Privacy Notice

Introduction

We are committed to preserving your privacy and observing your rights under the Data Protection Act. We use this privacy notice to disclose the privacy practices of the BCMG Insurance Brokers Limited in accordance with the Data Protection Act. We aim to help you understand what personal data we collect, how we use it, and what control you have over it. This notice will define the following:

1. What personal data is collected from you.
2. How personal data is collected, used, shared, stored, and otherwise processed.
3. The security procedures implemented to protect your data.
4. Your choices and rights regarding the use of your data.
5. How you can contact us for issues such as to correct inaccuracies of your data or to request the
   removal of your personal data.

Please read the following privacy notice to understand the processing, collection, sharing, protection, and your rights associated with your personal data.

Who we are

BCMG Insurance Brokers Limited (“BCMG ”) is an insurance broker in Jamaica. BCMG provides clients with a full spectrum of insurance products, solutions, and services to tackle the changing paradigms of the insurance landscape. Formerly Billy Craig (1963) and MGI (1986), BCMG is today one of Jamaica’s leading insurance brokers, now regulated by the Financial Services Commission. This Privacy Notice applies to all services provided by BCMG Insurance Brokers Limited.

For the purposes of this notice, we act as the “Data Controller”, because we determine how your personal data is used and processed.

We have appointed a Data Protection Officer to assist with questions, requests, and complaints in regards to this privacy notice and the collection and processing of your personal data. For details on how to contact us, see the Contact Information section at the end of this notice.

Data We Collect

We have access to data that you voluntarily provide via email, telephone, forms (both physical & electronic).

Through these means, we typically collect the following types of data:

• Full name
• Email address
• Phone number
• Occupation
• Address
• Nationality
• Date of birth
• TRN, NIS
• Employment status
• Salary and place of employment
• Marital status
• Medical history
• Medical diagnosis
• Medical doctor’s name and contact information
• Dependent’s name, date of birth, gender and TRN
• Beneficiaries name and relationship
• Identification
• Banking Details
• Identification Documents
• Images through photography and videos for marketing and security purposes
• Information required for processing any promotional or other marketing activity

We also have access to your data that we collect from various third-party suppliers. The data we typically collect is as follows:

• Medical doctors, hospitals, clinics, laboratories or other health facilities
• Your employer
• Referrals from banks, professional organisations, and existing customers

How We Use Your Data

Your personal data is used for purposes including but not limited to:

• Customer Account creation and administration
• Process any claims for international health, property, general, liability, cyber risk, motor vehicle, employee benefits insurance through underwriters and insurance companies, whether online on our client portal or through our forms
• Know Your Client (“KYC”)
• Legal obligations
• Internal audits
• Fulfilment of obligations outlined in any agreement
• Respond to your requests, complaints and comments
• Process your transactions
• Reference details
• Security and surveillance on the property
• Enrolment of insured persons, both online on our client portal or through our forms
• Optimize your user experience on the website
• Marketing purposes

Legal Basis of Processing

We process your personal data to provide you with a full spectrum of insurance products, solutions, and services, which may be necessary to provide you with insurance services under contract. While we may process personal data with your consent, you have the right to withdraw consent to processing for specific purposes, as outlined below.

We are a regulated insurance broker, and are required to obtain information from you so that we may comply with the Proceeds of Crime Act, the Terrorism Prevention Act, the Insurance Act and attendant rules and regulations. Because of this, we may process personal data to comply with our legal obligations.

We may also share personal data with underwriters or other insurance companies as may be necessary to enter into an insurance contract with you.

We may also process personal data for purposes of our own legitimate interests, granted that the interests of the BCMG do not override any of your own interests, rights, and freedoms. These legitimate interests include processing for marketing, security of our premises, research, and business development purposes.

Children

Where we process personal data of individuals under 18 years of age, we require the parent or legal guardian to provide their consent to the processing of any personal data.

Specific Data Use

In some instances, the provision of personal data sought by BCMG from the data subject may be compulsory under a particular law and not providing such data may cause the data subject to suffer consequences under the law.

How We Share Your Data

Your personal data may be shared with regulators in compliance with any legal obligation to which we are subject. We may also share your personal data with our underwriters, insurance companies, your employer in order to process any claims or offer an insurance service to you. We may occasionally share personal data with software developers who are engaged by BCMG to provide an improved service to you. We have implemented security measures and controls to ensure data remains appropriately protected, these include but are not limited to non-disclosure agreements, contractual requirements and data sharing agreements.

Where We Process Your Data

Under certain circumstances, your personal data that we collect may be transferred to other countries such as USA, UK, Europe, Caribbean & Latin America.

We have implemented security measures and controls to ensure data remains appropriately protected in these jurisdictions, these include but are not limited to non-disclosure agreements, contractual requirements and data transfer agreements.

How Long We Store Your Data

The Data Protection Act requires that personal data processed for any purpose shall not be kept for longer than is necessary for that purpose (ie. Statutory requirements, business needs). We retain your data for a minimum of seven (7) years after the end of your relationship with us, in accordance with industry standards.

We will only retain your personal data for the duration necessary to fulfill the purposes for which it was collected.

How We Protect Your Data

Securing your personal data is a priority for us, while both online and offline. We have implemented appropriate safeguards to prevent the unauthorized or unlawful processing of, or accidental loss or destruction of or damage to your personal data.

Employees and third parties are provided only with personal data on a need-to-know basis and only the minimum amount they require to complete their specific job function. All personal data users are subject to annual training on the proper handling of sensitive data.

Your Rights Regarding Your Personal Data

We aim to maintain data that is accurate and up-to-date. Under the circumstances that your personal data changes (e.g. moving addresses), please notify us of any changes or update your data.

You have the legal right to the following:

• to be informed as to whether we process your personal data;
• request all personal data we have collected about you, if any;
• request rectification of any errors or omissions in the personal data we have collected about you;
• object to the processing of your personal data for the purposes of direct marketing at any time;
• prevent the processing of your personal data outside the scope of your consent; and
• assurance that no decisions having significant impact on you are processed by automated means only.

To exercise these rights, please contact us via email, mail, or phone as indicated below in the “Contact Information” section.

Cookies

Cookies are small text files that are downloaded to your device by websites you visit. They allow the website to recognise your device and store some information about your location and past actions. We do not use any cookies on our website, however, third parties may be using cookies for different things, such as for profiling.

You can find more information about cookies at www.allaboutcookies.org.

Contact Information

For any questions, concerns, or requests to exercise your rights outlined in this privacy notice, please contact us via email at dpo@bcmgbrokers.com, or mail us at:

Any changes to this privacy notice can be found on our website at https://bcmgbrokers.com/.