Bupa Insurance Company Privacy Notice

Effective Date: November 15th 2020

Welcome

We are committed to protecting your privacy when dealing with personal information we process. This privacy notice (“Privacy Notice”) describes the commitment by Bupa Insurance Company and its subsidiaries, affiliates, and related group of companies in Latin America (see Annex 1 below for a listing of the names and domiciles of the companies who act as data controllers in each Country - collectively “Bupa” “we” or “our”) to your privacy. Bupa respects your privacy. By accessing and using this Site, you agree that you have read and understand this Privacy Notice and our Terms of Use, and that you accept and consent to our privacy practices and any uses and disclosures of your Personal Information for the primary purposes that are described in this document.

Depending on which of our products and services you ask us about, buy or use, different companies within our organization may process your information.

Please read this Privacy Notice carefully so you can make an informed decision about your use of this Site and other Bupa products and services. If you have questions or comments relating to Bupa or this notice, please see the “Questions and Comments” section below.

HIPAA Notice of Privacy Practices: To read more about our privacy practices specifically regarding health and medical information under the Health Insurance Portability and Accountability Act (“HIPAA”), please visit our HIPAA Notice of Privacy Practices.

 

Scope of our Privacy Notice

This privacy notice applies to anyone who interacts with us in relation to our products and services (“you”) in any way (for example, through our websites, mobile apps, live chat features, email, phone, or purchase of our products). For the purpose of this Privacy Notice, “Personal Information” means any information relating to an identified or identifiable individual. We may obtain Personal Information relating to you in the situations described below in this document. This Privacy Notice provides details about the Personal Information that we collect about you, the purposes for which we collect that Personal Information, the other parties with whom we may share it, how we use it and how we protect it. It also provides information about your rights as an individual in relation to the Personal Information that Bupa collects from you, and how you can contact us about our privacy practices.

We may also provide you with further information and/or privacy notices as necessary, depending on the way we interact with you and the products and services Bupa provides to you. These may also apply to you, for example when you consent to them or where they apply to any Bupa products and services you use.

 

How we Collect Personal Information

We collect Personal Information from you and from third parties (anyone acting on your behalf, for example, agents/brokers, health-care providers and so on). 

Where you provide us with Personal Information about other people, you must make sure that they have seen a copy of this privacy notice and are also in agreement with you giving us their Personal Information. 

Bupa will collect and process Personal Information in compliance with applicable laws, and in line with data protection principles as set out in this notice.

Without limitation, we collect Personal Information from you:

• through your contact with us, including by phone (we may record or monitor phone calls to make sure we are keeping to legal rules, codes of practice and internal policies, and for quality assurance purposes), by email, through use of our websites or apps, by post mail, by filling in application or other forms relating to our products and services, by entering competitions, or through your contact and interaction with us on social media, through face-to-face (for example, in health services interactions, diagnosis and treatment), and through surveys we send you.

We also collect information from other people and organizations. Without limitation and in compliance with applicable laws and regulations, for all our customers, we may collect information from:

• your parent or guardian, if you are under 18 years old;
• a family member, or someone else acting on your behalf;
• doctors, other clinicians and health-care professionals, hospitals, clinics and other health-care providers;  
• any service providers who work with us in relation to your product or service, if we don’t provide it to you directly, such as providing you with apps, medical treatment, dental treatment or health assessments;
• organizations who carry out customer-satisfaction surveys or market research on our behalf, or who provide us with statistics and other information (for example, about your interests, purchases and type of household) to help us to improve our products and services;
• fraud-detection, background screening and credit-reference agencies; and
• information sources which are available to the public.

If we provide you with insurance products and services, we may collect information from:

• the main member, if you are a dependent under a family insurance policy;
• your employer, if you are covered by an insurance policy your employer has taken out;
• brokers and other agents (this may be your broker if you have one, or your employer's broker if they have one); and
• other third parties we work with, such as agents working on our behalf, other insurers and reinsurers, actuaries, auditors, solicitors/counsel, translators and interpreters, tax advisers, debt-collection agencies, credit-reference agencies, fraud-detection agencies (including health-insurance counter-fraud groups), regulators, data-protection supervisory authorities, health-care professionals, other health-care providers and medical-assistance providers.

If we provide you with health-care related services, we may collect Personal Information from:

• your employer, if you are covered by a contract for services your employer has taken out or if we are providing occupational health services;
• brokers and other agents (this may be your broker if you have one, or your employer's broker if they have one); and
• those paying for the products or services we provide to you, including among others insurers and embassies.

