1. Introduction
1.1 We at Pioneer Insurance Holdings Limited (hereinafter referred to as “PIHL” or “Pioneer”) take our responsibilities under the data protection laws in Kenya (and internationally) seriously. The purpose of this policy is to help you understand how we collect, use, disclose and/or process the personal data you have provided to us, and to assist you in making an informed decision before giving us access to your personal data.
1.2 This statement should be read together with our Terms and Conditions for products and services.
1.3 Personal data is information relating to our customers or potential customers (hereafter referred to as “you” or “your”).
1.4 The data controller of your personal data is PIHL, with whom you have or may have a relationship.
1.5 This statement applies to all customers, suppliers, and all clients who have any business dealings with the company.
2. Statement of Details
2.1 Collection of Information
We collect your personal information with your knowledge and consent when you do any of the following (this list is not exhaustive):
- Apply for a specific product or service
- Ask for more information about our products or services, or contact us with a query or complaint
- Respond to or participate in a survey, marketing promotion, prize competition, or special offer
- We may also collect your information from other organizations, including criminal investigative agencies, fraud prevention agencies, and business directories
- We may collect your information when you interact with us as a supplier, as prescribed in this statement
- We may also collect information when you visit any of our premises
- When you interact with our sales agents, they may collect personal information
2.2 What Information Is Collected
The information we collect and store about you includes, but is not limited to, the following:
- Your identity, including your name, photograph, address, location, phone number, identity document type and number, date of birth, email address, age, and gender
- Your account information, including bank account numbers, SWIFT codes, or other banking information
- Your transaction information from M-Pesa statements and bank statements
- Details of your earnings as per your payslip
- Your contact with us, such as when you call us or interact with us through social media (we may record your conversations, social media, or other interactions with us)
2.3 Use of Information
We may use and analyse your information for the following purposes:
- Processing applications for products and services, effecting payments and transactions, and completing instructions or requests
- Responding to any of your queries or concerns
- Verifying your identity through publicly available and/or restricted government databases in order to comply with applicable regulatory requirements
- Assessing suitability for products and services
- Carrying out credit checks and credit scoring
- Keeping you informed generally about new products and services, and contacting you with any new product, unless you opt out of receiving such marketing messages (you may contact any of our subsidiaries at any time to opt out, or by sending “stop” to the number provided in the SMS)
- Complying with any legal, governmental, or regulatory requirement, or for use by our lawyers in connection with any legal proceedings
- Business practices including quality control, training, and ensuring effective systems operations
- Understanding how you use our products and services for purposes of developing or improving them
- Preventing and detecting fraud or other crimes, and for debt recovery
- Research, statistical, survey, and other scientific or business purposes
- Providing aggregated data (which does not identify you as an individual) to third parties for research and scientific purposes
- Administering any of our online platforms/websites
2.4 Lawful Basis for Processing Your Information
We will process your personal information based on any of the lawful bases provided for under the Data Protection Law:
- The performance of a Product/Service Agreement with you
- PIHL’s legitimate business interests
- Compliance with a mandatory legal obligation
- Consent you provide
- Public interest
- Your vital interest
2.5 Retention of Information
We retain your personal data in line with our legal and regulatory obligations and for business and operational purposes. In the majority of cases, this will be for seven years from the end of your relationship with us.
Anonymised information that can no longer be associated with you may be held indefinitely.
3. Disclosure of Information
3.1 We will respect the confidentiality of the personal data you provide to us.
3.2 Any disclosure of your information shall be in accordance with applicable law and regulations. The company shall assess and review each request for information and may decline to grant such information to the requesting party.
3.3 We may disclose your information to:
- Law enforcement agencies, regulatory authorities, courts, or other statutory authorities in response to a demand issued with the appropriate lawful mandate and where the form and scope of the demand is compliant with the law
- Our associates, partners, software developers, or agents involved in delivering the company’s products and services you order or use
- Fraud prevention and anti-money laundering agencies, and credit reference agencies
- Publicly available and/or restricted government databases to verify your identity in order to comply with regulatory requirements
- The insurance regulator, assessors, brokers, agents, garages, or related organisations contracted with us
- Survey agencies that conduct surveys on behalf of the company
- Any other person we deem legitimately necessary to share the data with
3.4 We shall not release any information to any individual or entity acting beyond its legal mandate.
3.5 Marketing
We may use your personal data to conduct market research and surveys aimed at improving our products and services, and for marketing purposes, promotional events, competitions, and lucky draws.
You can ask us to stop sending you marketing messages at any time by writing to us, following the opt-out option on any marketing message sent to you, or contacting us through the provided contacts.
4. Access to and Updating Your Information
If you believe that our records contain inaccurate or incomplete information about you, please visit any of our branch outlets to make the necessary amendments. Some changes will only be made once the necessary supporting documentation has been obtained. We will take reasonable steps to investigate your concerns and correct inaccurate information in a timely manner.
5. Safeguarding and Protection of Information
The company has put in place technical and operational measures to ensure the integrity and confidentiality of your data, via controls around access control, physical and environmental security, and monitoring and compliance.
6. Your Rights
6.1 Subject to legal and contractual exceptions, you have rights under data protection laws in relation to your personal data, including:
- The right to be informed that we are collecting personal data about you
- The right to access personal data that we hold about you and request information about how we process it
- The right to request that we correct your personal data where it is inaccurate or incomplete
- The right to request that we erase your personal data, noting that we may continue to retain your information if obligated by law or entitled to do so
- The right to object to and withdraw your consent to processing of your personal data (we may continue to process it if we have a legitimate or legal reason to do so)
- The right to request restricted processing of your personal data, noting that we may be entitled or legally obligated to continue processing your data and refuse your request
6.2 If you wish to exercise any of the rights set out above, please contact us on our data protection email.
6.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who has no right to receive it. We may also contact you for further information relating to your request, to speed up our response.
7. Cookies
7.1 We may use cookies and similar technologies on our websites and apps, and in our emails. Cookies are text files that gather small amounts of information, which your computer or mobile device stores when you visit a website or use an app. When you return to the website or app, or visit websites and apps that use the same cookies, they recognise these cookies and your device.
7.2 We use cookies for many purposes, such as letting you navigate between pages efficiently, remembering your preferences, and generally improving your online experience. They can also help make sure the ads you see online are more relevant to you. We also use similar technologies such as pixel tags and JavaScript for these purposes.
7.3 We also use cookies in some of our emails to help us understand how you interact with them and to improve our future email communications.
7.4 For more detail on cookies, how and where we use them, and how you can control them, see our Cookie Policy.
8. How to Contact Us
If you would like to contact us on any topics in this privacy policy, you can email us at info@pioneerassurance.co.ke / info@pioneerinsurance.co.ke, or call: 0207220131, Mobile: 0723479848.
9. Right to Lodge a Complaint
You have the right to lodge a complaint with the relevant supervisory authority tasked with personal data protection within the Republic of Kenya (the Office of the Data Protection Commissioner).
10. Amendments to This Statement
The company reserves the right to amend or modify this statement at any time. You are advised to visit this page regularly to check for any amendments.
11. Disclaimer
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that they have their own privacy policies, and we do not accept any responsibility or liability for these policies. Please check these policies before submitting any personal data to these websites.
