Data Protection Information

Section 1 - Laferla Group as a Data Controller

Who is responsible for processing your personal data?

The information and/or personal data which you provide us, is included in a file whose controller is the Laferla Group.

Laferla Group Identity

  • Laferla Insurance Agency Limited; Company Nr C14529; Registered at 204A, Vincenti Buildings, Old Bakery Street, Valletta VLT1453, Malta;
  • Laferla Holdings Limited; Company Nr C11059; Registered at 25/20, Vincenti Buildings, Strait Street, Valletta VLT1432, Malta;
  • Laferla Services Limited; Company Nr C79815; Registered at 25/20, Vincenti Buildings, Strait Street, Valletta VLT1432, Malta; and
  • Any other company which may in future be established with the same direct or indirect control, forming part of the Laferla Group.

Contact Information

In terms of the General Data Protection Regulation (EU2016/679), we are deemed to be the Data Controller for any data that we collect, or you provide through this website or by other means, except for data collected for the purpose of purchase of a Mapfre Middlesea plc (MMS) or Mapfre MSV Life plc (MMSV) policy, in which case, you need to refer to their Data Protection Information below in Section 2 and Section 3 respectively. When data is collected to provide you with a MMS or MMSV insurance policy, the Laferla Group is acting as a processor of your data under the instruction of MMS and/or MMSV.

We may collect the following data when you visit our website or provide this data for the purpose of requesting us to provide you with feedback to an enquiry, a proposal or process a purchase:

  • Personal identification and communication details provided to us by completing the registration form on the website or any other information you submit to us through the website, by email, or by other means;
  • Verification documents provided for Identity, Payment Method verification and other documentation we may request due to our obligations at law or to provide you with the service requested;
  • Contact information through the website, email, telephone or other media;
  • Your answers to questionnaires or surveys we conduct;
  • Elements of transactions, including financial accounts information that you may provide us, made through the website, telephone or other media;
  • Details of your visits to the website, including but not limited to traffic data, site information, weblogs and other contact information;
  • Telephone calls or chat sessions to and from our customer service staff are recorded for security and education purposes along with the resolution of questions arising from the service provided to you.

For what purposes do we process your personal data?

The Laferla Group shall process all the personal data voluntarily provided by the interested parties directly or through an Intermediary, and data obtained by recording telephone conversations or as a result of browsing through our Internet webpages or another medium, for the enforcement of the agreement or for a query, application, or to purchase any service or product, even after the end of the pre-contractual or contractual relationship for the following purposes:

  • Management of the relationship between the data subject and the Laferla Group or any single company within the Laferla Group.
  • The processing, monitoring, and updating of any request for information, business, pre-contractual, or contractual relationship, of any of the various Laferla Group companies.
  • Maintenance and integral and centralised management of its relationship with the various Laferla Group companies.

All the data obtained, as well as the processing and purposes specified above are required or relevant to adequately maintain, implement, and control the contractual relationship with you.

Only to the extent that you have expressly requested, the accepted purposes include the delivery of information and advertising, including via email, on offers, products, recommendations, services, promotional items, and customer loyalty campaigns of the Laferla Group, or third-party companies with which any Laferla Group company has signed partnership agreement; data extraction and storage, and marketing surveys to adapt our commercial offers to your specific profile, both if a transaction is formalised or not, and once the existing contractual relationship ends. You can withdraw your consent to receiving such communications at any time and at no cost by sending an email to [email protected].

We do not carry out fully automated decision making or profiling with the personal data that you provide us and where we carry out partially automated decision making, a final review is carried out by a natural person prior to providing you with a decision.

 

Vacancy Applications

If you apply for one of our vacancies available on our website, your personal data will be received and processed by the Laferla Group of companies. If you are not selected for a vacancy you applied for, Laferla Group will retain the submitted vacancy application and submitted documentation, including Curriculum Vitae, for up to 12 months for consideration should a related vacancy arise within our group companies. Should you wish to have your data erased before such date, you can notify us and we will promptly delete your details from our system save any other legal obligations to retain the data. Should you have been selected, your personal data would be processed in line with the Data Processing Agreement that would be presented to you prior to employment.

Use of Cookies

We use cookies as a means of collecting information from an internet server for the below reasons, at visiting of the site by a member. We may need your consent to use certain cookies; for further information, please visit https://www.laferla.com.mt/privacy-policy.

Cookies contain information that is transferred to your computer’s hard drive. They help us to improve the website and provide better and more personalized services. Some of the cookies we use are necessary for the operation of the site.

