Liberty Privacy and Security Notice
Your right to privacy and security as guaranteed by Zambia’s Electronic Communications and Transactions Act (ECTA) is very important to us. Liberty Holdings Limited and its subsidiaries (Liberty, Liberty Health, we, us, our) treat your personal information as private and confidential.
How and why we collect personal information
- We collect personal information for the purposes set out in this notice or otherwise communicated to you.
- We collect personal information directly from you when you contact us directly or provide information through this website.
- This personal information is used to create a policy in your name and to issue you with a member certificate and card as proof of cover and to gain access to medical service and the benefits of the policy. This information is also used to authenticate and verify that you are you when interacting with Liberty Health. It is used for security purposes to ensure that unauthorised persons do not get access to your Liberty Health information or benefits.
- We may collect from and share your personal information with selected third parties to ensure we meet our responsibilities as a Health Insurance Product Service Provider. These third parties may include, but are not limited to:
- Regulatory bodies
- Financial Advisers and other intermediaries
- Member companies of the Standard Bank Group – Our parent company
- Credit bureaus – to establish credit worthiness (If Liberty Health is requested by any regulatory body / bureau to confirm whether or not we have a certain client covered by policy we have to provide this information).
- Other insurers or authorised financial services providers for prevention of fraud – Forensics investigations. Sharing of information would come into play when we have litigation cases and this information is shared with the respective legal representative with Liberty Health and/or member’s employer.
- We collect personal information from and about you for the following purposes, but not limited to:
- Assess your individual requirements accurately
- Deliver effective and personalised services to you that comply with applicable regulations.
- Carry out statistical and other analyses to identify potential markets and trends, evaluate and improve our business (this includes improving existing and developing new products and services).
- Tell you about services and products available within the Liberty Group. This information is used for Marketing purposes giving you access to the broader Liberty Group product offering.
- Constantly improve our offerings to suit your unique needs.
- To verify and protect your identity. This information is also used to authenticate or verify your identity when interacting with Liberty Health. It is used for security purposes to ensure that unauthorised persons do not get access to your Liberty Health information or benefits.
- Regulatory reporting – Liberty Health and the Liberty Group is obliged to provide regulatory reporting to the insurance and other regulatory bodies.
- Comply with relevant regulatory requirements, including monitoring and analysing your account for credit, fraud, compliance and other risk-related purposes as required by law.
- As otherwise allowed by law
- Without your personal information, we may not be able to provide or continue to provide you with the products or services that you need. This personal information is used to create a policy in your name and to issue you with a member certificate and card as proof of cover and to gain access to medical service and manage your policy. This information is also used to authenticate or verify that you are you when interacting with Liberty Health. It is used for security purposes to ensure that unauthorised persons do not get access to your Liberty Health information or benefits.
Transfer across borders
Sometimes we will process your personal information in other countries, either to carry out your instructions or for ordinary business purposes. These countries may not have the same level of protection. We will only process your personal information with your consent. If necessary, we will ask the party to whom we transfer your personal information to agree to our privacy principles, associated policies and practices.
We store personal information as required by law.
Our use of technology to follow your use of our website
We collect and examine information about visits to this website. We use this information to find out which areas of the website people visit most. This helps us to add more value to our services. This information is gathered in such a way that we do not get personal information about any individual or their online behaviour on other websites.
We use cookie technology on some parts of our website. A cookie is small pieces of text that are saved on your Internet browser when you use our website. The cookie is sent back to our computer each time you visit our website. Cookies make it easier for us to give you a better experience online. You can stop your browser from accepting cookies, but if you do, some parts of our website or online services may not work. We recommend that you allow cookies.
Marketing by post, email or text messages
If you give us permission, we may use your personal or other information to tell you about products, services and special offers from us or other companies that may interest you. We will do this by post, email or text message (SMS). If you later decide that you do not want us to do this, please contact us at firstname.lastname@example.org and we will stop doing so.
We ask other organisations to provide support services to us. When we do this, they have to agree to our privacy policies if they need access to any personal information to carry out their services.
Our website may contain links to or from other websites. We try to link only to websites that also have high standards and respect for privacy, but we are not responsible for their security and privacy practices or their content. We recommend that you always read the privacy and security notices on these websites.
When we may reveal personal information without consent
We will not reveal personal information to anyone outside Liberty or certain of our service providers without your permission, unless:
- we must do so by law or in terms of a court order
- it is in the public interest
- we need to do so to protect our rights
- there is a legitimate purpose for the sharing.
Our security practices
- We are committed and obliged to implement all reasonable controls to safeguard access to your personal information.
- Where third parties are required to process your personal information in relation to the purposes set out in this notice and for other legal requirements, we ensure that they are contractually bound to apply the appropriate security practices.
- All use of our website and transactions through it are protected by encryption (secret codes) in line with international standards.
Your right to access information
You have the right to request access to the personal information we process about you. You may exercise this right by emailing us at email@example.com. Please note that in some cases we may not be able to comply with your request for reasons such as our own obligations to comply with other legal or regulatory requirements. We will always respond to any request you make and if we can’t comply with your request, we will inform you of the reasons why. If you have any questions regarding this, please let us know at firstname.lastname@example.org.
Your right to lodge a complaint
You have a right to complain to the Zambian Information and Communication Technology Authority at any time if you object to the way in which we use your personal information. More information can be found on the Zambian Information and Communication Technology Authority’s website: https://www.zicta.zm/.
Privacy and security statements that apply to specific online services
Different online services or businesses of Liberty may have their own privacy and security policies because the service or product they offer may need different or extra policies. These specific policies will apply to your use of the particular service where they are different from our general policies.
Personal use of emails and notice about checking on emails
Our communication and information systems are for business use. However, we realise that our employees occasionally use our systems for personal use. Personal use includes sending or receiving personal emails within or outside Liberty. We do not accept responsibility for the contents of personal emails sent by our employees using our systems. Please note that we may intercept, check on and delete any communications created, stored, sent, or received using our systems, according to any law that applies.
Right to change this privacy and security notice
We may always change this privacy and security notice. We will put all changes on our website. The latest version of our privacy and security notice will replace all earlier versions of it, unless it says differently.
Email us at email@example.com if you have any questions about this privacy and security notice.