 

Categories of Personal Information we Collect

We process a number of categories of Personal Information about you and (where this applies) your dependents, and may collect, without limitation, the following categories of data:

• contact information, such as name, username, address, email address and phone numbers;
• yours and your family members’ or other insured’s nationality, residency, age, date of birth, government issued ID numbers such as a national ID number or a passport number, your marital status, sex, height, weight, signature;
• data relating to lifestyle, such as frequency of travel, times when you are most likely to need insurance coverage, or other products you may have purchased in the past from Bupa or other companies;
• information about your employment;
• details of any contact we have had with you, such as any complaints or incidents;
• financial details, such as details about your credit card, payments, and bank details such as account numbers and billing addresses;
• the results of any credit or any anti-fraud checks we have made on you;
• information about how you use our products and services, such as insurance claims;
• information about how you use our website, our apps or other technology, including IP addresses or other device information (please see the below Cookie Policy for more details).

Some of these categories of information may be defined as “sensitive” under differing applicable laws and regulations and might then require special protections. Such sensitive Personal Information you provide us with will be collected only with our having a legal basis to do so, such as (for example) your consent. Such Personal Information will be safeguarded under strict administrative, technical and physical security measures, taking care of the integrity and availability of said data and avoiding its damage, loss, alteration, destruction or unauthorized use. Personal Information collected about you will be handled only by authorized personnel and in compliance with applicable laws and regulations to ensure it is appropriately safeguarded and not inappropriately disclosed.

Sensitive Personal Information that we may process includes:

• information about your physical or mental health, including genetic information or biometric information (we may get this information from application forms you have filled in, from notes and reports about your health and any treatment and care you have received or need, or it may be recorded in details of contact we have had with you such as information about complaints or incidents, and referrals from your existing insurance provider, quotes and records of medical services you have received), birth of family members, pregnancies or adoptions;
• information about your race, ethnic origin and religion (we may get this information from your medical preferences to allow us to provide care that is tailored to your needs); and
• information about any criminal convictions and offences (we may get this information when carrying out anti-fraud or anti-money-laundering checks, or other background screening activity).

 

Collection of Personal Information from Children Under 13

This Site is not designed or intended to attract children 13 years of age.

Bupa is committed to complying, among others with the U.S. Children’s Online Privacy Protection Act. 

We collect information about children under the age of 13 only with consent from the child’s parent or legal guardian. 

We do not collect any Personal Information directly from any person if we know that such a person is a child under the age of 13. 

By accessing this site, you represent that you are 13 years of age or older. If you believe we have collected Personal Information from a child under the age of 13 without consent, please contact us at privacyoffice@bupalatinamerica.com or at the contact details below.

 

What we use Personal Information for

We may process your Personal Information for the purposes set out in this privacy notice. We have also set out some legal reasons why we may process your Personal Information (these also depend on what category of Personal Information we are processing). We normally process Personal Information if this is necessary to provide the services set out in a contract, it is in our or a third party’s legitimate interests or it is required or allowed by any law that applies. Where required by applicable law, we must have a lawful reason for processing your Personal Information. 

We process Personal Information about you for the following “primary” purposes if this is:

