BSP Life (Fiji) Limited (“BSP Life” and “we”, “us” or “our”) is committed to protecting the privacy of the individuals we encounter in conducting our business.
“Personal Information” is information or an opinion about an identified individual such as you or other individuals (such as your dependants) or an individual who is reasonably identifiable.
- our website and online customer self-service portal (collectively referred to as the “BSP Life Online Services”); and
- other means (for example, from your insurance application and claim forms, telephone calls, emails and other communications with us, as well as from claim investigators, medical professionals, witnesses or other third parties involved in our business dealings with you).
- Who to contact about your personal information?
If you have any questions about our use of your Personal Information you can email email@example.com, call us on 132700 or write to:
Customer Care Department
Level 7 BSP Life Centre
Private Mail Bag, Suva
- Personal information that we collect
Depending on your relationship with us (for example, as a policyholder; life insured or beneficiary/nominee; witness; insurance broker or appointed representative; or other individual relating to our business), Personal Information collected about you and your nominees may include:
General identification and contact information: Your name; address; email and telephone details; gender; marital status; family status; date of birth; passwords on our systems; educational background; physical attributes; activity records, such as driving records; photos; employment history, skills and experience; relationship to the policyholder, insured or beneficiary; and date and cause of death, injury or disability.
Financial information and account details: Payment card number; bank account or other financial account number and account details; tax returns, credit history and credit score; assets and liabilities; income and expenses; judgments and civil litigation history; and other financial information.
Medical condition and health status: Current or former physical or mental or medical condition; health status; injury or disability information; medical procedures performed; personal habits (for example, smoking or consumption of alcohol); prescription information; and medical history.
Other sensitive information: In certain cases, we may receive sensitive information about you, including your professional trade or association or union membership, religious beliefs, political opinions (for example, if you apply for insurance through a third party marketing partner that is a trade, religious or political organisation). In addition, we may obtain information about your criminal record or civil litigation history in the process of deciding whether to provide insurance and preventing, detecting and investigating fraud or other crimes. We may also obtain sensitive information if you voluntarily provide it to us (for example, if you provide your driving history or express preferences regarding medical treatment based on your religious beliefs).
Identification numbers issued by government bodies or agencies: In certain limited cases, government identification numbers such as passport number, tax identification number or driver licence or other numbers.
Telephone recordings: Recordings of telephone calls to our representatives and call centres.
Photographs and video recordings: Photographs or video recordings (where you are identifiable) created in connection with our insurance or other business activities, including for claims assessment, processing, settlement, and disputes, or for other relevant purposes as permitted by law.
Information to investigate or prevent crime, including fraud and money laundering: For example, insurers commonly share information about their previous dealings with policyholders and claimants for this purpose.
Information enabling us to provide products and services: age categories of individuals you wish to insure; policy and claim numbers; coverage details; your status as director or partner, or other ownership or management interest in an organisation; and other insurance you hold.
Loan information (for mortgage insurance services): Details about property (address and description, and nature of property, whether primary or secondary residence or commercial); purpose of loan; details of loan transaction (for example, purchase price, deposit, loan terms and other financing); default status; and reason for default.
Marketing preferences and customer feedback: You may let us know your marketing preferences, enter a contest or prize draw or other sales promotion, or respond to a voluntary customer satisfaction survey.
Information from other sources: To improve the quality of our products and services, and to carry out research and analysis, we and our service providers may supplement the Personal Information we collect with information from other sources, such as publicly available information from social media services, commercially available sources and information from our affiliates or business partners.
BSP Life usually collects personal information directly from an individual, from the individual’s insurance broker or other appointed representative, in certain cases from websites or other publicly available information or from available searches or information services, and in limited cases, from competitions or from contact lists acquired from other parties.
We cannot usually deal with individuals who do not identify themselves (anonymity) or use a pseudonym such as a nickname. This is usually impracticable, because we need to identify the individual to enter into and administer insurance cover as a binding contract, check an individual is authorised to access or change information we hold and comply with applicable laws.
- How we use Personal Information?
Depending on your relationship with us and the Personal Information collected, we use Personal Information to:
- Communicate with you and others as part of our business.
- Send you important information regarding changes to our policies, other terms and conditions, BSP Life Online Services and other administrative information.
- Make decisions about whether to provide insurance and assistance services, and other products and services we offer, and provide such products and services, including claim assessment, processing and settlement; and, where applicable, manage claim disputes.
- Assess your eligibility for payment plans, and process your premium and other payments.
- Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers).
- Prevent, detect and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks.
- Provide marketing information to you (including information about other products and services offered by selected third party partners) in accordance with preferences you have expressed.
- Personalise your experience when using our BSP Life Online Services or visiting third party websites by presenting information and advertisements tailored to you.
- Identify you to anyone to whom you send messages through the BSP Life Online Services.
- Allow you to participate in contests, prize draws and similar promotions, and to administer these activities. Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these carefully.
- Facilitate social sharing functionality.
- Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management.
- Resolve complaints, and handle requests for data access or correction.
- Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering, sanctions and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence).
- Establish and defend legal rights; protect our operations or those of any of our group companies or insurance business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.
- Assess potential or actual job applicants for employment.
- International Transfer of Personal Information?
Due to the global nature of our business, for the purposes set out above we may transfer Personal Information to parties located in other countries (including countries that have a different data protection regime than is found in Fiji). For example, we may transfer Personal Information in order to provide emergency medical assistance services for you abroad. We may transfer information internationally to our group companies, service providers, business partners and governmental or public authorities.
The kinds of Personal Information likely to be transferred and countries include (where applicable):
- for product or claims referral or reporting purposes to other group companies: Papua New Guinea;
- Disclosure of Personal Information
While making use of your Personal Information, BSP Life may need to make Personal Information available to:
Our group companies Other BSP Group companies may have access to and use of Personal Information in connection with the conduct of our business where appropriate. BSP Life is responsible for the management and security of jointly used Personal Information. Access to Personal Information within the BSP group is restricted to those individuals who have a need to access the information for our business purposes.
Other insurance and distribution parties in the course of marketing and providing insurance and processing claims, BSP Life may make Personal Information available to third parties such as other insurers; reinsurers; insurance and reinsurance brokers and other intermediaries and agents; appointed representatives; distributors; affinity marketing partners; and financial institutions, securities firms and other business partners.
Our service providers Subject to any consents required from you, external third party service providers, such as medical professionals, accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; travel and medical assistance providers; call centre service providers, mailing houses and marketing companies, IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; banks and financial institutions that service our accounts; third party claim administrators; document and records management providers; claim investigators and adjusters; construction consultants; engineers; translators; and similar third party vendors and outsourced service providers that assist us in carrying out business activities.
Governmental authorities and third parties involved in court action BSP Life may also share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement agencies, tax authorities and criminal investigations agencies); and third party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.
Other Third Parties We may share Personal Information with payees; emergency providers (fire, police and medical emergency services); retailers; medical networks, organisations and providers; travel carriers; credit bureaus; licensed credit reporting agencies; and other people involved in an incident that is the subject of a claim; as well as purchasers and prospective purchasers or other parties in any actual or proposed reorganisation, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business, assets or stock.
Personal Information may also be shared by you, on message boards, chat, profile pages and blogs, and other services to which you are able to post information and materials (including without limitation the BSP Life Online Services). Please note that any information you post or disclose through these services will become public information, and may be available to visitors to the BSP Life Online Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the BSP Life Online Services.
BSP Life will take appropriate technical, physical, legal and organisational measures, which are consistent with applicable privacy and data security laws. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have with us has been compromised), please immediately notify us. (See the “Who to Contact About Your Personal Information” section above.)
When BSP Life provides Personal Information to a service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the Personal Information.
If we believe the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavour to do so as promptly as possible under the circumstances, and, to the extent we have your email address, we may notify you by email.
- Retention of Personal Information
- Personal Information of other Individuals
- Marketing Preferences
We will provide you with regular opportunities to tell us your marketing preferences, including in our communications to you. You can also contact us to tell us your marketing preferences or to opt-out by email at firstname.lastname@example.org, on telephone number 331 7000 or by writing to:
Level 7 BSP Life Centre
Private Mail Bag, Suva
If you no longer want to receive marketing-related emails from BSP Life on a going-forward basis, you may opt-out of receiving these marketing-related emails by clicking on the link to “unsubscribe” provided in each email or by contacting us at the above addresses.
We aim to comply with your opt-out request(s) within a reasonable time period. Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the databases of third parties with whom we have already shared your Personal Information (i.e. those to whom we have already provided your Personal Information as of the date on which we respond to your opt-out request). Please also note that if you do opt-out of receiving marketing communications from us, we may still send you other important administrative communications from which you cannot opt-out.
