Privacy policy

Privacy Policy

Privacy Policy and our compliance with Panamaian Law 81 of March 26, 2019, on Personal Data Protection, and Law 12 of April 27, 2012, which regulates insurance activity in Panama, and related regulations.

Below, we detail our Practices regarding the handling of your personal information, always safeguarding and protecting the information you share with us. This Privacy Policy includes examples of the types of personal information we collect and the companies with which we share that information. These examples are illustrative and should not be considered a complete inventory of our collection, use, and disclosure of information. We also provide you with the opportunity to prevent us from sharing your personal information with companies that are not our affiliates.

At EFFLUZ S.A., we wish to maintain the confidentiality of all personal information we obtain from individuals who visit our websites. We want you to understand how and why we collect, use, and disclose the personal information you provide to us on our websites.

Definitions

For the purposes of this Protocol on Policies for the Use, Processing, Access to Information, and Protection of Data, the following terms shall have the meanings assigned to them below:

  1. Data storage: The preservation or custody of data in a database belonging to EFFLUZ S.A. or to third parties that we subcontract for an activity authorized by the User and/or Panamanian regulations.
  2. Consent: An expression of intent granted by the user so that EFFLUZ S.A. may collect, use, access, process, and transfer all or part of the data and information that the User provides, provided that it does so in accordance with the provisions of this Protocol on Policies for the Use, Processing, Access to Information, and Protection of Data and the related regulations of the Republic of Panama.
  3. S.A.: Refers to the corporation organized in accordance with the laws of the Republic of Panama with qualified personnel.
  4. Personal Data: Information concerning natural persons that identifies them or makes them identifiable.
  5. Sensitive data: Data that refers to the private sphere of its owner, or whose improper use may give rise to discrimination or entail a serious risk to the owner. By way of example, personal data that may reveal aspects such as racial or ethnic origin; religious, philosophical, immoral beliefs or convictions; trade union membership; political opinions; data relating to health, life, sexual preference or orientation, genetic data, or biometric data, among others, subject to regulation and intended to uniquely identify a natural person, are considered sensitive.
  6. Data Processing: Any technical operation or procedure that allows EFFLUZ S.A. or companies within the same economic group to collect, store, record, organize, prepare, select, extract, compare, interconnect, associate, disassociate, communicate, assign, exchange, transfer, transmit, or delete User data, or use it in any other manner.
  7. User: Client/person who uses the services of EFFLUZ S.A. or provides it with their data.

What Information We Collect

We obtain two types of information through our digital channels: Non-Personal Data and Personal Data.

The Non-Personal Data obtained includes: the type of browser used by the visitor, device type, and operating system; area(s) of the digital channels visited; date and time of access; server provider or Internet Service Provider, or ISP; and the identity of the originating website—the site from which the visitor accessed the Online Services; IP Address; media information—for example, advertising engagement on social, digital, and broadcast media; the manner in which the user uses our digital channels and mobile applications, search terms, pages of our mobile applications that you visit, and application performance; and the location of the mobile device, provided that the user’s device settings have authorized it.

We also obtain Personal Data that may identify the visitor, user, or patient, including, but not limited to, name, address, and other contact information, policy information, claim information—including materials submitted as part of the claim—customer service requests, information provided for roadside assistance services, or other information that you choose to provide to us, but only when you provide it voluntarily. If you submit a job application or enroll in the Career Center, we may obtain personal information about your employment and academic background. Likewise, certain online services may obtain precise information about the location of the mobile device, but only with your express consent. Once you have given your consent to obtain the precise location of the mobile device, you may adjust this consent through the management of location service preferences in the mobile device settings.

How Do We Obtain Personal Data Through This Website and Its Apps?

