Privacy Statement

Prudential Bermuda Privacy Notice

Prudential Bermuda ISAC Ltd., Prudential Bermuda Re ISA, Ltd., and Prudential Bermuda ISA, Ltd. (collectively “Prudential Bermuda”, “us”, “our” and “we”) are organisations that use personal information in Bermuda. We take the privacy and protection of your personal information seriously and are committed to complying with the Personal Information Protection Act 2016 (“PIPA”).

So we’ve set out below information about our processing of your personal information, what rights you have under PIPA, and how you can get in touch with us or our Privacy Officer if you want to know more.

This Privacy Notice applies to all individuals whose personal information we use, including but not limited to policyholders, insureds, beneficiaries, claimants, prospective customers, website visitors, business contacts, and any other individuals whose personal information we collect or receive in connection with our business activities.

This Privacy Notice is intended to provide individuals with clear and easily accessible information about Prudential Bermuda’s practices and policies with respect to personal information, and is intended to comply with the requirements of PIPA.

This Privacy Notice does not form part of a contract (if any) with Prudential Bermuda and does not confer any contractual right on you, or place any contractual obligation on us. We may update or otherwise amend this notice at any time.

What we collect

When we say personal information, we mean information about you, such as your name, date of birth and contact details. A full list is provided below:

Personal contact information: personal and contact details, such as title, full name, contact details and contact details history;
Identity and travel document information: travel document information, identity document copies and details, visa, work permit, driving licence, tax identification, company registration documents;
Age and gender: your date of birth, gender and/or age;
Your nationality (if relevant to the product or service);
Stakeholders’ information: details of policy holders, joint policy holders, insureds, beneficiaries, including minor beneficiaries, assignees, trustees, claimants, authorised representatives, company staff and other individuals connected with our products or services;
Family and dependent information: family members, your marital status, family, lifestyle or social circumstances, e.g. the number of dependents you have or if you are a widow/widower (if relevant to the product or service);
Correspondence and digital information: records of your contact with us, including call records, and details such as mobile phone location data, IP address, MAC address, log-in credentials, online usage and logs;
Product and application information: products and services you hold with us, have been interested in or have held and the associated payment methods used;
Usage and claims information: the usage of our products and services, any claims and whether those claims were paid out or not (and details related to this);
Analytics information: analysis of data relating to marketing made to you, including history of communications and whether you open them or click on links;
Your views and opinions, such as preferences, comments, feedback, complaints, recommendations, survey responses and inquiries that you choose to provide to us;
Marketing information: information about your use of products or services held with our Marketing Partners, such as insurance policies, mortgage, savings or financial services and products;
Third party claims information: information we obtained from third parties, including information about insurance risk, pricing, claims history, instances of suspect fraud and usage history;
Third party insurance information: information we obtained from third parties including but not limited to insurance policy information (if you consented);
Credit information: personal information which we obtain from Credit Reference Agencies and Fraud Prevention Agencies, including public (for example, defaults) and shared credit history, financial situation and financial history;
Fraud, debt and theft information, including details of money you owe, suspected instances of fraud or theft, and details of any devices used for fraud;
Criminal records information, including alleged offences;
Health Data: information about your health / medical records;
Property information: information about your property, such as location, value, number of rooms, property type and building work you’ve had done (if relevant to the product or service);
Financial and payment information: financial details about you, such as your salary and details of other income, details of your savings, details of your expenditure, payment method(s), credit card details and bank account information;
Details about all your existing borrowings and loans (if relevant to the product or service);
Information about your employment status, source of income and supporting financial documents, if relevant to the product or service;
Information about your property occupier status, such as whether you are a tenant, live with parents or are an owner occupier of the property where you live at the time of your application;
Your residency and/or citizenship status;
Your marital status, family, lifestyle or social circumstances (if relevant to the product or service). For example, the number of dependents you have or if you are a widow or widower;
Information we buy or rent from third parties, including demographic information, details of outstanding finance, marketing lists, publicly available information, and information to help improve the relevance of our products and services;
Profiling information: insights about you and our customers gained from analysis or profiling of customers;
Third party transactions information; such as where a person other than the account holder uses the service, information about that person and the transaction; and
Tax information (if relevant to the product or service). For example, for investment accounts.