- Access and correction requests and complaints
You have the right to access your Personal Information on certain grounds and, if applicable, to request its correction. BSP Life will correct information if it is satisfied that, having regard to a purpose for which the information is held, the existing information is inaccurate, out of date, incomplete, irrelevant or misleading. Please contact us as set out in the “Who to Contact About Your Personal Information” section above with any such requests or if you have any questions or concerns about how we process Personal Information.
BSP Life has established an internal dispute resolution process for handling privacy complaints.
If you feel you have a complaint about our compliance with the applicable Privacy Principles or need help in lodging a privacy complaint, you can contact us as set out in the “Who to Contact About Your Personal Information” section above.
Your complaint will be reviewed and you will be provided with a written response. If it cannot be resolved, your complaint will be referred to BSP Life’s Managing Director who will respond within 15 working days. In either case the matter will be reviewed by a person or persons with appropriate authority to deal with the complaint.
If your complaint cannot be resolved by BSP Life’s internal dispute resolution process, you can lodge the complaint with the Reserve Bank of Fiji. You can contact the Reserve Bank of Fiji via:
- Other information that we collect through our Sites
“Other Information” is any information that does not reveal your specific identity, such as:
- Browser information;
- App usage data;
- Information collected through cookies, pixel tags and other technologies;
- Demographic information and other information provided by you; and
- Aggregated information.
We and our third party service providers may collect Other Information in a variety of ways, including:
Through your browser or device: Certain information is collected by most websites or automatically through your device, such as your IP address (i.e., your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, internet browser type and version, device manufacturer and model, language, internet browser type and version, time of the visit, page(s) visited and the name and version of the BSP Life Online Services you are using. We use this information to ensure that the BSP Life Online Services function properly.
Third parties may collect information about your use of the BSP Life Online Services and your use of other websites or online services. You can refuse to accept other cookies we use by adjusting your browser settings. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Sites and some online products.
Using pixel tags, web beacons, clear GIFs or other similar technologies: These may be used in connection with some BSP Life Online Services and HTML-formatted email messages to, among other things, track the actions of users of the BSP Life Online Services and email recipients, measure the success of our marketing campaigns and compile statistics about Site usage and response rates.
Using your Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or Wi-Fi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalised content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalised services and content. In addition, we may obtain the precise geolocation of your device when you use our mobile applications for purposes of providing travel or other assistance services to our clients who are enrolled in such services. In connection with providing travel or other assistance services, we may share your device’s precise geolocation information with our clients and other entities with whom we work. You may opt-out of our collection and sharing of precise geolocation information by deleting the mobile application from your device, by disallowing the mobile application to access location services through the permission system used by your device’s operating system, or by following any additional opt-out instructions provided in the privacy notice available within the mobile application.
Using information provided by you: Some information (for example, your location or preferred means of communication) is collected when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you.
By aggregating information: We may aggregate and use certain information (for example, we may aggregate information to calculate the percentage of our users who have a particular telephone area code).
Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then, in addition to the uses listed in this “Other Information We Collect” section, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.
- Third Party Privacy Practices
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organisations, such as Facebook, Apple, Google, Microsoft, RIM or any other software application developer or provider, social media platform, operating system or wireless service provider, or device manufacturer, including any Personal Information you disclose to other organisations through or in connection with any other applications or social media pages.
(In relation to products and services available on BSP Life’s website)
The terms of this disclaimer (“Disclaimer”) apply to this website www.bsplife.com.fj for BSP Life whose principal place of business is located at Level 7, BSP Life Centre, Thomson Street, Suva, Fiji.
In accessing this website and/or using the information provided on or via this website, you agree to be bound by this Disclaimer. If you do not accept the terms and conditions of this Disclaimer, you are not authorised to use this website or the Customer Self Service Portal. Your access to and your use of this website and the Customer Self Service Portal constitute your acceptance and agreement to abide by the terms and conditions set out in this Disclaimer. In the event of any conflict between the terms and conditions of specific products offered by BSP Life and this Disclaimer, the conditions specific to such products and services shall prevail.
- Use of this Website
The information provided on or via this website is general and informative in nature and should not be used as a substitute for any form of financial, legal, investment or insurance advice. Decisions based on the information provided on the website are at your own account and risk. Therefore, any user of the information provided should evaluate and if necessary, seek the appropriate professional, foreign exchange or financial advice regarding the contents of this website.