If you want to delete any cookies already stored on your computer or stop cookies that record your browsing habits on the webpage, you can do so by deleting your existing cookies and / or by changing your browser’s privacy settings to block cookies (the procedure you follow will vary depending on the browser). Please note that by deleting our cookies or by deactivating our future cookies, you may not be able to access certain sites or services on the site.

How long will we keep your personal data?

The personal data provided will be kept for the period established on the basis of these criteria: (i) legal obligation of conservation; and (ii) term of the contractual relationship and service of any responsibilities derived from the said relationship.

As a guide:

  • For up to one (1) year: Details of your visits to the site, including but not limited to traffic data, site information, weblogs and other contact information;
  • For up to five (5) years from last activity: Personal identification and communication details provided, contact information provided through the website, email, telephone or other media related to your relationship with us, proposals and quotes.
  • For up to ten (10) years from last activity: Elements of transactions, including financial accounts information that you may provide us, made through the website, telephone or other media, claims information, payments effected and related documentation.
    • Recordings of telephone calls to and from our Customer Service Department will be kept for a maximum of 30 days.

We will also keep personal data for the purpose of presenting and processing in case of a litigation or a legal process which you, the relevant authorities or us may be party in, due to our provision of services to you. If your relationship with us, in any of the aforementioned cases, is not active, then we will not process the data further except for complying with the above statutory obligations.

To whom will your data be communicated?

The Laferla Group may communicate your data exclusively for the purposes included in the section “For what purposes do we process your personal data?”, to companies belonging to the Laferla Group, subsidiaries and investees, Public Administrations, and other natural or legal persons that also conduct any of the aforementioned activities and with which the various Laferla Group companies enter partnership agreements, whether a transaction is formalised or not, and once the existing contractual relationship has ended, with no need to notify every first communication sent to the aforementioned recipients.

Likewise, any company that is a member of the Laferla Group, subsidiaries and investees, may communicate your personal data to any of the aforementioned companies, in order to conduct integral and centralised management of the relationships between the interested parties and the various Laferla Group companies, and that interested parties may benefit from the possibility of accessing their data from any of them, complying in all cases with the applicable legislation on personal data protection, with no need for the interested parties to be notified of every first communication made. The communication of data between Laferla Group companies is necessary for the maintenance of integral and centralised management of your relationship with the Group, the application of special offers such as discounts and giveaways, and other benefits obtained from this fact and the management of customer loyalty programmes if you subscribe to them.

As part of the communications described in the previous paragraph, international data transfers may be made to third parties or international organisations, whether there exists a European Commission decision on their adequacy or not. International transfers to countries that cannot guarantee an adequate protection level shall be made on an exceptional basis and will be made whenever they are necessary for the adequate development of the contractual relationship.

The Laferla Group has data protection clauses to adequately ensure the protection of your data as part of the communication and international transfer of your data in countries in which they can be applied.

International Data Transfers

The company does not in principal share any of the personal data you provide us to third parties located outside of the European Economic Area (EEA) or countries considered by the EU to provide an equivalent standard of data protection.

If the company will in the future need to carry out such transfers of personal data to third parties outside of the EEA or equivalent countries to be able to provide you with your requested services, we will let you know of this and seek your authorisation unless this is in an emergency situation in the interest of preserving your well-being and where we have no reasonable alternative to obtain your consent.

In the case of a standard, non-emergency transfer as above mentioned,  we would ensure to follow applicable data protection legislation and where applicable, seek approval from our Data Protection Authority to ensure that at all times, your personal data rights are respected and guaranteed.

What are your rights when you provide us with your data?

Under the terms and scope established in the regulations in force, any person is entitled to:

  • confirm whether the Laferla Group is processing personal data that concerns you, and access it and the information related to its processing;
  • request the rectification of inaccurate data;
  • request the removal of data, among other reasons, when it is required for the purposes for which it was collected, in which case the Company will cease to process the data except for legal obligations such as but not limited to Fraud Detection, Anti-Money Laundering initiatives and other legitimate interests;
  • request the limitation of the processing of your data, in which case it will only be processed with your consent, with the exception of its storage and use for the filing of and defence against claims or for the protection of the rights of another natural or legal person or for reasons of significant public interest in the European Union or in a certain Member State;
  • object to the processing of your data, in which case, the Laferla Group shall cease to process your data, except for the defence against potential claims and other aforementioned legitimate reasons;
  • receive, in a structured, widely-used format that can be machine readable, the personal data that concerns you and that you have provided to the Laferla Group;
  • withdraw the consent granted, if applicable, for the purpose specified in the section “What do we use your personal data for?“, without affecting the lawfulness of the processing based on consent prior to withdrawal.

