Alpha PPLI Privacy Statement
This document outlines the privacy practices of Alpha PPLI – Branch of Providence Life Assurance (Bermuda). Our commitment is to safeguard your personal information, ensuring its collection and use are appropriate, lawful, and transparent.
About Us
Alpha PPLI operates as a brand name for Alpha PPLI – Branch of Providence Life Assurance (Bermuda), delivering wealth management products and services globally.
Information We Collect
We gather specific personal details about you, which may include your name, contact information (address, phone number), and other relevant data. This information is typically collected when you:
- Interact with our website or secure online services.
- Enquire about our products or services.
- Apply for and receive our services.
- Consult with a financial adviser.
- Subscribe to our newsletters.
The nature of the personal information collected will depend on the purpose of collection and may encompass:
- Contact Information: Your primary means of communication.
- Identity Verification: Data required to confirm your identity.
- Personal Background: Information related to your family, lifestyle, and health.
- Financial Details: Bank and other financial specifics.
- Employment Information: Details about your professional background.
We primarily obtain personal information directly from you. For example, during the initial stages of our relationship (e.g., when applying for a policy or service) and in subsequent communications, we request information to verify your identity. This is a legal obligation designed to protect both you and us against criminal activity.
When providing services to trusts, we collect relevant personal information for the settlor, protector, beneficiaries, and trustees. For companies, we may collect personal information for Directors, Shareholders, and Beneficial Owners.
If it becomes necessary to collect more sensitive information, such as data concerning criminal convictions or detailed health information, we will clearly explain what is needed and why.
We may also obtain information about you from external sources, including:
- Your financial adviser.
- Any other authorised agent you may have.
- Third-party entities (e.g., for enhanced due diligence and identity verification).
- Cookies (small text files placed on your computer by websites to enhance functionality and provide information to website owners).
Your personal information is retained only for as long as necessary to fulfil the purpose for which it was collected, or as required by legal or regulatory obligations. Data no longer needed will be securely disposed of in accordance with our Personal Data Retention and Disposal Schedule.
How We Use Your Information
We process your personal information for the following objectives:
Contractual Obligations & Relationship Management
- Processing applications for our services.
- Delivering our products and services, including managing our relationship with you, your adviser, or any other agent.
- Executing requested transactions.
- Monitoring or recording telephone calls for query resolution, issue management, audit, or training.
- Maintaining records to ensure compliance with legal and regulatory requirements.
- Providing additional services such as enhanced due diligence, underwriting, reinsurance, data hosting, online services, payments, and tax/levy reporting.
Legal & Regulatory Compliance
- Confirming your identity for regulatory purposes.
- Detecting and preventing fraud, money laundering, terrorist financing, bribery, or other misconduct.
- Meeting tax reporting obligations, including Common Reporting Standards (CRS) and the US Foreign Account Tax Compliance Act (FATCA).
Business Purposes
- Verifying your identity for security.
- Improving, testing, modifying, and personalising our services.
- Sending communications we believe are relevant to you.
- Conducting customer satisfaction research or statistical analysis.
- For audit and record-keeping.
- Enhancing the security of our network and information systems.
- Maintaining effective management systems, including internal reporting to our parent company and corporate group members.
You have the right to object to the processing of your personal data for the aforementioned business purposes. However, this may impact Alpha PPLI’s ability to continue servicing your policy.
Who We Share Your Information With
We share your information with trusted third parties who assist us in providing products and services or meeting regulatory requirements (e.g., tax reporting). These include:
- Other companies within the Alpha Growth PLC group of businesses.
- Your financial adviser, their third-party data providers, and any other authorised party.
- Third parties who perform tasks for us to facilitate service provision or accurate tax reporting and administration of your policy.
- Third parties for identity verification, in line with anti-money laundering or other requirements.
- Law enforcement and fraud prevention agencies to deter and detect fraud.
- Regulatory or governmental agencies, such as the Isle of Man Financial Services Authority.
- Appointed discretionary asset managers or custodians to fulfil their legal or regulatory obligations.
- Prospective buyers (or their advisors) for due diligence, if we are considering a sale of any business or assets.
- Other agencies as mandated by law, court order, or regulation.
Information Security
We are dedicated to maintaining the confidentiality of your personal information. We continuously review our security controls and related policies to ensure your data remains secure.
When engaging third parties, we mandate that they implement appropriate security, privacy, and confidentiality measures to protect personal information.
Should we collaborate with third parties in countries outside the EEA, we ensure these countries offer an adequate level of personal data protection as confirmed by the European Commission, or that the third party provides adequate safeguards and commits to the same level of protection we uphold.
Your Rights
You have the right to request:
- A copy of the personal information we hold about you.
- Updates or corrections to your personal information.
- Deletion of your information.
- Restriction of processing of your personal information where appropriate.
In specific circumstances, you also have the right to:
- Object to the processing of your personal information.
- Object to automated decision-making and profiling.
- Data portability.
For more details on your data protection rights, please visit: https://www.inforights.im/.
Our Appointed Representative in the Isle of Man is an establishment of Alpha PPLI – Branch of Providence Life Assurance (Bermuda) located at 3rd Floor, 34 Hope Street, Douglas, Isle of Man, IM1 1AP.
Contact Us
For questions about this notice, further information on our privacy practices, or to lodge a complaint, please contact our Data Protection Officer:
Write to:
Data Protection Officer,
Alpha PPLI – Branch of Providence Life Assurance (Bermuda),
3rd Floor, 34 Hope Street,
Douglas, Isle of Man, IM1 1AP, British Isles
Email: jm@alphappli.com
Telephone: +44 (0)1624 855340
If you are not satisfied with our response, you may complain to our supervisory authority:
Write to:
The Isle of Man Information Commissioner,
First Floor,
Prospect Hill,
Douglas,
Isle of Man,
IM1 1ET, British Isles
Email: ask@inforights.im
Telephone: +44 (0) 1624 693260
Please note that calls may be monitored and recorded for training and to avoid misunderstandings.
Alpha PPLI – Branch of Providence Life Assurance (Bermuda) is registered in the Isle of Man. Registered Office: 3rd Floor, 34 Hope Street, Douglas, Isle of Man, IM1 1AP. Tel: +44 (0)1624 855340. Licensed by the Isle of Man Financial Services Authority.
Alpha PPLI is registered in the Isle of Man as a business name of Alpha PPLI – Branch of Providence Life Assurance (Bermuda).