Although BSP Life uses reasonable efforts to provide accurate, complete and up to-date information which has been obtained from reliable sources, errors or omissions sometimes occur. BSP Life makes no warranties or representations express or implied, nor shall BSP Life or any party involved in creating, producing or delivering this website, be responsible or liable in any manner, including but not limited to negligence, as to whether information provided on or via this website is accurate, complete or up to-date. BSP Life controls and maintains this website from Fiji and makes no representations that the information provided on or via this website is appropriate for use in overseas jurisdictions. If you do use this website from other overseas jurisdictions, the laws of Fiji apply and any offers on this website are for Fiji residents only.
- Use of the Customer Self Service Portal (“Portal”)
In order to access the information and services offered on the Portal, users may need to use a specific user log in and password (“User Details”). User Details must not be disclosed to a third party and users must not access the Portal using another person’s User Details.
This Portal must not be accessed or used for any unlawful or prohibited purpose. BSP Life reserves the right to terminate a user’s ability to access the Portal if the user has breached the terms and conditions for using this Portal.
Users are responsible for their use of the Portal and must take necessary precautions to ensure that the accessing of this Portal does not expose the user to the risk of viruses, malicious computer code or other forms of interference which may damage the user’s computer system.
The Portal does not attempt to provide full details of policies held with BSP Life. For full details, please read your individual policy wordings, copies of which are available upon request.
Users are authorised to print, copy, reproduce and download materials and statements from the Portal subject to the material being used exclusively for personal use and the material not being modified in any manner. If any material is downloaded from the Portal, the material, together with any files or images incorporated in or generated by the software and data accompanying the material is licensed to you by BSP Life.
BSP Life has taken reasonable efforts to ensure that the content contained on the Portal is accurate. However, the services, information and data made available in the Portal are provided “as is” without warranties of any kind and all users are encouraged to verify the information before using or relying on the information. BSP Life makes no representations or warranties regarding the condition or functionality of the Portal, its suitability for the use or that the Portal will be uninterrupted, non-infringing, virus free or error free or that any such problems will be corrected.
- Intellectual Property
BSP Life retains all rights (including copyrights, trademarks and any other intellectual property right) in relation to all information provided on or via this website including all texts, graphics and logos. You must not reproduce, copy, distribute, and publish any of the information contained in this website unless BSP Life gives its prior written consent to do so. Any unauthorised use of any intellectual property on this website may violate copyright laws, trademark laws, the laws of privacy and publicity and communications regulations and statutes and BSP Life does not warrant or represent that the use of any material from this website will not infringe rights of third parties.
- Exclusion of Liability
Neither BSP Life, its directors, officers, its agents, subcontractors or its employees shall be liable for any direct, indirect, special, incidental, consequential, punitive, or exemplary damages, including lost profits even if BSP Life is advised of the possibility arising in any way from, including but not limited to i) any defects, viruses and any other malfunctions caused to any equipment and other software in connection with access or use of this website or Portal, ii) the information provided on or via this website or Portal, iii) interruption modification or misuse of information transmitted to BSP Life or transmitted to you, iv) the functioning or non-availability of this website or the Portal, v) the misuse of this website or Portal, vi) the loss of data, vii) downloading or use of any software made available by this website or Portal, viii) claims of third parties in connection with the use of this website or Portal.
BSP Life reserves the right to change the information provided on or via this website including the terms of this Disclaimer, at any time and without notice. Any updates and/or changes made to this website are based on valuations, projections or forecasts and shall not be taken as advice but merely as information. It is recommended that you review the information provided on this web site including the terms of this Disclaimer, periodically for changes.
- Third Party Content
This website may be linked to other websites which are not maintained by BSP Life. BSP Life is not responsible for the content of such websites. The inclusion of any link to such websites does not imply BSP Life’s approval or endorsement of such websites or the content thereof. BSP Life cannot guarantee that the links set out on our website will be accurate at the time of your access. Moreover, the sites pointed at by links have been independently developed and possibly maintained by person(s) over whom BSP Life has no control. BSP Life cannot and does not monitor the sites linked to its pages on the Internet or any transmission made through the respective webpages and news groups. Accordingly, BSP Life assumes no responsibility for the content of any site referenced to by any hyperlink or otherwise. BSP Life believes that our making available links to publicly accessible webpages is legally permissible and consistent with the common, customary expectations of those who make use of the Internet.
- Applicable Law
This website and its Disclaimer are governed in accordance with the laws of Fiji. Any disputes arising out of or in connection with this Disclaimer shall be submitted to the exclusive jurisdiction of the courts in Fiji.