  1. We collect information that you enter into our digital channels and/or at our clinic through applications and other forms or documents, such as your name, address, personal identification or ID card number, income, and beneficiaries.
  2. Information provided by third parties authorized by the user: the Human Resources Department of your company, insurance brokers, and medical personnel.
  3. Automated information collection: We may link information collected automatically with information in our database in order to identify you as a unique user of EFFLUZ S.A., whether online, at the clinic, through a mobile device, etc.
  4. Automated information collection by third parties: We and our service providers use anonymous identifiers, such as cookies and other technologies, to collect and store certain types of information.
  5. Social media widgets: Our websites and mobile applications have social media-related features, such as widgets. These features may collect information about you, such as your IP address and the page you are visiting on our website. They may install a cookie or use other tracking technologies to accomplish this. Social media features and widgets may be hosted by third parties. Your interactions with those features are governed by the privacy policies of the companies that provide them.
  6. Mobile device location information: If you use a mobile device, your device may share information about its location—when location services are activated—with our websites, mobile applications, services, or other service providers.

Servers, Storage, and Transmission of Information

Your data is stored for the purposes established in this document or in other documents that you sign with our company and affiliates.

All direct payment gateways adhere to the standards established by PayPal and Paguelo Fácil.

Third-Party Services

The third-party providers we use will only collect, use, and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies regarding the information that we are required to provide to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so that you can understand how these providers handle your personal information. In particular, remember that certain providers may be located or have facilities located in jurisdictions different from yours or ours. Therefore, if you decide to proceed with a transaction involving the services of a third-party service provider, your information may then be subject to the laws of the jurisdiction or jurisdictions in which the service provider or its facilities are located.

Once you leave our website and are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or by our website’s Terms of Service.

Information We Share

We will only disclose your personal and sensitive information in the cases and manner provided for by Panamanian data protection law and related regulations. Notwithstanding the foregoing, by providing us with your personal and/or sensitive data.

You may authorize us through a written document to share data if necessary.

How Do We Use Your Information?

We use the information obtained through digital channels for various purposes, including:

  • to offer, contract, renew, and modify products and services;
  • to process payments, prepare credit documentation requested by the user, and evaluate their creditworthiness;
  • to provide requested information and documents and for other purposes related to customer service;
  • to process claims;
  • to enforce our contractual rights;
  • to provide information about services or required notifications, whether physical or digital;
  • to send marketing communications or promotional materials that may be of interest and to help us determine relevant advertising;
  • to administer promotions that we may offer, surveys and analysis groups, interest-based advertising, as well as to conduct research and analysis;
  • to improve the services provided and the usefulness of the digital channels;
  • to personalize your experience when using our digital channels;
  • to comply with applicable laws;
  • to conduct investigations and email due diligence processes;
  • to prevent and detect fraud, violations, and other possible improper uses; and
  • for any other activity authorized by the user in writing.

In addition, we may anonymize, combine, or join information obtained through digital channels or otherwise for any of the purposes mentioned above or to analyze the use of statistics and trends.

The personal information provided by you will not be sold, licensed, transmitted, or disclosed outside EFFLUZ S.A. unless: (1) you expressly authorize such actions; (2) it is necessary for our contractors or agents to provide services to you; (3) it is necessary to provide our products or services to you; (4) it is disclosed to entities that provide marketing services on our behalf or to entities with which we have entered into joint marketing agreements; (5) in connection with a merger, consolidation, acquisition, divestiture, or other corporate restructuring involving all or part of our business; or (6) it is otherwise required or permitted by law.

Age of Consent and Accuracy of Data

By using this website, you declare that you are at least the age of majority in the Republic of Panama and have given us your consent for the use of your personal data. You also declare that the data provided is true, and otherwise, this will be sufficient reason to refuse to provide you with any service or to terminate such services early and without any penalty whatsoever for EFFLUZ S.A.

Policy Regarding Information About Former Clients

EFFLUZ S.A. may share information about its former clients in the same manner as it does regarding its current clients. Information about former clients is retained for the period required by local laws and regulations governing the insurance industry.

Security Measures

EFFLUZ S.A. limits access to your personal information solely to those employees who need it in order to provide you with services and products. In addition to the foregoing, we maintain the necessary physical and electronic security measures to safeguard the confidentiality of your information, as required by law and our Privacy Policy.

