Pan-American México, Compañía de Seguros, S.A. de C.V. Privacy Notice
I. Identity and Address of the Data Controller
Pan-American México, Compañía de Seguros, S.A. de C.V. (hereinafter referred to as the “Company”) is an Insurance Institution that has been authorized to operate as such by the Ministry of Finance and Public Credit. It was incorporated in accordance with the laws of Mexico. The address of its registered office is Av. Paseo de la Reforma 412, suite 1501, Colonia Juárez Delegación Cuauhtémoc, Código Postal 06600, Ciudad de México. The Company is the data controller responsible for the processing of your personal data that have been directly collected as a result of our legal relationship with you, through our Insurance Agents or through any third party that must send or transfer your personal data to the Company for the proper performance of its obligations. The above includes data sent via print formats, electronically, by fiber optics, by audio, by visual means, or by any other means or technology.
II. Personal Data to Be Processed
The categories of personal data that the Company may request and use for the purposes of its services are the following: identification and gender data; contact information and address; information regarding your occupation; financial data; information on academic background; movement and immigration data; and data on administrative and judicial matters. In addition, depending on the type of insurance, data relating to the following Sensitive Data categories will be used: data on your health status; personal characteristics and habits; and physical characteristics.
III. PRIMARY Purposes of the Processing
The personal data described above will be processed for the following purposes: to accurately identify you; to evaluate your Insurance Application and select the risk to be covered, or to include you as an insured in a Group Insurance policy; to determine the premium and deductible applicable to the requested insurance; to determine the kind of coverage you require; to issue, maintain, manage, and renew the Insurance Policy through our marketing network; to handle losses and to process and pay insurance claims; to contact family members in case of emergency; to request references and to conduct inquiries, investigations, and reviews involving losses and any complaints and/or claims; to provide the service under the insurance policy/policies through the Company’s supplier network; to prevent fraud and detect transactions using funds from illegal sources; to conduct statistical studies; and to fulfill the Company’s obligations and to exercise the Company’s rights provided under the Insurance Contract Act (Ley Sobre el Contrato de Seguro) and the Insurance and Financial Institutions Act (Ley de Instituciones de Seguros y de Fianzas) and other related legislation.
IV. SECONDARY Purposes of the Processing
Your personal data may be processed to offer and promote goods, products, and services and/or for marketing and business prospecting purposes, by both the Company and business partners offering complementary services or services related to the insurance offered by the Company, provided that you consent to such purpose as established by Article 294(XIV) of the Insurance and Financial Institutions Act.
V.Transfers of Personal Data
The Company informs you that it will transfer your personal data to third parties for the PRIMARY purposes described in this Notice. The transfers to be carried out by the Company will be directed to service providers (to provide services, handle losses, and manage the policy); Insurance Agents and the marketing network (to issue, maintain, renew, and provide other services related to the policy); regulatory, governmental, and judicial authorities (for compliance with applicable regulations, for statistical studies, and for the prevention and detection of transactions using funds from illegal sources); and other Insurance Institutions and Insurance Institution Associations (for underwriting, investigations, compensation payments, and fraud prevention).
Furthermore, the Company may transfer your personal data to third parties for the SECONDARY purposes set forth in this Notice. We will deem that you have granted your tacit consent to this if you do not express your disagreement with such transfer when the Privacy Notice is communicated, when the data are directly or personally collected, or via an email sent to the Company’s Privacy Officer.
If the Company transfers financial or sensitive personal data for SECONDARY purposes or for any other purpose not included in this Notice, the Company will inform you and will obtain, if applicable, your express or written consent, as required.
VI. Means for Exercising the Rights to Access, Rectification, Erasure, and Objection
You may request from the Company the Access, Rectification, or Erasure of the data for which you are the data subject, as well as object to the processing of such personal data. You may do so directly or through a representative, by sending to the Privacy Officer the form entitled “Exercise of the Rights to Access, Rectification, Erasure, and Objection” (“Ejercicio de derechos ARCO”) (which you can download at the URL www.palig.com/mexico or request at our offices). Such form must be accompanied by the documentation specified in the form.
The exercise of your Rights to Access, Rectification, Erasure, and Objection allows you to request the following from the Company:
Access: The data subject may request that we inform him or her of the personal data that are processed by the Company. The data subject’s data may be provided by the Company through non-notarized printed copies or by electronic means.
Rectification: The data subject may request that the Company rectify one more of his or her personal data. To this end, he or she must provide documentary evidence proving the appropriateness of the rectification.
Objection: The data subject may object to the processing of his or her data for a certain purpose. In this regard, the data subject should take into account that data processing for the PRIMARY purposes is essential for the fulfillment of the Company’s obligations under the insurance contract and the laws governing it.
Erasure. The data subject may request that his or her personal data processed by the Company be erased, provided that such data are no longer used for the relationship established with the data subject and provided that the Company is not required by Law to process such data for a minimum period of time. In exercising this right, it should be taken into account that the Company may not erase personal data until allowed by the laws regulating the Company, if applicable. The exercise of your rights to Access, Rectification, Erasure, and Objection is free of charge. However, the Company may request that the data subject pay only reasonable shipping costs or the costs of reproducing the requested information.
After the request has been submitted in the required form and with the required complete documentation, the Company will inform the data subject of the Company’s decision within a maximum of 20 (twenty) days. If the request is deemed appropriate, it will take effect within 15 (fifteen) days of the date on which notice is given of the Company’s response.
VII. Means to Limit the Use and Disclosure of Personal Data
Since the processing of your personal data is essential for all of the activities and obligations under the Insurance Contract and for compliance with the legal provisions governing the Company, it is not possible to limit the Company’s processing of your personal data with respect to the PRIMARY purposes established in this Notice.
However, in order to limit the use and disclosure of your personal data for the SECONDARY purposes established in this Notice, you must communicate such request via email to the Company’s Privacy Officer at the email firstname.lastname@example.org.
When we collect your personal data through electronic means (the internet), the Company may automatically extract any information it deems necessary, for statistical and business prospecting purposes.
VIII. Revocation of Consent
You can revoke any consent that, if applicable, you have granted us for the processing of your personal data by sending an email to the Company’s Privacy Officer. You understand that this will result in the termination of our services and of any legal relationship that you may have with the Company; that is, the cancellation of the Insurance Contract.
IX. Limits to the Use of Your Personal Data
In order to limit the use of your personal data for the Secondary Purposes of the processing of your personal data, you may request that your data be included in the exclusion lists kept by Company for this purpose. The Company has implemented administrative, technical, and physical security measures to protect your personal data against damage, loss, alteration, or destruction, or unauthorized use, access, or processing, and to ensure that any third party performing the data processing respects this Privacy Notice.
X. Security Measures
The Company has implemented administrative, technical, and physical security measures to protect your personal data against damage, loss, alteration, or destruction, or unauthorized use, access, or processing, and to ensure that any third party performing the data processing respects this Privacy Notice.
XI. Means of Communicating the Privacy Notice and Any Changes to the Privacy Notice
This Privacy Notice and any changes to the Privacy Notice will be available at the website www.palig.com/mexico and in announcements placed at our offices. However, you may also be informed of the Privacy Notice and any changes to the Privacy Notice by any other means of communication.
XII. Contact Information for the Company’s Privacy Officer
Av. Paseo de la Reforma 412
Colonia Juárez Delegación Cuauhtémoc, Ciudad de México
Código Postal 06600
Last updated: June 30, 2017