Privacy Policy

Effective Date: 15/5/2018 

G.A.P. Vassilopoulos Group and its associated companies, (collectively,"GAP Group", or "we" or "us" or "our" are committed to safeguarding your privacy. In this Privacy & Cookie Policy (" Policy we explain to you what information we may collect, use, share and store about you, and the choices and rights that are available to you. If you have any questions about this Policy, please contact us using the contact details provided below. 

We comply with the relevant Data Protection legislation as set forth by the European Union regarding the collection, use, and retention of personal information. 


About GAP Group 
Through our network of specialized operating companies, GAP Group is a contemporary and adaptive organization, operating within the services sector by providing a variety of related services under one roof as a one-stop shop. 
Using our industry expertise, we have developed a full suite of service solutions. To learn more about the details of our services offerings, please click here


When this Policy Applies 
This Policy applies to our collection, use and disclosure of your personal information in relation to the Insurance products & services offered by GAP Group through our website(s) and content that link or refer to this Policy; 

This Privacy Statement does not apply to the practices of third parties that GAP Group does not own or control. 


What is in this Policy?

Collection & Retention of Personal Information 
Use of Personal Information 
Cookies and Online Tracking 
Profiling and decision making 
Sharing Your Personal Information 
International Data Transfers 
Your Privacy Rights 
Security of Your Personal Information 
Children's Privacy 
Marketing preferences: 
Changes to this Policy 
Contacting Us
 


Collection & Retention of Personal Information 

Depending on your relationship with us (for example, as a consumer policyholder; non-policyholder insured or claimant; witness or other person who are involved in an incident giving rise to an insurance claim), personal information collected about you and your dependants may include:  

  • General identification and contact information. Your name; address; e-mail and telephone details; gender; marital status; family status; date and place of birth; activity records, such as driving records; photos; employment history; professional licenses and affiliations; relationship to the policyholder, insured or claimant.  
  • Identification numbers issued by government bodies or agencies. Social insurance number; passport number; tax identification number; driver’s or other license number.  
  • Financial information and account details.Bank account number and account details; credit history; assets; income; 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.  
  • Information enabling us to provide products and services.Location and identification of property insured (for example, property address, vehicle license plate or identification number); age categories of individuals you wish to insure; policy and claim numbers; cause of loss; prior accident or loss history and other insurance you hold.  
  • Marketing preferences and customer feedback.You may let us know your marketing preferences or other means of sale promotion. 

If you submit any personal information relating to other people to us or to our service providers in connection with the GAP Insurance Services, you confirm that you have the authority to do so and to permit us to use the information in accordance with this Policy. You also agree to inform the individual about the content of this Privacy Policy. 

We collect information submitted to us: We collect personal information that individuals provide to us through GAP Insurance Services, such as when they visit one of our Sites, post a request on our websites or otherwise contact us. 
Information we collect automatically: We automatically collect certain technical information from visitors to our Site(s), such as the Internet protocol (IP) address of their device, their login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platforms. 
Special categories of Personal Information:When you request for an insurance product, you may be asked for types of personal information for you or your family that are viewed as sensitive personal information. Sensitive personal information includes information about an individual's medical conditions, ethnic origin or criminal convictions as well as any other information deemed sensitive under applicable data protection laws (collectively "Special categories of Personal Information").  
Retention of Personal Information: Information submitted to us abide to strict confidentiality principles and advanced security policies. 
We will keep your personal information as long as it is necessary, including updating the product or service or as required by law. 
When we destroy personal information, we will use safeguards to prevent unauthorized parties from gaining access to the information during the process. 
What if I do not agree with this Privacy Policy? 
If you do not agree to our processing of your data in the manner outlined in the Policy, please do not submit any personal data to us. 


Use of Personal Information 
The personal information we collect, will be used only as described in this Policy. 

We use this 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 and other administrative information; 
  • Make decisions about whether to provide insurance; provide insurance and assistance 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;
  • Prevent, detect and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks;
  • Carry out market research and analysis, including satisfaction surveys. 
  • 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;
  • 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 and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence); and 
  • 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. 

