HSF health plan (Malta) privacy notice
HSF health plan (Malta) Ltd is authorised under the Insurance Business Act and regulated by the Malta Financial Services Authority to carry on business of insurance in Malta. Company Registration number C 93406.
This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them and will not inadvertently fall into the hands of a third party. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate. Our policy complies with the EU General Data Protection Regulation (GDPR). The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.
Under the GDPR, we have a legal duty to protect any information we collect from you. We use leading technologies to safeguard your data and keep strict security standards to prevent any unauthorised access to it. Upon the demonstration of satisfactory identification evidence, you may request a copy of the information we hold about you.
What information do we collect?
Health Cash Plan Applications
If you make an application for a Health Cash Plan. We collect three types of information: your personal details, your medical details and payment details.
- Personal details
The personal details we collect are: Your personal and contact details including name, address, date of birth, company name and address, email address and telephone numbers.
- Medical details
The medical details we collect are: Any conditions or illness you may have had (or have) and the date any of the symptoms began.
- Payment details
The payment details we collect can be bank details or Credit Card information to support premium deductions or claim payments being made directly into your bank account.
Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business.
Site usage information – Log files and Google Analytics
This website uses log files and Google Analytics to track visits to the website in order to inform changes to the layout of the site and to the information on it, based on the way that visitors move around it.
- Log files do not contain any personal information but may record the IP address, the type of web browser and operating system used during a visit to the website.
hsfhealthplan.com.mt is not responsible for the content of external internet sites.
How we use your information and the legal basis
When you make an application for a Health Cash Plan or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information in order to:
- Verify your identity for security purposes
- Sell products to you
- Provide you with our services
- Provide you with suggestions and advice on products, services and how to obtain the most from using our website.
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
Who we share your information with
HSF health plan (Malta) may share your data with regulatory bodies when it is a legal requirement to do so for the purpose of monitoring and enforcing compliances;
- Financial Ombudsman Services
- Fraud Prevention Agencies
- Data Protection Authorities
We may also share aspects of your information on occasions with organisation to enable continuity of service, these include:
- Organisations that pay premiums on your behalf in line with the policy contract.
- IT Support & Technical Service Providers
- Service providers to assist in the continuity and provisions of benefits if applicable.
How long do we hold your data for?
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
- To provide you with the services you have requested
- To comply with other law, including for the period demanded by our tax authorities
- To support a claim or defence in court.
In line with our current retention policy, we retain your personal data for at least 6 years but no more than 7 years after the health plan policy has ceased.
Where is your information stored?
The disclosure of personal information to the affiliates and other third parties set out above may involve the transfer of data outside the EEA. We have put in place the Standard Contractual Clauses approved by the European Union Commission for such transfers of personal data.
Implications of not providing data
If you do not provide information we may not be able to:
- Provide requested services to you
- To continue to provide and/or renew existing products or services
We will tell you when we ask for information which is not a contractual requirement or is not needed to comply with our legal obligations.
How to exercise your information rights including the right to object
Right to be informed:
We will always be transparent in the way we use your personal data. You will be fully informed about the processing through relevant privacy notices.
Right to Access
You have the right to request a copy of all information about you held by us.
Please note that we are not obliged to take proactive steps to discover that a subject access has been made. If we cannot view a subject access request without paying a fee or signing up to a service, we will not respond to the request.
You have the right to exercise your right to data portability in certain circumstances.
Right to Object or to Restrict Processing
You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. Please note our policy is to only keep personal information for as long as is reasonably required for the purpose(s) for which it was collected. We are required to keep certain transactional records – which does include personal information – for more extended periods to meet legal, regulatory, tax or accounting needs. We are also required to retain an accurate record of dealings with us for at least six years after your last interaction with us, so we can respond to any complaints or challenges you or others might raise later.
We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, if this is the case we would not use or share your information in other ways whilst it is restricted. You can ask us to restrict the use of your personal information if:
- It has been used unlawfully but you don’t want us to delete it.
- You have already asked us to stop using your data, but you are waiting for us to tell you if we can keep on using it.
Right to Rectification
We want to make sure that the personal data we hold about you is accurate and up to date. If any of your details are incorrect, please let us know and we will amend them. When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Right to Erasure
You have the right to have your data ‘erased’ in the following situations:
- Where the personal data is no longer necessary in relation to the purpose for which it was originally collected or processed.
- When you withdraw consent.
- When you object to the processing and there is no overriding legitimate interest for continuing the processing.
- When the personal data was unlawfully processed.
Please note that each request will be reviewed on a case-by-case basis and where we have a lawful reason to retain the data or where exceptions exist within our retention policy, then it may not be erased. If you wish to exercise any of your above right, you can do so by contacting the Data Protection Team.
Right to Complain.
Should you not be happy with the way we handle your personal data, you have the right to complain. You can do so by contacting the Data Protection Team. If your complaint reasonably requires us to contact a third party, we may decide to give to that third party some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
You also have a right to lodge a complaint with the supervisory, the Information & Data Protection Commissioner
HSF health plan (Malta) Data Protection Team contact details:
Address: HSF health plan (Malta) Head Office, Vision Exchange Building, Triq It Territorjals – Zone 1, Central Business District, Birkirkara, CBD 1070, Malta.
Email Address: email@example.com
Telephone No: +356 2778 0685
Use of information we collect through automated systems when you visit our website.
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
- To track how you use our website
- To record whether you have seen specific messages we display on our website
- To keep you signed in our site
- To record your answers to surveys and questionnaires on our site while you complete them
Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution. We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. No such information is personally identifiable to you.
Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
Compliance with the law
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.