Where we get your personal information

We’ll collect personal information from the following general sources:

from you directly, and any information from family members, associates or beneficiaries of products and services;
information generated about you when you use our products and services;
when you submit an application or registration form, or any other forms relating to any products and services offered and/or distributed by us;
when a policyholder takes up an insurance policy for your benefit or appoints you as the life assured / insured members;
when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;
when you interact with our customer service officers, representatives, agents or appointed service providers (for example, via telephone calls, letters, face-to-face meetings, social media platforms, surveys, workshops and/or e-mails);
when you use our electronic services, or interact with us via mobile services, social media accounts, digital platforms, any of our websites or web services;
when you request us to contact you (whether pursuant to a request for more information, complaints, or any other purposes);
when you respond to our promotions, lucky draws, contests, events, initiatives, surveys organised by Prudential Bermuda, its partners, representatives or service providers and/or any other request for personal information;
from a broker or other intermediary (for example, agents, distributors, Business Partners) who we work with to provide products or services or quote to you;
Prudential Group companies if you already have a product with them, have applied for one or have held one previously or for any other lawful purposes;
cookies, location services, IP addresses when you visit our website or mobile app.
questionnaire and contact details when you attend surveys, investor conferences, roadshows or when you update contact us form on our website;
from other sources such as Fraud Prevention Agencies, Credit Reference Agencies, other lenders, publicly available directories and information (for example, telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies;
we buy or rent information about you or customers generally from third parties including demographic information, vehicle details, claims history, fraud information, marketing lists, publicly available information and other information to help improve our products and services or our business;
when your images are captured by us via CCTV cameras while you are within any of our premises, or via photographs or videos taken by us, our representatives or our agents when you attend our events;
when we receive references from Business Partners or third parties (for example, where you have been referred by them);
when we receive information from third parties about you when you make payment through (including but not limited to physical and digital payment kiosks);
when we seek information from third parties about you in connection with the products and services you have applied for; including but not limited to from other insurers, insurance associations, healthcare institutions, clinics, investigators, ex-employer and the relevant authorities;
when you submit your personal information to us for any other reason;
when you consent to us seeking information from third parties (including but not limited to other insurers, financial institutions and banks) about you in connection with any fact finding exercise; and/or
other publicly available sources where relevant and appropriate.

Why we collect the information

We collect personal information from you that is necessary for us to either provide you with our products or services or to comply with statutory or contractual requirements. Prudential Bermuda only collects and uses personal information if it is lawful to do so, including but not limited to where:

you have given your consent to the use of your personal information for specified purposes;
the use is necessary for the performance of a contract to which you are a party;
except regarding sensitive personal information, a reasonable person would consider that you wouldn’t object to our use of your personal information and our use does not prejudice your rights;
the use is required for us to comply with a legal obligation;
it is publicly available and used consistently with the purpose of its public availability;
it is necessary in the context of your present, past or potential employment relationship with us; or
the use is otherwise permitted by applicable law.

We, Prudential, the Prudential Group and our Business Partners, will use the personal information you provide to us, together with other information, for the following purposes:

Verifying your identity and any information you provide to us;
Assessing and processing of any claims and payments arising under your policy including by requesting from hospitals and clinics information such as your medical reports and blood test results;
Carrying out your instructions or responding to your queries, complaints, feedback and requests and/or otherwise communicating with you in relation to your policies;
Communicating with you on updates to the policy benefits, terms and conditions and providing administrative information, including for the purposes of servicing in relation to the products and services offered;
The administration of our products and services, including to enable us to perform our obligations to you and to provide any relevant services as discussed with you prior to any purchase of a product or service;
Carrying out checks using agencies such as credit reference agencies, tracing companies, or publicly available information;
Underwriting (including preliminary underwriting), pricing, insurance and re-insurance of your application with and/or through us and/or other companies within the Prudential Group;
Carrying out due diligence activities in accordance with any legal, regulatory or internal risk management obligations in relation to your application with and/or through us;
Automated decision-making or profiling;
The provision of customer services - like to reply to a question, or tell you that something’s changing;
Keeping your information on record and carrying out other internal business administration;
Administering and managing your relationship, programme and/or policy with us, which includes activities such as (i) renewing or reinstating policies, (ii) collecting any outstanding payments from you, (iii) providing you with financial health check review services; or (iv) processing any refunds to you;
Processing and dealing with any debt collections and claims (which includes the settlement of claims and any necessary investigations relating to such claims, under your policies (whether such policies have been issued by us or any other insurer);
Conducting research, surveys, analysis and development activities in order to design or improve the products and services we offer to you, as well as to improve the overall customer experience;
Administering contests, lucky draws and events that you have signed up to;
Telecommunications, information technology, payment, processing and training;
Storing, hosting, backing up of your personal information (including via clouds storage), and for otherwise managing and ensuring the efficiency and security of our IT environment and business operations;
Monitoring of undesired sales practice and ensuring compliance with our own policies and standards, as well as compliance with any policies or standards throughout the Prudential group of companies;
Managing the administrative and business operations of the Prudential Bermuda and complying with internal policies and procedures;
Facilitating business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Prudential Group companies;
Complying with any legal, regulatory and good governance obligations (which may include responding to requests from public or governmental authorities);
Conducting audit reviews;
Monitoring and coaching employee and agent for quality assurance;
If you have consented – to send you marketing, advertising and promotional information about insurance, investment and/or financial products and/or services that we may be selling or marketing; and
Any other such purpose which may be incidental or ancillary to any of the above purposes.