The aforementioned rights of access, rectification, erasure or right to be forgotten, restriction of processing, portability, objection, and the right to object to automated individual decision making may be directly exercised by the data owner or its legal or voluntary representative, through a written communication sent to [email protected], or when available directly through the website, such as for direct marketing, by visiting your account profile.

You also have the right to file a claim with the Office of the Information and Data Protection Commissioner or through https://idpc.org.mt, particularly if you feel that the concerns raised with the Laferla Group in the exercise of its rights, have not been successfully answered. You may also decide to file a claim with your local data protection authority; contact details can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

Section 2 - Laferla Insurance Agency Limited as a Data Processor on behalf of the MAPFRE Middlesea plc

Who is responsible for processing your personal data?

The information and/or personal data which you provide us including, your health data, are included in a file whose controller is:

  • Identity: MAPFRE Middlesea plc – Company Number C5553
  • Post address: Middle Sea House, Triq San Publiju, Floriana FRN1442, Malta.
  • Telephone: +356 21246262
  • Email: [email protected]
  • Data Protection Officer Contact[email protected]

For what purposes do we process your personal data?

MAPFRE Middlesea plc shall process all the personal data voluntarily provided by the interested parties directly or through its Insurance Intermediaries, and those obtained by recording telephone conversations or as a result of browsing through Internet webpages or another medium, for the enforcement of the agreement or for a query, application, or to purchase any service or product, even after the end of the pre-contractual or contractual relationship for the following purposes:

  • Management of the insurance activity and/or fulfilment of the agreement or pre-agreement as well as of the legal obligations.
  • Risk assessment and delimitation, for the detection, prevention, suppression and investigation of fraud; in risk selection and claims management, irrespective of whether the insurance agreement is formalised or not and after its termination, if applicable.
  • The performance of statistical studies and calculations, surveys, market trend analyses, and quality control.
  • The processing, monitoring, and updating of any request for information, business, pre-contractual, or contractual relationship, of any of the various MAPFRE Group companies, and management of activity with Insurance Intermediaries.
  • Maintenance and integral and centralised management of its relationship with the various MAPFRE Group companies.

All the data obtained, as well as the processing and purposes specified above are required or related to adequately maintain, implement, and control the contractual relationship.

Only to the extent that you have not expressly objected, the accepted purposes include the delivery of information and advertising, including via email, on offers, products, recommendations, services, promotional items, and customer loyalty campaigns of MAPFRE Middlesea plc and the various MAPFRE Group companies (www.mapfre.com) or third-party companies with which any MAPFRE Group company has signed partnership agreement; data extraction and storage, and marketing surveys to adapt our commercial offers to your specific profile, both if a transaction is formalised or not, and once the existing contractual relationship ends.

In order to adequately enforce the insurance agreement and be able to offer you products and services according to your needs, on the basis of the information provided, we will create different profiles based on your interests and necessities allowing the MAPFRE Group to define business strategies, and as a result may undertake automated decisions on the basis of these profiles.

How long will we keep your personal data?

The personal data provided will be kept for the period established on the basis of these criteria: (i) legal obligation of conservation; (ii) term of the contractual relationship and service of any responsibilities derived from the said relationship; and (iii) request of removal by the interested party in the applicable cases.

What is our legal standing regarding the processing of your data?

The legal basis for the processing of your data for the purposes specified in the section “For what purposes do we process your personal data?” is the enforcement of the insurance agreement. The prospective offer of products and services included in the section “For what purposes do we process your personal data?” is based on the consent which you have given us. Under no circumstances will the withdrawal of this consent place conditions on the enforcement of the insurance agreement.

You are obligated to provide us with your personal data to sign the insurance agreement. Should you fail to do so, the Company reserves the right not to sign the insurance agreement.

To whom will your data be communicated?

MAPFRE Middlesea plc may communicate your data, including your health data and the data on the claims associated with the policies, exclusively for the purposes included in the section “For what purposes do we process your personal data?”, to other Insurance and Reinsurance Companies, Insurance Intermediaries, Financial Institutions, Real Estate Agents, and other Service Providers related to its business, belonging to the MAPFRE Group, Subsidiaries and Investees, the Fundaciόn MAPFRE, Public Administrations, and other natural or legal persons that also conduct any of the aforementioned activities and with which the various MAPFRE Group companies enter partnership agreements, whether a transaction is formalised or not, and once the existing contractual relationship has ended, with no need to notify every first communication sent to the aforementioned recipients.