Security in Internet Communications

The Internet is not a secure medium. We implement administrative, technical, and physical security safeguards designed to protect personal information. When you enter sensitive information, such as a credit card number, on our websites, we encrypt the information using SSL technology or similar technology during transmission to our website. Unfortunately, the security of no method of transmission or data storage can be guaranteed, and we assume no liability whatsoever for damages or losses caused by the transmission of information to or from EFFLUZ through the Internet. If you believe that the security of an account you have with us has been compromised, please contact us through one of the methods described below.

We restrict access to personal information obtained about you on our websites to our employees, the employees of our affiliates, or other persons who may need that information to provide services or in the ordinary course of business operations.

Sensitive Data

Sensitive data to which EFFLUZ S.A. has access will not be transferred except in the following cases:

  1. When the user has granted authorization, except in cases where the granting of such authorization is not required by law.
  2. When necessary to safeguard the life of the user and the user is physically or legally incapacitated. In these cases, the guardians or those who have legal guardianship over the user must grant authorization to transfer such information.
  3. When it concerns data necessary for the recognition, exercise, or defense of a right in legal proceedings with authorization from the competent judicial authority.
  4. For historical, statistical, or scientific purposes. In these cases, EFFLUZ S.A. will disassociate the identity of the user.
  5. Any other reason permitted by legal regulations.

How Do You Give Us Your Consent?

When you provide us with personal, confidential, and/or sensitive data, it is because you agree that we may collect and use it for the reasons established in this document or in the documents that you sign with EFFLUZ S.A. For our part, we commit to only requesting the information we require in accordance with what is authorized by the user in this Privacy Policy, Processing, Access to Information, and Data Protection Policy and the related regulations of the Republic of Panama.

Changes to the Privacy Policy

EFFLUZ S.A. reserves the right to modify or amend this Privacy Policy.

Any modification or change to this Privacy Policy will become effective immediately once published. Continued use of our website after a revised version of this Privacy Policy has been published will constitute acceptance of the revised Policy.

The information contained in this Privacy Statement for our digital channels must not be used by any person or in any country or jurisdiction where such use would constitute a violation of the law. If this applies to you, you will not be authorized to access or use any information contained on this website. By using the digital channels of EFFLUZ S.A. or any digital channel of companies within the same economic group—unless the specific website contains a provision to the contrary—you agree to be bound by the terms of this Website Privacy Statement and our Terms of Use. Please periodically review the terms of this Website Privacy Statement, as we reserve the right to modify or amend the Privacy Statement or our Terms of Use at any time.

How We Use “Cookies” and Other Data Collection Tools

Cookies. EFFLUZ may use electronic “cookies” in the browser files of the computer or mobile device when you access the EFFLUZ website. Cookies are data that the EFFLUZ website transfers to your computer or mobile device so that our systems recognize your browser and personalize the information included on our websites according to your interests. For example, if you previously visited an EFFLUZ website and accessed your account information or inquired about a particular service on it, cookies allow us to present information personalized to your account and/or particular interests the next time you visit the website. In addition, EFFLUZ or a third-party service provider or business partner may use cookies on your computer or mobile device that may be combined with other personal information that we hold about you to pre-fill certain online forms for your convenience. We also use cookies to analyze visitors’ use of our websites. Based on this analysis, we better understand which areas of our websites are most useful and popular so that we can plan improvements and updates. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to obtain or receive information from EFFLUZ websites and applications and other places on the Internet, and use this information to provide market research services and identify advertisements for you.

Why Are Cookies Important for the Use of EFFLUZ Websites?

We use cookies to improve the functionality of the website and to identify information about how the website is used in order to continuously improve it and personalize it based on the user’s preferences. In particular:

Cookies allow us to provide an individually personalized use of the websites. Some functions of our websites cannot be used without cookies, such as registering or changing settings. Cookies must be enabled for optimal use of the website.

We cannot track the number of visitors to our website without cookies. Without this information, the risks related to security and fraud on the website increase, something we wish to avoid.

Cookies allow us to verify how users access and navigate the website. This is very important for improving the website and making it easier to use.

It is important to clarify that cookies can only read the identification number randomly created by the generator on your computer and can only retrieve information that is directly related to the EFFLUZ website.

