1. Introduction
Seven Insurance Brokers LLC (“Seven Insurance Brokers”, “we”, “us”, “our”) is committed to protecting the privacy and confidentiality of all personal information we process. This policy sets out how we collect, use, store, and protect Personally Identifiable Information (PII) and Protected Health Information (PHI) relating to our customers, employees, business partners, vendors, suppliers, service providers, and job applicants.
This policy has been prepared in accordance with applicable UAE federal and local data protection legislation, including the Abu Dhabi Healthcare Information and Cyber Security Standard (ADHICS v2).
2. Scope
This policy applies to all users, operating facilities, and IT resources, including systems, networks, software, data storage devices, and communications equipment, used to store, process, transfer, or manage PII and PHI.
3. Data We Collect and Why
We collect PII and PHI only for clearly identified, lawful purposes, and only to the extent necessary for those purposes (data minimisation). Before collecting your personal data, we will obtain your explicit consent and explain clearly what it will be used for. You have the right to withdraw your consent at any time.
4. How We Use Your Data
Your PII and PHI will only be used for the purpose for which it was collected, as agreed with you at the time of collection. It will not be disclosed or used for any other purpose without your consent. We process your data in a fair, lawful, and transparent manner.
5. Your Rights
You have the right to: access the PII and PHI we hold about you; request correction, update, suppression, or deletion of your data; object to the processing of your data, including decisions made by automated processing; and receive your data in a machine-readable format where applicable. To exercise any of these rights, please contact our Data Protection Officer.
6. Data Security
We protect your PII and PHI using appropriate technical and organisational safeguards, including system controls (user access management, network security, data security), process controls (data classification, backup and retention policies, compliance audits), and people controls (confidentiality agreements, staff training, awareness programmes, background checks). All PII and PHI is stored, processed, and transferred within the UAE. Data will only be held or transmitted outside the UAE where a valid exemption has been granted by the Department of Health (DoH).
7. Disclosure to Third Parties
We will only share your PII and PHI with third parties with your explicit consent. Where third-party data processors are engaged, we conduct due diligence and ensure that appropriate data protection and privacy provisions are included in all contracts and service level agreements.
8. Data Accuracy and Retention
We take reasonable steps to keep your data accurate, complete, and up to date. Your PII and PHI is retained only for as long as necessary to fulfil the stated purpose, or as required by applicable law. Where data is no longer needed, it will be anonymised or securely disposed of.
9. Cross-Border Data Transfers
Where business requirements necessitate the transfer of PII or PHI to entities or third parties outside the UAE, such transfers will be conducted in full compliance with applicable federal and local regulations governing data transfer, processing, and storage.
10. Data Breach Management
In the event of a suspected or confirmed privacy breach, we will record and investigate the incident promptly, notify the relevant regulatory authority within the required timeframe, and inform affected individuals of the nature of the breach, its potential impact, and the steps taken to address and prevent recurrence.
11. Data Privacy Impact Assessments (DPIA)
We conduct Data Privacy Impact Assessments for new projects and processing activities that may present privacy risks, prior to the commencement of processing. DPIAs ensure that privacy risks are identified and mitigated at the earliest stage.
12. Training and Awareness
We provide regular training and awareness programmes to our staff, partners, and other relevant parties to ensure understanding of data privacy obligations and to reduce the risk of a privacy breach.
13. Policy Compliance
Any breach of this policy may result in disciplinary action and/or legal proceedings in accordance with applicable UAE law. Users who are uncertain about their obligations under this policy should seek guidance from the relevant team.
14. Contact Us
For any queries, subject access requests, or concerns relating to your personal data, please contact us at: Seven Insurance Brokers LLC, 49th Floor, Tower B, Business Central Towers, Internet City, Dubai, PO 214909. Tel: +971 4 436 1800. Email: info@seveninsurancebrokers.com. Web: www.seveninsurancebrokers.com