Likewise, any company that is a member of the MAPFRE Group, subsidiaries and investees, may communicate your personal data to any of the aforementioned companies, in order to conduct integral and centralised management of the relationships between the interested parties and the various MAPFRE Group companies, and that interested parties may benefit from the possibility of accessing their data from any of them, complying in all cases with the applicable legislation on personal data protection, with no need for the interested parties to be notified of every first communication made. The communication of data between MAPFRE Group companies is necessary for the maintenance of integral and centralised management of your relationship with the Company, the application of the premium discounts, and other benefits obtained from this fact and the management of customer loyalty programmes if you subscribe tot hem.

As part of the communications described in the previous paragraph, international data transfers may be made to third parties or international organisations, whether there exists a European Commission decision on their adequacy or not. International transfers to countries that cannot guarantee an adequate protection level shall be made on an exceptional basis and will be made whenever they are necessary for the adequate development of the contractual relationship.

The MAPFRE Group has data protection clauses to adequately ensure the protection of your data as part of the communication and international transfer of your data in countries in which they can be applied.

What are your rights when you provide us with your data?

Under the terms and scope established in the regulations in force, any person is entitled to:

  • confirm whether MAPFRE Middlesea plc is processing personal data that concern you, and access them and the information related to their processing.
  • request the rectification of inaccurate data
  • request the removal of data, among other reasons, when they are required for the purposes for which they were collected, in which case the Company will cease to process the data except for the filing of or defence against potential claims.
  • request the limitation of the processing of your data, in which case they will only be processed with your consent, with the exception of their storage and use for the filing of and defence against claims or for the protection of the rights of another natural or legal person or for reasons of significant public interest in the European Union or in a certain Member State.
  • object to the processing of your data, in which case, MAPFRE Middlesea plc shall cease to process your data, except for the defence against potential claims.
  • receive, in a structured, widely-used format that can be machine readable, the personal data that concern you and that you have provided to the Company or request that MAPFRE Middlesea plc transfers them directly to another controller when technically possible.
  • withdraw the consent granted, if applicable, for the purpose specified in the section “What do we use your personal data for?“, without affecting the lawfulness of the processing based on consent prior to withdrawal.

The aforementioned rights of access, rectification, erasure or right to be forgotten, restriction of processing, portability, objection, and the right to object to automated individual decision making may be directly exercised by the data owner or its legal or voluntary representative, through a written communication sent to the Rights Management Bureau on [email protected].

The Data Subjects may file a claim with the Office of the Information and Data Protection Commissioner or through https://idpc.org.mt, particularly if they feel that the concerns raised with the Company in the exercise of its rights, have not been successfully answered.

Section 3 - Laferla Holdings Limited as a Data Processor on behalf of the MAPFRE MSV Life plc

Who is responsible for processing your personal data?

The information and/or personal data which you provide us including, your health data, are included in a file whose controller is:

  • Identity: MAPFRE MSV Life plc – Company Number C15722
  • Post address: MAPFRE MSV Life Plc, The Mall, Triq il – Mall, Floriana FRN1442, Malta.
  • Telephone: +356 2590 9000
  • Email: [email protected]
  • Data Protection Officer Contact[email protected]

For what purposes do we process your personal data?

MAPFRE MSV Life plc shall process all the personal data voluntarily provided by the interested parties directly or through its Insurance Intermediaries, and those obtained by recording telephone conversations or as a result of browsing through Internet webpages or another medium, for the enforcement of the agreement or for a query, application, or to purchase any service or product, even after the end of the pre-contractual or contractual relationship for the following purposes:

  • Management of the insurance activity and/or fulfilment of the agreement or pre-agreement as well as of the legal obligations.
  • Risk assessment and delimitation, for the detection, prevention, suppression and investigation of fraud; in risk selection and claims management, irrespective of whether the insurance agreement is formalised or not and after its termination, if applicable.
  • The performance of statistical studies and calculations, surveys, market trend analyses, and quality control.
  • The processing, monitoring, and updating of any request for information, business, pre-contractual, or contractual relationship, of any of the various MAPFRE Group companies, and management of activity with Insurance Intermediaries.
  • Maintenance and integral and centralised management of its relationship with the various MAPFRE Group companies.

All the data obtained, as well as the processing and purposes specified above are required or related to adequately maintain, implement, and control the contractual relationship.

Only to the extent that you have not expressly objected, the accepted purposes include the delivery of information and advertising, including via email, on offers, products, recommendations, services, promotional items, and customer loyalty campaigns of MAPFRE MSV Life plc and the various MAPFRE Group companies or third-party companies with which any MAPFRE Group company has signed partnership agreement; data extraction and storage, and marketing surveys to adapt our commercial offers to your specific profile, both if a transaction is formalised or not, and once the existing contractual relationship ends.

