Purpose of this Policy
Who are we and what do we do
Klapton Reinsurance Limited is a reinsurer registered and regulated in Zambia, offering reinsurance services to both national and international clients. Klapton Reinsurance Limited is the data controller responsible for your personal information processed via the Site.
How to contact us
What personal information do we collect?
We may collect personal information from you in the course of our business, including through your use of our Site, when you contact or request information from us, when you engage our legal or other services or as a result of your relationship with one or more of our staff or clients. Our primary goal in collecting personal information from you is to help us:
To undertake these goals we may process the following personal information:
Klapton Reinsurance Limited is primarily engaged by corporate entities and as such those instructors are not data subjects. However, as part of such engagements personal information may be provided to us (e.g. personal information relating to any of our corporate clients’ or prospective clients’ officers or personnel). If you are an individual whose personal information is processed by us as a result of providing the Services to others (including individual clients and corporate clients) we will process a variety of different personal information depending on the Services provided. This may include personal information relating, without limitation, to any of our corporate clients’ or prospective clients’ officers or personnel. We might also need to process personal information in relation to other third parties engaged either by our own clients or other persons or companies involved with us providing the Services to our client. For clients and prospects, we also collect information to enable us to market our products and Services which may be of interest to you. For this purpose we collect:
If you are a potential recruit to join Klapton Reinsurance Limited we collect:
How do we use your personal information?
We may use your information for the following purposes: Fulfilment of Services We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or our Services to enable us to perform the Services. Please note also that our contractual terms of business apply when we provide the Services. What is our legal basis? It is necessary for us to process your information to perform our obligations in accordance with any contract that we may have with you. It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others. Client services Our Site uses various user interfaces to allow you to request information about our Services including electronic enquiry forms and a telephone enquiry service. Contact information may be requested in each case, together with details of other personal information that is relevant to your Service enquiry. This information is used in order to enable us to respond to your requests. What is our legal basis? It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others. Business administration and legal compliance We use your personal information for the following business administration and legal compliance purposes:
What is our legal basis? Where we use your personal information in connection with a business transition, to enforce our legal rights, or to protect the rights of third parties it is in our or a third party’s legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us. Recruitment We use your personal information for the following recruitment purposes:
What is our legal basis? Where we use your personal information in connection with recruitment it will be in connection with us taking steps at your request to enter a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions for Klapton Reinsurance Limited. We will not process any special category data except where we are able to do so under applicable legislation or with your explicit consent. Marketing communications We carry out the following marketing activities using your personal information:
Our web pages contain “cookies” “web beacons” or “pixel tags” (“Tags”). Tags allow us to track receipt of an email to you, to count users that have visited a web page or opened an email and collect other types of aggregate information. Once you click on an email that contains a Tag, your contact information may subsequently be cross-referenced to the source email and the relevant Tag. In some of our email messages, we may use a “click-through URL” linked to certain websites administered by us or on our behalf. By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of offers our registered users like to see. We also use this information for marketing purposes (see the marketing section above for further details). What is our legal basis? Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other clients. Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details, where available.
What is our legal basis to use or process your personal information?
It is necessary for us to use your personal information:
Who do we share your personal information with?
Klapton Reinsurance Limited may share personal information with a variety of the following categories of third parties as necessary:
Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide the Services as effectively as we can.
Third party contractors and other controllers
As mentioned above, we may appoint sub-contractor data processors as required to deliver the Services, such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, document and information storage providers, who will process personal information on our behalf and at our direction. We conduct an appropriate level of due diligence and put in place contractual documentation in relation to any sub-contractor to ensure that they process personal information appropriately and according to our legal and regulatory obligations. Further, we may appoint external data controllers where necessary to deliver the Services. When doing so we will comply with our legal and regulatory obligations in relation to the personal information, including but without limitation, putting appropriate safeguards in place. What is our legal basis? It is necessary for us to perform our obligations in accordance with any contract that we may have with you. It is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services in the best way that we can.
Where do we transfer your data to?
In order to provide the Services we may need to transfer your personal information to locations outside the jurisdiction in which you provide it. If you are based within the European Economic Area (EEA), please note that where necessary to deliver the Services we will transfer personal information to countries outside the EEA.
Confidentiality and the security of your personal information
We are committed to keeping the personal information provided to us secure and we have implemented appropriate information security policies, rules and technical measures to protect the personal information that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. All of our directors, employees, consultants, workers and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information.
How to access your information and your other rights
You have the following rights in relation to the personal information we hold about you:
Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.
Green City Office ParkKelvin Siwale RoadRhodesparkLusaka, Zambia
firstname.lastname@example.org+260 211 222 696
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