Cookies and Online Tracking 

A browser cookie is a small file saved on your hard drive when you visit certain websites. Browser cookies store information that a web site may use for a variety of purposes such as to personalize your experience and to gather web site statistical data, such as which pages you visit, what material you download, your Internet provider’s domain name and country, and the addresses of websites you visited immediately before, and after, visiting a particular web site. You can configure your browser to accept or reject browser cookies or to notify you when you are offered a cookie so you can accept or reject it. 

When you visit the GAP Insurance Services Website, we will place browser cookies on your hard drive to collect and store your preferences for viewing the Website, such as whether you disable Flash so that you will not have to do so for subsequent visits. In addition, the Website uses cookies to provide a unique identifier to your computer so that we can generate statistics regarding usage of the Website, such as the percentage of repeat visitors and other general statistics, determining the effectiveness of advertisements, and sales generated through advertisements. You may not be able to use some services on the Website if you disable your browser from accepting cookies. When you visit the Website, our strategic partners may also place browser cookies on your hard drive. 


Profiling and decision making 

We may use profiling to assess information you provide to understand unlawful patterns or to be able to submit your data to the relevant principal insurance company. Where special categories of personal information are relevant, such as medical history for medical insurance or past motoring convictions for motor insurance, your special categories of personal information may also be used for profiling. We might make some decisions based on profiling where final decisions are always a result of staff intervention 


Sharing Your Personal Information 

Our Group 
We may disclose your personal information to any affiliate within GAP Group for use in accordance with this Privacy Statement. This includes our subsidiaries, affiliates and our ultimate holding company.
GAP Group has established the GAP Group User Corporate Rules (“Corporate Rules”) in order for the GAP Group Entities to abide by these corporate guidelines that apply to the processing of User Information. The Corporate Rules are incorporated into the GAP Group corporate wide policy, requiring all GAP Group entities and employees to comply with and respect the Corporate Rules governing the collection, use, access, storage and transfer of Personal Information among GAP Group entities. To learn more about the Corporate Rules framework please click here
Other insurance parties.  
In the course of providing insurance and processing claims, we may make personal information available to third parties such as other insurers; reinsurers; insurance and reinsurance principal companies that we represent or by acting as brokers and other marketing partners; and financial institutions, securities firms and other business partners. 
Our service providers.  
External third-party service providers, such as medical professionals, actuaries, auditors, experts, lawyers, road accident assistance and other outside professional advisors; IT systems, support and hosting service providers; printing, advertising, marketing providers; banks and financial institutions; claim investigators and adjusters; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities. 
Customer companies. 
We may share our personal information with your company or employer in certain circumstances, for example, if your company has a corporate insurance product with us and you make a claim under that product. 

In addition, we may share and disclose personal information about you with in the following circumstances: 

Compliance with laws:   We may disclose personal information to a third party where we are legally required to do so in order to respond to or comply with any applicable law, regulation, subpoenas, court orders, legal process or government requests, including in response to public authorities to meet national security or law enforcement requirements. 
Vital interests and legal rights:   We may collect and possibly share personal information and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law, including without limitation to meet national security or law enforcement requirements. We also may disclose your personal information to third parties when we choose to establish or exercise our legal rights or defend against legal claims. 
With your consent:   We may disclose your personal information for other purposes with your consent.  
Your personal information is never sold, rented or leased to any external company. 

International Data Transfers 

  • Transfers to service providers & suppliersIn certain circumstances information that we collect about you may be sent to suppliers and service providers that are either based outside of the EEA or have servers based outside of the EEA. Countries outside of the EEA protect information differently, and so where we do transfer your information to suppliers based outside of the EEA, we will take all steps necessary to ensure that it is adequately protected and used in accordance with this Privacy Policy, including but not limited to relying on any appropriate cross-border transfer solutions such as the European Commission's Standard Contractual Clauses or the EU-US Privacy Shield Framework
  • Data Transfer As a global company, we may transfer Personal Information for certain services to GAP Group companies and third parties located anywhere in the world that may be outside your country of residence for storage and processing in order to provide the GAP Services. These countries may not necessarily have data protection laws as comprehensive as those in your country or residence. We will however protect your Personal Information in accordance with this Policy and applicable law wherever it is processed. 