• necessary to provide the services set out in a contract − if we have a contract with you, we will process your Personal Information in order to fulfil that contract (that is, to provide you and your dependents or covered employees with our products and services) and to provide you with information about the benefits of your Bupa insurance policy;
• necessary for the evaluation of your insurance application, premium quote and risk selection. The underwriting process of Bupa may use automated decision making to determine insurance policy coverage such as deductibles, inclusions and exclusions, and may also use automated decision making to determine premium rates based on information collected from you;
• necessary for the management of benefits and/or coverage contained in your insurance contract with medical providers, and for the processing of claims intended for the payment of claims and reimbursements;
• in our (or a third party’s) legitimate interest. Details of those legitimate interests are set out in the section below and include, as primary purposes of processing, hiring job applicants and processing job applications;
• required or allowed by law;
• necessary for addressing complaints and queries.
• necessary for the purposes of provision of health care, medical diagnosis, to provide treatment, and/or to help manage healthcare or social-care systems (including to monitor whether we are meeting expectations relating to our clinical and non-clinical performance);
• necessary for an insurance purpose (for example, advising on, informing of changes to, arranging, providing or managing an insurance contract, dealing with a claim made under an insurance contract, contracting and collection from reinsurers, or relating to rights and responsibilities arising in connection with an insurance contract or law);
• necessary to establish, make or defend legal claims (for example, claims against us for insurance);
• necessary for the purposes of preventing or detecting an unlawful act in circumstances where we must carry out checks without your permission so as not to affect the outcome of those checks (for example, anti-fraud and/or anti-money-laundering checks or to check other unlawful behavior, or to carry out investigations with other insurers and third parties for the purpose of detecting fraud);
• necessary for a purpose designed to protect the public against dishonesty, malpractice or other seriously improper behavior (for example, investigations in response to a safeguarding concern, a member's complaint or a regulator telling us about an issue);
• in the public interest, in line with any applicable laws;
• information that you have made public; or
• with your permission. As is best practice, we will only ask you for permission to process your Personal Information if there is no other legal reason to process it. If we need to ask for your permission, we will make it clear that this is what we are asking for, and we will ask you to confirm your choice to give us that permission. If we cannot provide a product or service without your permission, then we will make this clear when we ask for your permission. If you later withdraw your permission, we may no longer be able to provide you with a product or service that relies on having your permission.

In order to improve the services provided by Bupa, particularly in reference to the design of new products, the quality of existing products, and for the continuous improvement of Bupa’s services, Personal Information may be used for the following "secondary” purposes: 

• developing new ranges of products and services, including benefits, discounts or market studies, which may involve: a) the processing anonymized or deidentified data in our statistical databases; b) the preparation of statistical profiles based on subjects with similar characteristics; and/or c) the analysis of these statistical profiles, and measurement of the reliability of the statistical profiles created;
• supporting research to improve our products, services and operations, including, for example, research in relation to our product pricing. As part of this research we use anonymized information (with all names and other identifying information removed) including aggregated information (combining your de-identified information with that of other individuals) for research or statistical purposes. You cannot be identified from this information and we will only share the information with third parties where we have a legal basis to do so and in line with applicable laws and regulations.
• to contact you in relation to a market research that we are carrying out;
• to monitor how well we are meeting our clinical and non-clinical performance expectations in the case of health-care providers.

If you do not want your Personal Information to be used for secondary purposes as stated above, please contact us at privacyoffice@bupalatinamerica.com, or alternatively at the contact details that are provided below.

 

Legitimate Interests

Taking into account the applicable laws as well as your individual interests, rights and freedoms, we may process your Personal Information for a number of legitimate interests (among other legal reasons for processing your Personal Information, such as to fulfil a contractual obligation to you). These legitimate interests which allow us to process your Personal Information may include and not be limited to:

• to manage our relationship with you, our business and third parties who provide products or services for us (for example, to check that you have received a service that you’re covered for, to validate invoices and so on);
• to provide health-care services on behalf of a third party (for example, your employer);
• to make sure that claims are handled efficiently and to investigate complaints (for example, we may ask your treatment provider for information to make sure we receive accurate information and to monitor the quality of your treatment and care);
• to keep our records up to date and to provide you with marketing as allowed by law; 
• to develop and carry out marketing activities and to show you information that may be of interest to you, based on our understanding of your preferences (we combine information you give us with information we legally receive about you from third parties to help us understand you better); 
• for statistical research and analysis so that we can monitor and improve products, services, websites and apps, or develop new ones;
• to enforce or apply our Site’s Terms of Use, our policy terms and conditions or other contracts, or to protect our (or our customers’ or other people’s) rights, property or safety;
• to exercise our rights, to defend ourselves from claims and to keep to laws and regulations that apply to us and the third parties we work with; and
• to take part in, or be the subject of, any sale, purchase, merger or takeover of all or part of the Bupa business.

 

Marketing and Preferences

We may use your Personal Information to send you marketing communications through various channels (such as by post mail, by phone, through social media, by email or by text), however we only use your Personal Information to send you marketing communications material if we have your permission or a legitimate interest as described above. 

You have the right to object to direct marketing and profiling (the automated processing of your information to help us evaluate certain things about you, for example, your personal preferences and your interests) relating to direct marketing. You may exercise this right by for example opting-out by clicking on the ‘unsubscribe’ links that appear in emails that we send or by contacting us at privacyoffice@bupalatinamerica.com. Please consult the “Your Rights and Options” section which appears below in this Privacy Notice.

