Privacy & Cookies Policy for NexusInc Insurance Cyprus
- Introduction
- Key terms
- The scope of this privacy policy
- Personal information we collect about you
- How your personal information is collected
- How and why we use your personal information
- Who we share your personal information with
- Where your personal information is held
- How long your personal information will be kept
- Transferring your personal information out of the EEA
- Your rights
- Keeping your personal information secure
- How to complain
- Changes to this privacy policy
- How to contact us
- Cookies and Tracking Technologies
Introduction
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation (EU) 2016/679 (commonly known as the “GDPR”), which applies across the European Union and we are responsible as the controller of that personal information for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant Cyprus and EU legislation and our professional duty of confidentiality.
Key terms
It would be helpful to start by explaining some key terms used in this policy:
| we, us, our | NEXUSINC INSURANCE AGENTS, SUB-AGENTS AND CONSULTANTS LTD, (also referred to as NEXUS INC) is a limited liability registered in the Republic of Cyprus, with company registration number HE 441017 and registered office at Evelthontos 15, Strovolos, 2003 Nicosia, Cyprus. It is regulated by the Insurance Companies Control Service (licence registration number: 7568. |
| personal information | Any information relating to an identified or identifiable individual. |
| Special categories of personal information | Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, Genetic and biometric data. Data concerning health, sex life or sexual orientation. |
The scope of this privacy policy
This privacy policy applies in the following circumstances:
- when we provide or we agree to provide insurance intermediary services to actual and prospective clients, which consist of the submission of proposal forms to insurers and provision of insurance advice to actual or prospective clients;
- when, in the process of providing our services to clients, we process personal information of individuals who are not themselves our client, but who could be an insured person or beneficiary under an insurance policy;
- when you request information from us or provide information to us;
- when we process personal information of individuals who could be (or could be the employees or staff of) transaction counterparties, or litigants in legal proceedings involving, our actual or prospective clients.
How your personal information is collected
We collect most of this personal information directly from the proposal form which is filled in and submitted to an insurance company for the purpose of concluding or renewing an insurance policy. If you are the proposer and are an individual, then this data will be collected from you. If the proposer is a commercial client, this data will be collected by the person instructed by that legal entity to fill in the proposal form.
However, we may also collect information:
- from publicly accessible sources, for example the Registrar of Companies.
- directly from third parties, for example:
- sanctions screening providers,
- credit reference agencies,
- client due diligence providers.
- from a third party with your consent, for example:
- a family member or relative,
- your bank or advisor,
- other professionals you may engage in relation to your matter,
- your employer or organisation,
- your doctors, medical and occupational health professionals,
- your insurer.
- via our IT systems for example, case management and document management systems.
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party, where your interests and fundamental rights do not override our interests or those of a third party; or
- where you have given your consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and the legal bases which we rely on to do so:
| What we use your personal information for | Type of information | Lawful basis for processing |
To provide insurance intermediary services to you or your organisation
| a) Identity Data b) Contact Data c) Financial Data d) Background Data e) Information relating to the matter in which we are instructed to provide our legal advice or representation | a) Performance of a contract with you or taking steps at your request before entering into a contract b) Necessary for our legitimate interests (ensuring that you are provided with the best services we can offer, record and administer our transactions) c) Necessary to comply with our legal and regulatory obligations |
| If you are our (actual or prospective) client or a family member or dependent of our (actual or prospective) client or a beneficiary under an insurance policy, to check whether we would have a conflict of interest in acting for such client | a) Identity Data b) Contact Data c) Financial Data d) Background Data e) Information relating to the matter in which we are instructed to provide our legal advice or representation | a) Performance of a contract or to taking steps at your request before entering into a contract
b) Necessary to comply with our legal or regulatory obligations
c) Necessary for our legitimate interests (ensuring we and all other parties concerned understand any conflict of interest which may arise for us in a matter)
|
To take you on as a client, including: a) conducting checks to identify our clients and verify their identity b) performing anti-money laundering, fraud and other background checks
| a) Identity Data b) Contact Data c) Financial Data d) Background Data e) Information relating to the matter in which we are instructed to provide our legal advice or representation | a) Performance of a contract or taking steps at your request before entering into a contract
b) Necessary to comply with our legal or regulatory obligations c) Necessary for our legitimate interests (ensuring we do not deal with proceeds of criminal activities or assist in any other unlawful or fraudulent activities for example terrorism, |
| To manage payments, fees and charges, and to collect and recover money owed to us | a) Identity Data b) Contact Data c) Financial Data d) Transaction Data | a) Performance of a contract
b) Necessary for our legitimate interests (for running, administering and protecting our business and our rights |
To manage our relationship with you or your organisation which will include: a) notifying you about changes to how we operate our business or our terms of business deal with you b) updating the information we have about you
| a) Identity Data b) Contact Data
| a) Performance of a contract with you or to taking steps at your request before entering into a contract b) Necessary to comply with our legal and regulatory obligations c) Necessary for our legitimate interests (to inform you about our business and keep our records updated) |
To run, administer and protect our business which will include: a) ensuring business policies are adhered to b) operational reasons, such as improving efficiency, training and quality control c) preventing and detecting fraud d) preventing unauthorised access and modifications to systems e) ensuring safe working practices, staff administration and assessments f) ensuring the security of our premises, and detecting and preventing unauthorised access to our premises and restricted areas g) to improve our website and services, and client relationships
| a) Identity Data b) Contact Data c) Financial Data d) Transaction Data e) Usage data
| a) Necessary for our legitimate interests (for running, administering and protecting our business, monitoring and improving our business, making sure we are following our own internal procedures and working efficiently, preventing and detecting fraud and unauthorised access and modifications to systems) b) Necessary to comply with our legal and regulatory obligations |
| Gathering and providing information and making filings required by law or relating to audits, enquiries or investigations by regulatory bodies or authorities | a) Identity Data b) Contact Data c) Financial Data d) Transaction Data | a) Necessary to comply with our legal and regulatory obligations b) Necessary for our legitimate interests (for protecting our rights and defending ourselves in the context of audits, enquiries or investigations administration)
|
| External audits and quality checks | a) Identity Data b) Contact Data c) Financial Data d) Transaction Data | a) Necessary to comply with our legal and regulatory obligations b) Necessary for our legitimate interests (for maintaining our accreditations and operating at the highest standards)
|
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Who we share your personal information with
In the normal course of our business we will share your personal information with the insurers which you decide to submit a proposal to for the purpose of concluding an insurance policy. The insurance undertakings which we work with are the following:
- AIG Europe S.A.;
- CFC Europe S.A.