Types of Cookies

Cookies may be “persistent” or “session” cookies. This website uses both persistent and session cookies.

A persistent cookie consists of a text file sent by a server to a browser, which allows us to obtain and analyze—anonymously—information about website traffic and use, monitor the system, and improve operational performance, such as by saving preferences to improve subsequent visits. It is not automatically deleted when the browser is closed; instead, it remains stored and will remain valid until the established expiration date—unless it is deleted by the user before the expiration date.

A session cookie is essential to ensure the proper functioning of the website and is used to manage registration/login and access to restricted functions. It is stored temporarily during a browsing session and expires at the end of the user’s session when the browser is closed.

It is also important to consider that some cookies—which are generally session cookies—are what we call strictly necessary. Strictly necessary cookies allow you to navigate the website and use functions that have been explicitly requested. Other types of cookies may be disabled while strictly necessary cookies remain enabled—see “Your Cookie Choices” below.

Clear GIFs, pixel tags, and other technologies. In addition to cookies, we may also use other means to passively obtain data that is not personally identifiable regarding the use of our websites, such as “clear GIFs”—small information files that may be embedded in images on the website and allow us to track the use of our websites—and to analyze “clickstream” data—the virtual trail left when browsing the Internet and viewing our websites. We use clear GIFs and clickstream data to obtain information about visits to our websites and, in connection with emails, to track response rates. The data may include device information, such as the IP address, but does not identify the user by name. Blocking cookies prevents clear GIFs from tracking activity and also prevents us from obtaining certain information, such as the IP address, but we may still have a record of the visit. In addition to information obtained from cookies, clear GIFs, through the analysis of clickstream data, and other means that we may use to obtain non-personally identifiable information about you and your visits to our websites, we may also obtain anonymous information that you provide to us online, for example, when using our tools and calculators.

Your Cookie Choices

You may enable and disable cookies by adjusting your browser settings. In this manner, you may reject the use of cookies—except for strictly necessary cookies. You may also delete cookies that have already been placed on the device.

It is important to remember that disabling or deleting some or all cookies may affect the proper functioning of certain online services—including this website—preventing the browsing experience from being trouble-free and more personalized.

Third-party analytics tools. We use automated tools and applications, such as Google Analytics, to evaluate the use of our Online Services. We also use other analytics tools to evaluate our Online Services. We use these tools to improve our services, performance, and user experiences. These entities may use cookies and other tracking technologies to provide their services. We do not share your name or contact information with these analytics service providers, although they may obtain unique device identifiers or the IP address.

Third-party advertising networks. We use third parties as digital advertising providers to place advertisements on third-party websites or other media—for example, social media platforms. This allows us and third parties to identify advertisements for products and services that may be of interest to you. Digital advertising providers, advertisers, sponsors, and/or traffic measurement tools use cookies, JavaScript, web beacons—including clear GIFs—Flash LSOs, and other tracking technologies to measure the effectiveness of their advertisements and personalize advertising content. These third-party cookies and other technologies are governed by the specific privacy policy of each third party, not by this policy. We may provide these advertising third parties with information about you.

Right of Access, Rectification, Cancellation, and Opposition

If you wish for your personal information to continue being shared with non-affiliated companies, you do not need to return this document.

We appreciate your trust in all our insurance products and services.

If you wish to know the personal data that we store about you, its origin, and the purpose for which it was collected, complete the Request included below with the subject line “Access.”

If you wish to delete the data we store about you because it is incorrect, erroneous, or outdated, complete the Request included below with the subject line “Cancellation.”

If you wish to correct the data we store about you because it is incorrect, erroneous, or outdated, complete the Request included below with the subject line “Rectification.”

If you do not wish for your personal information to be shared, for example, among non-affiliated companies, complete the Request included below with the subject line “Opposition.”

Consent

By using the Online Services, you consent to this Online Privacy Policy and the website’s Terms of Use. If you do not agree with this policy or with the website’s Terms of Use, please do not use the Online Services. The Online Services may not be used within any country or jurisdiction, or by any person, where such use constitutes a violation of the law. If this applies to you, you are not authorized to access or use any of the Online Services.