Depending on the applicable law to you, we may have to tell you about:

• automated decision-making (making a decision by using technology, without any person being involved); and
• our profiling activities (automated processing of your information to help us to learn and evaluate certain things about you, for example, what are your personal preferences and your interests).

This is because the law that is applicable to you may provide that you have certain rights relating to both automated decision-making and profiling. You have the right to object to profiling on you relating to our direct marketing. If you do this, we will no longer carry out profiling for direct marketing purposes with respect to you. You also have the right to object to profiling in other circumstances set out below.

When we make decisions using only automated processing which produce legal effects which concern you or which have a significant effect on you, we will let you know. You then have 21 days to ask us to reconsider our decision or to make a new decision that is not based only on automated processing. If we receive a request from you, within 21 days of receiving our notice, we will: 

• consider the request, including any information you have provided that is relevant to it;
• meet your request; and
• let you know in writing what we have done to meet your request, and the outcome.

 

Profiling and automated decision-making

The processes set out below involve both profiling and automated decision-making:

• Depending on the type of health-insurance product that you want to benefit from, to help us decide what level of cover we can offer you, we may ask you to provide information about your medical history. We may use software to review this information to find out whether you have any previous or existing health conditions which we cannot cover you for and which will be excluded from your insurance policy. 
• We may use software to help us calculate the price of products and services based on what we know about you and other customers. For example, our technology may analyze information about your claims history and compare it with the information we hold about previous claims to evaluate how likely you are to need to make a claim. We may also evaluate your age, where you live and other details relating to your health (such as existing health conditions and whether you smoke) to calculate prices for community-rated products which are based on predefined groups with similar risk profiles.

 

Profiling

The processes set out below may involve profiling.

• In order to improve outcomes and be more efficient, and allow us to offer advice about different treatment paths (for example, alternatives to surgery or other invasive treatments), we may use software to evaluate medical history and information about the general population in an area to identify customers who are likely to need that advice most. 
• When your policy is due for renewal, our software tells us this and may also evaluate your payment and claims history, information about the general information in a particular area, and other information from third parties to automatically provide you with information about what incentives we can offer you and the marketing messages you will receive. 
• We may ask other organizations to carry out some of our consumer and market analysis to improve our marketing processes. This may involve sharing Personal Information relating to our customers with third parties who specialize in profiling and segmenting people (putting people into groups of different types of customer, based on different kinds of information collected about them, to help us to better target our products to them). These companies match the information we give them with information they get from other sources to improve the accuracy of their analysis. We use the results of this analysis to help us target our marketing and offers. 
• We may use information about the products you have bought, and information about what other customers who have bought the same products you have bought, to make sure we send you information about the products you are most likely to be interested in. 
• We may share your Personal Information (including your name, date of birth, sex and the country you live in) with third-party companies that we use to carry out anti-fraud checks. We will review any matches from this process. (We will not use automated decision-making for this.)

 

Sharing your Information

We share your information within the Bupa Group, with relevant policyholders (including your employer if you are covered under a group scheme), with funders arranging services on your behalf, with people acting on your behalf (for example, brokers and other agents) and with others who help us provide services to you (for example, health-care providers and medical-assistance providers) or who we need information from to allow us to handle or confirm claims or entitlements (for example, professional associations). We also share your information in line with the law. 

We sometimes need to share your information with other people or organizations for the purposes set out in this privacy notice.

We may share your Personal Information with:

• other members of the Bupa Group;
• other organizations you belong to, or are professionally associated with, in order to confirm your entitlement to claim discounts on our products and services;
• doctors, clinicians and other health-care professionals, hospitals, clinics and other health-care providers;
• suppliers, third parties and commercial partners who help to deliver our products, services or marketing (such as insurance agents, or companies providing the technology and logging for the live chat features of our websites);
• people or organizations we must share or are allowed to share your Personal Information with by law (for example, for fraud-prevention or safeguarding purposes);
• the police and other law-enforcement agencies to help them perform their duties, or with others if we must do this by law or under a court order;
• if we (or any member of the Bupa group) sell or buy any business or assets, the potential buyer or seller of that business or those assets; and
• a third party who takes over any or all of the Bupa Group’s assets (in which case Personal Information we hold about our customers or visitors to the Site may be one of the assets the third party takes over).