- Metlife Europe d.a.c.;
- CNP Asfalistiki Limited.
- General Insurance of Cyprus Limited;
- Atlantic Insurance Company Public Ltd;
- Allianz Greece Single Member Insurance S.A.
In addition to the above, we routinely share personal information with:
- our professional advisers or consultants, including bankers, legal advisors, auditors and accountants;
- service providers who provide information technology and system administration services to us;
- external auditors, any person or entity to whom we are required or requested to make such disclosure by any court of competent jurisdiction or by any governmental, taxation or other regulatory authority, law enforcement agency or similar body; and
- our own insurers, re-insurers, brokers, re-brokers, and banks.
We only allow third parties to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal information is held
Your information is stored in physical files in our premises in Cyprus and also in electronic form in servers located in the EU. However, it may also be held by third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
How long your personal information will be kept
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for. This includes for example the purposes of satisfying any legal, regulatory, accounting, reporting requirements, to provide our services to you or your organisation.
Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you in accordance with the law; and
- to keep records required by law.
Different retention periods apply for different types of personal information. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal information out of the EEA
We will most likely not transfer your personal information outside the European Economic Area (EEA). However, it could in the future be necessary for us to share your personal information with any service providers located outside the EEA or if there is an international dimension to the services we are providing.
If so, such transfers will be subject to special rules under European and Cyprus data protection law.
If we do transfer your personal information out of the EEA, we will ensure a degree of protection similar to that afforded in EEA countries is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission.
- Where we transfer your personal information to countries that have not been deemed to provide an adequate level of protection for personal information by the European Commission, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe.
If you would like further information please contact us (see ‘How to contact us’ below).
Your rights
You have the following rights in relation to your personal information:
| Access | The right to be provided with a copy of your personal information. |
| Rectification | The right to require us to correct any mistakes in your personal information. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us. |
| To be forgotten | The right to require us to delete your personal information (in certain circumstances). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. |
| Restriction of processing | The right to require us to restrict processing of your personal information (in certain circumstances). This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it. |
| Data portability | The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. |
| To object | The right to object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. |
| Not to be subject to automated individual decision-making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. |
| Withdraw consent | The right to withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent. |
For further information on each of those rights, including the circumstances in which they apply, please contact us or visit the website of the Commissioner for the Protection of Personal Data (www.dataprotection.gov.cy).
If you would like to exercise any of those rights, please:
- email, call or write to us—see below: ‘How to contact us’;
- let us have enough information to identify you;
- let us have proof of your identity; and
- let us know what right you want to exercise and the information to which your request relates.
You will not have to pay a fee to access your personal information or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Cyprus is the Commissioner for Personal Data Protection who can be contacted at 1 Iasonos street, 2nd floor, 1082 Nicosia; tel: 22818456; fax: 22304565; email: [email protected]; www.dataprotection.gov.cy.
How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:
15 Eveltontos Street, 2003, Strovolos, Cyprus
Email: [email protected]
Tel: +357 99197242
Cookies and Tracking Technologies
Our website uses cookies and similar technologies to ensure it functions correctly, improve your browsing experience, and, where applicable, support marketing and analytics efforts.
What are cookies?
Cookies are small text files stored on your device when you visit a website. They allow the site to remember your preferences, such as language or login details, and help us understand how visitors use our site.
Types of cookies we use:
Strictly Necessary Cookies – essential for the website to operate, enabling core functions like secure login, privacy preferences, and form submissions. These cannot be switched off.
Performance/Analytics Cookies – help us analyze how visitors interact with the site to improve its performance.
Google Analytics
Google Analytics is Google’s analytics tool that helps our website to understand how visitors engage with their properties. It may use a set of cookies to collect information and report website usage statistics without personally identifying individual visitors to Google.
Functionality Cookies – remember your settings and preferences to enhance usability.
Marketing/Third-Party Cookies – used, where applicable, for advertising and remarketing purposes.
First-party and third-party cookies:
We use cookies set by us (first-party) and by trusted third parties for analytics or advertising. Third-party cookies come from domains other than ours.
Managing your cookies:
You can set your browser to block or alert you about cookies. Please note that blocking certain cookies may affect the functionality of the website.
By continuing to use our website, you consent to the use of cookies as described here.