Unfortunately, if you don’t provide all of the information we require this may mean we are unable to provide our products and services to you.

Use of your sensitive personal information

For certain products or services, we’ll need to process your sensitive personal information, such as information relating to health, genetics, biometric identifiers and sexual orientation. To the extent that we need to use your sensitive personal information, we will do so in accordance with a lawful condition under PIPA. Whether or not required, we may also ask for your explicit consent to use this kind of personal information in the manner described above, and we will provide details of this at the point of collection.

Use of AI-enabled technologies

We may use AI-enabled technologies, including generative AI and natural language processing tools, to support our service, operational and internal business processes. This may include reviewing communications, organising and summarising information, responding to queries, improving service quality, detecting potential fraud indicators, supporting information security and assisting with document review, data extraction or similar tasks.

These tools may process personal information contained in documents, correspondence, claim submissions, customer service interactions or other information you provide to us.

We use these technologies as part of our broader service and operational processes and, where appropriate, apply human review and oversight. Where these tools process personal data, we do so in accordance with the lawful bases set out in this notice and apply appropriate safeguards.

Who we share your personal information with and why

We’ll share your personal information within the Prudential Group and with our Business Partners, for any of the purposes set out above. If you have a joint policy or investment, the other person may receive your personal information too.

We may use your personal information in a country other than the one you are resident in. By acknowledging this Privacy Notice and using our products/services, you consent to the cross-border transfer of your information to any country where we have databases or affiliates (including but not limited to Singapore and Hong Kong). To the extent we transfer your personal information, we will use appropriate safeguards and comply with applicable data protection laws to ensure the transfer is done lawfully. Details of the safeguards we use are available on request.

We work with many external parties in order to provide you with a seamless experience in relation to any products and/or services you have purchased from us. In the ordinary course of business, we may be required to disclose personal information to such external parties and these external parties may be located overseas.

We only disclose your personal information, where appropriate and necessary, for one or more of the above-mentioned purposes or as permitted by law. The external parties we may disclose your personal information to include, but is not limited to, the following:

within the Prudential Group companies and distribution partners / brokers / Business Partners / applicable group policyowners to facilitate the conduct of our business, carrying out our business activities and servicing you in relation to the products and services offered to you where appropriate and relevant;
our third-party service providers, sub-contractors of third-party service providers, contractors and vendors – which could include accountants, auditors, lawyers, IT service providers, business consultants, claim investigators, event managers, debt collection service providers, other such third-party service providers and sub-contractors of such third-party service providers which may assist us in carrying out our business activities. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the purposes;
medical institutions, clinics, financial institutions, credit card companies, credit associations, industry bodies, other insurance and re-insurance companies – to facilitate the processing of your applications, claims or any other insurance-related information or procedures;
public and governmental authorities, including regulatory authorities and law enforcement agencies – to comply with legal process, to respond to requests from such parties, to detect and prevent fraud and to protect our business operations; and
your family, relatives, appointed executors, appointed trustees, appointed administrators, and their professional advisers - in connection with your will(s) or the administration of your estate;
any business partner, investor, assignee or transferee (actual or prospective) - to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Prudential Group companies; and
any social media and/or advertising platform providers such as Google and Facebook if you have consented to receiving marketing, advertising and promotional information; and
any other party whom you authorize us to disclose your personal information to.

Accuracy and protection of your personal information

We will take reasonable efforts to ensure that any personal information we have about you is accurate and complete. However, this means that you must also ensure the accuracy of the personal information provided by you and update us of any changes to the personal information that you had initially provided to us in a timely fashion.

We will also take reasonable efforts to protect the personal information in our possession by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or any similar risks. Access to your personal information is also restricted to authorised persons who require access for a permitted purpose and whom have been advised as to its proper handling.

We keep your personal information for a set amount of time

We do not keep your information for longer than is necessary to fulfil the purposes above. Your personal information will be stored either for as long as you (or your joint policyholder) are our customer, or longer if required by law or as is otherwise necessary for us to fulfil the purposes above. It’ll always be in line with our data retention policy. [A limited and reasonable amount of information may be kept for archiving purposes.