Your Privacy Rights 
You have certain rights under applicable data protection laws, which include the right (i) to request a copy of your personal information, (ii) to request access, rectification or erasure; (iii) to restrict the processing of your personal information and recall your consent where applicable; and (iv) to submit a complaint to the Commissioner’s Office for the Protection of Personal Data. In certain circumstances, you may also have the right to object to the processing of your personal information. All the above are subject to the business relationship you have with us and any applicable prevailing legislations.  

If you would like to exercise any of the above rights, please immediately notify us in accordance with theContact Ussection below so that we may assess your request and determine, under applicable law, whether we are in position to comply with your request.

Your Choices: 

Cookies and other similar technologies: For information about how to disable selected cookies and other similar tracking technologies from collecting information on the GAP Services to third party properties, please see the Section headed "Cookies and Online Tracking". 

Marketing preferences: If you no longer want to receive marketing-related material from us on a going-forward basis, you may opt-out by following the instructions in the “Marketing Preferences section”. 


Security of Your Personal Information 
We are committed to protecting the personal information you share with us. We use appropriate physical, technical, organizational and administrative security measures to help protect your personal information from unauthorized or unlawful access, use or disclosure, and from accidental loss, destruction or damage. 

We support online security using secure server technology because we want your data to be safe. We use state-of-the-art security arrangements and facilities on our Sites and through the GAP Services to maintain data security. Unfortunately, the transmission of information via the internet cannot be guaranteed 100% completely secure and we cannot guarantee the security of your personal information that is transferred over the internet. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the "Contact Us" section below.


Children's Privacy 
GAP Group services are not intended for use by children under the age of 18. We do not knowingly collect personal information from children under the age of 18. If we learn that we have collected personal information from a child under the age of 18, we will delete that data from our systems unless we have the explicit consent from the parent/guardian. 


Marketing preferences: 
We will provide you with regular opportunities to tell us your marketing preferences, including in our communications to you. To tell us your marketing preferences and to opt-out, you can contact us using the information in the "Contact Us" section below. 

  • Receiving e-mail messages and text messages from us:If you no longer want to receive marketing-related e-mails or text messages from us on an ongoing basis, you may opt-out of receiving these marketing-related messages by clicking on the link to “unsubscribe” provided in each message or by contacting us.  
  • Receiving telephone communications and postal mail from us:    If you no longer want to receive mobile messages, telephone communications or postal mail from us on an ongoing basis, you may opt-out of receiving these marketing-related communications by contacting us.  
  • Our sharing of your Personal Information with our group companies for their marketing purposes:    If you would prefer that we do not share your Personal Information on an ongoing basis with our group companies for their own marketing purposes, you may opt-out of this sharing 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., to 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. 


 Changes to this Policy 
We will update the "Effective Date" at the top of this page to indicate the date from which any changes take effect. We reserve the right to change, modify or amend this Privacy Policy at any time. Any revised Privacy Policy will only apply prospectively to Personal Information collected or modified after the effective date of the revised policy. Customers are responsible for periodically checking the Privacy Policy posted on the Website for changes. 


Contacting Us 
If you have any questions about this Policy or if you wish to exercise Your Privacy Rights please contact:  

G.A.P. Vassilopoulos Group 
20 Strovolos Av., 
2011 Strovolos 
P.O. Box 23897, 1687 
Nicosia, 
Cyprus


ATTN: Privacy Team Privacy Team 
Tel:: 22710000 
Website:: www.gapgroup.com/contact
Email: privacyofficer@gapgroup.com