Group Data Privacy Statement

This Privacy Statement gives a description how Octagon Africa Financial Services Limited (hereinafter referred to as ‘Octagon’, ‘We’, ‘Us’) its subsidiaries, successors in titles and assigns; collects and uses information about you as We provide services to you. This Privacy Statement covers each time you apply to become a customer, utilize our Website or online services, and get services from Us as a client. 

We take firmly our responsibility to preserve your privacy, and We want you to be aware of how We utilize your personal information. The reasons We process your personal data, who We share it with, your rights regarding that data, and anything else We believe you should know are all spelled out in full in this Privacy Statement. 

The following is covered by this Privacy Statement. 

1. What is Personal Information? 

Any information that can be used to identify you or “other third parties” is considered personal information or person data. It includes any information that is captured in any way and can be used to identify an individual. Information including but not limited to; name, contact information, date of birth, health information, National Identification, National Social Security, and National Health Insurance numbers etc.  

2. Whose Personal Information Do We Collect?

We collect information including but not limited to: visitors, agents, service providers, individual clients, suppliers and/or third parties. In this Privacy Statement We refer to all such individuals as ‘you’. 

3. How do We collect Personal Information?

We collect your personal information from various sources including: 

• Making an application, buying any of our products or services or from agents or on our digital platforms.
• Entry into our premises.
• Onboarding of suppliers, clients, agents and third parties.
• From next of kin/beneficiaries.
• Employment details when onboarding new employees.
• Attending an event/training organized by Us.
• Subscribing to our online services, emails, social media platforms and Short Message Services (SMS).
• We may also collect data from other third parties, government agencies and organizations that directly engage with Us on insurance services or when required to fulfil statutory duties.

4. What Information do We Collect?

• Name, date of birth, gender, sex, Identification Numbers (such as ID Card No., Passport No., Alien Card No., Employment No., National Health Insurance numbers, National Social Security numbers, Postal Address, Health data, phone numbers, marital Status, Employment Data etc;
• Family Details e.g. spouse, children and other beneficiaries;
• Financial Information (such as Bank Account Details, Revenue Authority personal identification numbers, Credit Card Numbers, Financial Profile, Pension Income and Expenses, Debts, Risk Appetite Details;
• Education Details (such as Student ID Cards);
• Identifiers (E-mail, Internet Protocol (IP);
• Details of minors where relevant with the consent of the guardians or parents; and/or
• Any other details required by regulators- Know Your Client.

5. What is our Legal Justification for Using your Information, and how do We Use it?

Any of the following Uses, which are not exclusive, are possible for the personal information you supply Us: 

• Identifying You and verifying your details;
• Creating a storage data for You;
• Assessing the nature of business to contact with You;
• Assist in the monitoring of the online platforms;
• To comply with legal requirements;
• For ensuring the security of the premises;
• To improve the products provided by Us;
• For third parties e.g. contractors, suppliers and agents, We shall process the data for due diligence and administrative purposes;
• For background checks on new employees;
• For keeping You up to date on new products launched by Us; and
• In the event You attend Our events or trainings, We will be taking photos or videos.

6. Processing of Sensitive Data

We may collect sensitive data such as health data, gender, race, ethnicity, beliefs, property details, marital status, biometric data, family details as required by the law. 

7. Transfer of Personal Data

We may transfer your personal data as required by the law or when contracting with third parties who have put in place measures to protect and safeguard the said data. For cross-border transfers, We shall seek your consent and ensure that adequate safeguards are in place in the recipient country. 

8. Disclosures

We shall only disclose your data when required by the law, for investigative or fraud prevention purposes, to enforce rights, enforce agreements, with your consent, and for public interest. 

9. Direct Marketing

We might occasionally Use your personal information to get in touch with you for market research purposes or to tell you about additional services We believe you might find interesting. Before receiving marketing communications from Us, you might need to explicitly consent in any other way, such as by opting in. Depending on which of our products you Use, We respect your right to control your personal information. We will thus always offer you the option to decline receiving such direct marketing or market research communications, at the very least. You are free to Use the opt-out option whenever you choose. 

10. Retention of Personal Data

We will only keep your personal information on file for as long as it takes to fulfil the reason it was originally acquired. We maintain specific records management and retention policies and procedures, and We may retain your personal data and/or information for up to seven (7) years, or as may be required by law.  

11. Your Rights

You have a right to: 

• Be informed of the reasons why We are collecting your data;
• Request access to the personal data We currently have about you;
• Request Us to rectify incorrect data;
• Withdraw consent from processing your data;
• Request erasure of personal data; and/or
• Request restrictions in processing your personal data.

12. Usage of Cookies 

When you visit our Websites, We could Use “cookies” to store some information on your computer. This helps Us identify you for when We come back. We employ cookies to protect and preserve your preferences and settings, make it easier for you to log in, deliver interest-based advertising, stop fraud, evaluate the functionality of our products, and accomplish other justifiable goals. 

Additionally, We might use this data to create services that are specifically catered to your requirements and interests. If you would like, you may set your browser to either not accept cookies at all or to prompt you before accepting any, depending on which one you are Using. However, this will make some of the Website’s functions inaccessible.  

13. Contact Details

Our contact details are as follows: 

Address: Octagon Africa Financial Services Limited, WestPark Suites, Ojijo Road, 8^th Floor, P.O. Box 10034-00100, Nairobi, Tel: 0709 986 000 

We have appointed Data Protection Officers. You can contact the Data Protection Officers using the following details:  

Email: dpo@octagonafrica.com 

Phone: 0709 986 000 

14. Review 

This Privacy Statement shall be reviewed from time to time to be consistent with any future developments, industry trends and/or any changes in legal or regulatory requirements.