Your personal information is protected

We implement and update technical and physical security measures to safeguard your personal information against loss, misuse or unauthorized access on an ongoing basis. Our protective measures include firewalls, data encryption, and access controls. However, please be aware that transmitting information over the Internet is not completely secure, and no data storage system can be guaranteed to be entirely safe. While we strive to protect your personal information, we cannot guarantee the security of data transmitted to our sites; any transmission is at your own risk. We encourage you to recognize the important role you play in maintaining the security and confidentiality of your personal information.

You’re in control

Under PIPA, when it comes to how we / your Prudential representative (where applicable) uses your personal information, you may have the right to:

Right to Access: request a copy of your personal information, the purpose for which your information is being used, and the names or types of persons to whom and circumstances in which your personal information has been disclosed (we have the right to charge a reasonable fee to complete this request) from us / your Prudential representative;
Right to Correction: request that we / your Prudential representative correct anything that’s wrong, or complete any incomplete personal information;
Right to Object or Block: request that we cease, or not begin, using your personal information for the purposes of advertising, marketing or public relations, or where the use of that personal information is causing or is likely to cause substantial damage or substantial distress to you or another individual;
Right to Erasure: request erasure or destruction of the personal information we hold about you. We may need to retain personal information if there are valid grounds under applicable laws for us to do so; and
Right to Complain: make a complaint to The Office of the Privacy Commissioner for Bermuda about how your personal information is being used.

If you want to exercise your rights, or would like an explanation about these rights, we’ve explained how you can get in touch in the ‘Contact us’ section. Any request must be in writing and provide sufficient detail to enable us to identify the personal information to which the request relates.

If you do need to speak to us, it’ll be useful to have to hand that the organisation responsible for your personal information is Prudential Bermuda.

We may monitor or record calls or any other communication we have with you. This might be for training, for security, or to help us check for quality.

Acting on someone else’s behalf?

If you give us personal information about another person (or persons), we’ll take that to mean they have appointed and authorised you to act on their behalf. This includes providing consent to:

our use of their personal information and sensitive personal information (as we’ve explained above);
you are getting any information protection notices on their behalf; and
this includes minor’s information when you are purchasing an insurance or other products on their behalf as parents or legal guardians.

If for any reason you are concerned as to whether you are permitted to provide us with the other person’s information, please contact us at the email address below before sending us anything.

Contact us

If you have any questions or concerns or wish to file a complaint about your personal information or how it is being used, you can contact the Data Privacy Officer at the address below. If the Data Privacy Officer is unable to satisfactorily address your concerns, you have the right to complain to The Office of the Privacy Commissioner for Bermuda.

Write to us at:

Data Privacy Officer
Prudential Bermuda ISAC Ltd.
Bermuda

Email us on: privacy@prudential.com.bm

About this notice

Language: To the extent there is any inconsistency between the English version and an official local translation of this Privacy Notice, the English version shall prevail.

Prudential Bermuda forms part of the wider Prudential Group of companies. "Prudential Group" means Prudential plc, Prudential Holdings Limited, any other entities whose ultimate parent or holding company is Prudential plc and any affiliates of Prudential plc.

“Business Partners” means our service providers, accountants, auditors, IT service and platform providers, intermediaries, reinsurers, investment managers, agents, pension trustees (and other stakeholders), scheme advisors, introducers, selected third party financial and insurance product providers, selected third-party reward, loyalty, co-branding and privileges programs partners and our legal advisers.

“Marketing Partners” means our service providers, intermediaries, pension trustees (and other stakeholders), scheme advisors, introducers and selected third party financial and insurance product providers.

“Personal information” or “personal data” each mean any information about an identified or identifiable individual.

“Use” or “using”, in relation to personal information, means carrying out any operation on personal information, including collecting, obtaining, recording, holding, storing, organising, adapting, altering, retrieving, transferring, consulting, disclosing, disseminating or otherwise making available, combining, blocking, erasing or destroying it.

“Sensitive personal information” means any personal information relating to an individual’s place of origin, race, colour, national or ethnic origin, sex, sexual orientation, sexual life, marital status, physical or mental disability, physical or mental health, family status, religious beliefs, political opinions, trade union memberships, biometric information or genetic information.

Amendments

We may amend this Privacy Notice at any time by communicating such change to you. The amendment takes effect on the date stated in the notice or, if no date is stated, on the date the communication is made. By continuing to use our website or our products and services, you acknowledge and agree to our Privacy Notice as amended from time to time.

Version Control

Version 1.0 | Approved by: Data Privacy Officer