Privacy Policy

Introduction

The Laferla Group (“Laferla,” “we,” “our,” or “us”) is committed to protecting your personal data and ensuring transparency in how it is collected, processed, and used. This Privacy Policy outlines our practices in compliance with the General Data Protection Regulation (GDPR) and other applicable laws.

The Laferla Group includes:

1. Laferla Insurance Agency Limited; Company Nr C14529; Registered at 204A, Vincenti Buildings, Old Bakery Street, Valletta VLT1453, Malta

2. Laferla Holdings Limited; Company Nr C11059; Registered at 25/20, Vincenti Buildings, Strait Street, Valletta VLT1432, Malta

3. Laferla Services Limited; Company Nr C79815; Registered at 25/20, Vincenti Buildings, Strait Street, Valletta VLT1432, Malta

4. Laferla Digital OÜ, Company Number 16525710; Registered in Tallinn, Estonia; and

5. Any other company which may in future be established with the same direct or indirect control, forming part of the Laferla Group.

Key Definitions

First-Party Data:

Data collected directly through your interactions with Laferla, including via our website, app, in-person engagements, and customer support channels.

Zero-Party Data:

Data voluntarily shared by you, such as preferences, intentions, and feedback collected via surveys, forms, or direct interactions.

Third-Party Services:

Services offered by external providers that you access through Laferla based on your agreement to sign up to the services from such providers.

Data We Collect from Customers

1. Personal Details:

Name, surname, contact details, date of birth, national identification numbers, and other identifiers.

1. a. Policy information, such as type, duration, spend and coverage details, as well as details of assets or circumstances which you are insuring

2. b. Claims data, including claims history and supporting documentation.

3. c. Information used for underwriting of an application for insurance.

4. d. Employment and financial details, where necessary.

3. Transactional Data:

Payment history, transaction details, and records of transactions made through Laferla platforms or facilitated third-party services.

4. Behavioural and Usage Data:

Data collected through your interactions with our website, app, and digital communications (e.g., clickstream data, browsing behaviour, interaction with online publications and adverts).

5. Life Event Data:

Information related to milestones such as marriage, childbirth, relocation, or other significant changes.

6. Preference Data:

Communication preferences, survey responses, and expressed interests.

7. Third-Party Service Data:

Data generated or shared when you use external services facilitated by Laferla.

8. Affiliate and Referral Data:

Details from referrals, affiliate links, or shared promotions.

Data We Collect from Third Parties

Throughout the course of our operations, we may require data from Third Parties which is necessary for us to fulfil our contractual obligations to our customers. For instance, if we are asked to settle insurance claim costs directly to a third party, which may include suppliers such as, but not limited to, legal professionals, loss adjusters, medical professionals, hospitals and clinics, and third party administrators, then we may require some data from these third parties to fulfil our duties.

n such cases, we will always minimise the data that we request. Common requests may include data such as, but not limited to, identity verification aswell as verified contact details which are required for sharing of customer data, bank details, and qualifications and credentials to substantiate the provision of service to our customers.

We may also require such service providers to enter into a Data Processing Agreement and other similar agreements to ensure that Laferla is meeting its obligations under various laws and regulations, including but not limited to GDPR.

How We Use Your Data

We process Customer Data for the following purposes:

Service Delivery:

1. Administering insurance policies, including underwriting, billing, and claims management.

2. Facilitating access to third-party services.

Personalisation:

1. Enhancing your experience with Laferla through a personalised approach.

2. Enhancing your app and website experience with customised content.

3. Creating tailored marketing campaigns and personalised product or service recommendations.

Customer Engagement:

1. Informing you about relevant products and services based on your preferences, behaviour and life events.

2. Conducting surveys to gather feedback and improve our offerings.

Compliance:

1. Meeting legal and regulatory obligations, including but not limited to, Data Protection regulations, anti-money laundering (AML) and know-your-customer (KYC) requirements and regulations.

Quality and Assurance Purposes:

We process Third Party Data for the following purposes:

Service Delivery:

1. Fulfilling our requirements to administer insurance policies, including underwriting, billing, and claims management.

2. Notifications of relevant changes to processes, requirements or other relevant information with respect to our agreement or relationship with the Third Party.

Compliance:

1. oMeeting legal and regulatory obligations, including but not limited to, Data Protection regulations, anti-money laundering (AML) and know-your-customer (KYC) requirements and regulations

Quality and Assurance Purposes.

Data Collection Sources

We collect data from:

Interactions:

Data from our website, app, digital media and adverts, offline marketing initiatives with a digital link, in-person meetings, engagement at events hosted, sponsored or attended by Us, and customer service channels.

Insurance Operations:

Data provided during policy applications, renewals, claims submissions, or inquiries.

Surveys and Forms:

Data shared through optional surveys and preference forms.

Integrated Services:

Data from external services accessed via Laferla.

Legal Basis for Processing

We process your data based on:

Performance of a Contract:

For administering insurance policies andfacilitating third-party services which you have signed up to. This may also include informing you of changes and updates to any active services.

Legal Obligations:

To comply with laws and regulatory requirements.

Legitimate Interests:

To enhance our services, improve customer experience, and conduct marketing activities.

Consent:

For specific purposes, such as optional marketing communications.

Consent and Preferences

Consent and Preferences

1. Where consent is required by law, this is collected upon account creation by agreeing to the Privacy Policy and relevant Terms & Conditions and remains valid until withdrawn.

2. You can modify or withdraw your consent for specific processing activities via the Privacy Center in our app.

Sharing Your Data

Your data may be shared with:

Service Providers:

Third-party providers for payment processing, marketing, analytics, and other operational services necessary for the performance of our contract with you.

Regulators and Authorities:

As required by law or regulation.

External Partners:

Partners providing services you access through Laferla.

Data Security

We implement robust measures, including encryption and access controls, to protect your data from unauthorised access or breaches.

Retention Policy

We retain data for as long as required to fulfil the purposes outlined in this Policy, meet legal obligations, or resolve disputes.

Your Rights

You have the right to:

1. Access, correct, or delete your data.

2. Object to processing or restrict certain uses of your data.

3. Withdraw consent for specific activities at any time.

To understand and exercise your rights with any external service provider within a context where Laferla is considered a Data processer and the external service provider is considered the Data Controller, please seek guidance from the external service provider.

Updates to this Privacy Policy

We may update this Policy periodically. Changes will be communicated via email or the app.

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