In order to adequately enforce the insurance agreement and be able to offer you products and services according to your needs, on the basis of the information provided, we will create different profiles based on your interests and necessities allowing the MAPFRE Group to define business strategies, and as a result may undertake automated decisions on the basis of these profiles.

How long will we keep your personal data?

The personal data provided will be kept for the period established on the basis of these criteria: (i) legal obligation of conservation; (ii) term of the contractual relationship and service of any responsibilities derived from the said relationship; and (iii) request of removal by the interested party in the applicable cases.

What is our legal standing regarding the processing of your data?

The legal basis for the processing of your data for the purposes specified in the section “For what purposes do we process your personal data?” is the enforcement of the insurance agreement. The prospective offer of products and services included in the section “For what purposes do we process your personal data?” is based on the consent which you have given us. Under no circumstances will the withdrawal of this consent place conditions on the enforcement of the insurance agreement.

You are obligated to provide us with your personal data to sign the insurance agreement. Should you fail to do so, the Company reserves the right not to sign the insurance agreement.

To whom will your data be communicated?

MAPFRE MSV Life plc may communicate your data, including your health data and the data on the claims associated with the policies, exclusively for the purposes included in the section “For what purposes do we process your personal data?”, to other Insurance and Reinsurance Companies, Insurance Intermediaries, Financial Institutions, Real Estate Agents, and other Service Providers related to its business, belonging to the MAPFRE Group, Subsidiaries and Investees, the Fundaciόn MAPFRE, Public Administrations, and other natural or legal persons that also conduct any of the aforementioned activities and with which the various MAPFRE Group companies enter partnership agreements, whether a transaction is formalised or not, and once the existing contractual relationship has ended, with no need to notify every first communication sent to the aforementioned recipients.

Likewise, any company that is a member of the MAPFRE Group, subsidiaries and investees, may communicate your personal data to any of the aforementioned companies, in order to conduct integral and centralised management of the relationships between the interested parties and the various MAPFRE Group companies, and that interested parties may benefit from the possibility of accessing their data from any of them, complying in all cases with the applicable legislation on personal data protection, with no need for the interested parties to be notified of every first communication made. The communication of data between MAPFRE Group companies is necessary for the maintenance of integral and centralised management of your relationship with the Company, the application of the premium discounts, and other benefits obtained from this fact and the management of customer loyalty programmes if you subscribe tot hem.

As part of the communications described in the previous paragraph, international data transfers may be made to third parties or international organisations, whether there exists a European Commission decision on their adequacy or not. International transfers to countries that cannot guarantee an adequate protection level shall be made on an exceptional basis and will be made whenever they are necessary for the adequate development of the contractual relationship.

The MAPFRE Group has data protection clauses to adequately ensure the protection of your data as part of the communication and international transfer of your data in countries in which they can be applied.

What are your rights when you provide us with your data?

Under the terms and scope established in the regulations in force, any person is entitled to:

  • confirm whether MAPFRE MSV Life plc is processing personal data that concern you, and access them and the information related to their processing.
  • request the rectification of inaccurate data
  • request the removal of data, among other reasons, when they are required for the purposes for which they were collected, in which case the Company will cease to process the data except for the filing of or defence against potential claims.
  • request the limitation of the processing of your data, in which case they will only be processed with your consent, with the exception of their storage and use for the filing of and defence against claims or for the protection of the rights of another natural or legal person or for reasons of significant public interest in the European Union or in a certain Member State.
  • object to the processing of your data, in which case, MAPFRE MSV Life plc shall cease to process your data, except for the defence against potential claims.
  • receive, in a structured, widely-used format that can be machine readable, the personal data that concern you and that you have provided to the Company or request that MAPFRE MSV Life plc transfers them directly to another controller when technically possible.
  • withdraw the consent granted, if applicable, for the purpose specified in the section “What do we use your personal data for?“, without affecting the lawfulness of the processing based on consent prior to withdrawal.

The aforementioned rights of access, rectification, erasure or right to be forgotten, restriction of processing, portability, objection, and the right to object to automated individual decision making may be directly exercised by the data owner or its legal or voluntary representative, through a written communication sent to the Rights Management Bureau on [email protected].

The Data Subjects may file a claim with the Office of the Information and Data Protection Commissioner or through https://idpc.org.mt, particularly if they feel that the concerns raised with the Company in the exercise of its rights, have not been successfully answered.