudice to your privacy rights). For AILAC and Kane Solutions to comply with applicable regulations it will be necessary, in some cases, to disclose your personal details which would be classed as a legal duty. We will also process your data for us to assist you with your contracts under the general terms and conditions which AILAC and Kane Solutions considers to be a legal 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-group company or third party other than where:

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

If AILAC and Kane Solutions suspects that false or inaccurate information has been furnished, they may record 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 business which consists of effecting or carrying out a contract or is personal data which relates to a data subject who is not a party to the contract or seeking to become a party to the contract and can reasonably be carried out with the consent of the data subject.

Again, as above, processing can be carried out without obtaining consent of the data subject where we cannot be reasonably expected to obtain consent for the processing of that information for instance a nominated beneficiary of a contract who does not know that they have been nominated. AILAC and Kane Solutions can process the data subject's personal data when AILAC and Kane Solutions is not aware of you withholding consent. AILAC and Kane Solutions use the services of third parties to provide services 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 of the EEA. Most notably South Africa is not considered to be an equivalent jurisdiction for the transfer of personal data.

In those cases where the relevant country has been checked to ensure it has an equivalent level of data protection by the European Commission, or we need to make the transfer to perform a contract in your interests, 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 Manager (DPM, Jamie Sutton – Impact). We can 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 we regularly 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 for them; they consent to the processing of their personal data, including sensitive personal data; that they consent 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 a contract we have with you.

If you choose not to provide your personal data, it may delay or prevent us from meeting our obligations. It may mean that we cannot perform services to run your contracts which could result in a need 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 contract has finished. Reasons to retain data can include:

Should you wish to have a look at our document retention schedule stating what documents are kept and for how long please contact our DPM (Jamie Sutton – Impact) 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 with investigations, 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 we do 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 keep requesting information then it may be necessary to charge you. We will take into consideration the cost of obtaining your information and the length of time it will take to respond to your request. If you request 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 DPM (Jamie Sutton – Impact) to request copies. This is called a subject access request. If you wish to have more details as to how this works please contact our DPM (Jamie Sutton – Impact).

If you request information that is too much or if we hold a lot of information about you, we will ask you to 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 do consider 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. If you request copies of your information, we must provide you with your information within one month from 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 or incomplete.

We will endeavour to ensure that all information we retain for you is accurate, complete, and up to date. Please do let us know if you have a change of personal details such as surname or contact details and help us keep your details up to date. If you become aware that the information we hold is incorrect and have let us know we will take every reasonable step to ensure that your personal data is rectified 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 or stop using your personal information. This is your 'right to object' or 'right to be forgotten'. However, in doing so this may stop us being able to provide you with your contract or disrupt our service levels to you.

There may be circumstances where we are able to restrict the use of your data, i.e. restrict its use to certain things, such as legal claims or to exercise legal rights. In these circumstances, we would not use or 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 to assist 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 satisfaction you 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 facility provides you with access to your contract details, including valuations etc. When accessing online services, you will be asked to provide some personal data which may include your name and email address.

Recording of phone calls

If you call AILAC and Kane Solutions the telephone line may be recorded. The records will be AILAC and Kane Solutions' property and accepted by you as evidence of the orders or instructions given. A copy of the 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. To find out more about how we use cookies please see 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 we will retain your information for seven years. After the seventh-year anniversary of the surrender or you leave us we will completely delete your data and we will no longer be able to provide any copies should you 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 you on similar 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. You can call, write, or email our DPM (Jamie Sutton – Impact) who will help you. We also have a separate policy which sets out information 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 in our literature and in the General Terms and Conditions. Not all parts of the statement will relate to each client. 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 this with us as much as we can.
If you are unsure or if you feel something is not clear you can contact our DPM (Jamie Sutton – Impact) who will be able to answer your questions.

Our Data Protection Manager can be reached in writing to:

Alpha International Life Assurance Company (Guernsey) Ltd 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 widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Our websites may automatically collect information from your computer using Cookies which provide us with 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 in this 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 to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site.
The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
Adviser check advisor_verification This cookie remembers the choice made by a user when entering the adviser section of the site. The cookie only stores the fact that a user has identified themselves as an adviser and means that they will not see the question on future visits to the site.
CMS ASPSESSIONIDSAABRRQD system (CMS) that is used to update the content on the site uses cookies to record whether users are logged into that system. Only users who can update content will have this cookie 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 to see how visitors move around our website when they are using it. This helps 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 visited and the links you have followed. We may also share this information with third parties.

Cookie Scope

Cookies can expire at the end of a browser session (from when a user opens a browser window to when they 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 session cookies expire after a browser session so would not be stored long term. For this reason, session cookies may sometimes be considered less privacy intrusive than persistent cookies.

Persistent cookies are stored on a user's device in between browser sessions, which allows the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. 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 is collected 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 displayed in the URL window. Our website may place, and access certain first party cookies on your computer or device.

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 taken steps 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 a user visits a website and a separate company, sets a cookie through that website this would be a third party cookie. We have no control over how third party cookies act, or whether that third party uses any other cookies. We advise you to check the privacy notices of any such third parties before providing any data to them.

Managing Cookies

By using this website, you agree that we can place cookies on your computer or other device. You may refuse the use of cookies on www.alphaintlife.com by selecting the appropriate settings in your browser, 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 all websites visit http://tools.google.com/dlpage/gaoptout .

Google Analytics

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

Advertising cookies

We may use advertising cookies to help us deliver more relevant, targeted online advertising. This means that based on the pages you visit on our site, you may see our advertisements on other selected websites. 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. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not 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.