If we provide you insurance, we share your information with:

• the policyholder or their agent if you are not the main member under an individual policy (we will send them all membership documents and confirmation of how we have dealt with a claim, and all people who are insured on the policy may have access to correspondence and other information we provide through our online portal);
• your employer (or their broker or agent) for product or service administration purposes if you are a member or beneficiary under your employer’s group scheme;
• your broker or agent (or both);
• other third parties we work with to provide our products and services, such as agents working on our behalf, other insurers and reinsurers, actuaries, auditors, solicitors, translators and interpreters, tax advisers, debt-collection agencies, credit-reference agencies, fraud-detection agencies (including health-insurance counter-fraud groups), regulators, data-protection supervisory authorities, health-care professionals, health-care providers and medical-assistance providers; and;
• organizations who provide your treatment and other benefits, including travel-assistance services.
• If we share your Personal Information, we will make sure appropriate protection is in place to protect your Personal Information in line with data-protection laws.

In case that we provide you healthcare services, then we may share your information with:

• your employer, if your employer is paying for the services we are providing;
• our insurance partners, for example, brokers, reinsurers, actuaries, auditors, solicitors, translators and interpreters, tax advisers, debt-collection agencies, credit-reference agencies, fraud-detection agencies, regulators, data-protection supervisory authorities;
• those paying for the products or services we provide to you, including insurers, public-sector entities and embassies;
• those providing your treatment and other benefits; 
• where required by applicable law, with national registries; 
• where required by applicable law, with national screening databases;
• government authorities and agencies; and, 
• organizations that carry out patient surveys on our behalf.

If we share your Personal Information, we will make sure appropriate protection is in place to protect your Personal Information in line with data-protection laws.

 

Linked Sites

For your convenience, this Site may contain links to websites that are not operated by or affiliated with Bupa, including social media sites. These third-party websites are not under our control. We are not responsible for, and this Privacy Notice does not apply to, the privacy or security practices of those sites or of any companies that we do not own or control. Any information you disclose once you access these other web sites is not subject to this Privacy Notice. We encourage you to seek out and read the privacy notice of each website that you visit to understand how information about you is collected, used, and protected on those websites and by those third-party companies. Please see our Terms of Use for additional details on linked sites.

 

Your Rights and Choices

You may have a right of access with respect to the Personal Information of you that may be stored by Bupa. You may also have the right: to correct and/or update your Personal Information, to oppose to its processing or usage and to request the deletion of your Personal Information. To exercise any of such rights you need to request this to Bupa in writing via email to: Privacyoffice@bupalatinamerica.com.   

In the event that we receive a request from you asking for the deletion of your Personal Information, we will respond to your request and subject to the applicable laws we will have such Personal Information cancelled so that this is either deleted/destroyed, or we may convert your personal data into anonymous information in our database, so that any record or reference that is identifiable with respect to you is eliminated.

The procedure for the exercise of rights for the protection of your Personal Information before Bupa requires that such request is always submitted in writing, and must in addition contain and/or attach the following information:

1. The full name of the owner/owner of the personal data and his/her email address and other means of contact that may allow us to communicate/give our response to the request received;
2. The country/jurisdiction that is the place of permanent residence of the data owner whose Personal Information is object of the request;
3. A copy of documents proving the identity of the requester who is the data subject of the Personal information that is object of request, o when appropriate, the legal basis on which a requester acts on behalf of a customer, policy holder or beneficiary; and
4. The name of the personal data protection rights that you request to exercise, including a clear and precise description of the Personal Information with respect to which the exercise of rights is requested.

The requester will be in all cases required by Bupa to provide documented proof of its identity as the data owner of the Personal Information that is object of request, and when applicable, proof of the requester’s status to validly act on behalf of the data subject who owns the Personal Information. 

Bupa will notify you of our decision regarding your request, within the time limit set out in the applicable legislation.

 

Consent to Processing in the United States and Internationally 

Bupa is a global business. In order to provide you with the services and functionality that is available through this Site, and to allow us to process your Personal Information in line with the purposes set out in this Privacy Notice, we may send and store the Personal Information you provide us with to locations that are outside of the country where you reside, or outside from location from where you may access this Site. 

We may transfer Personal Information we collect about you to recipients in countries other than your country of residence, including the United States of America where Bupa Insurance Company is headquartered. These countries may not have the same data protection laws as the country in which you initially provided the information, When we transfer your Personal Information to other countries we will protect that information: as described in this Privacy Notice; as disclosed at the time of data collection; and when applicable as described on a product or service specific privacy notice that we may provide.

We are committed to protecting the privacy and security of Personal Information when it is transferred. Where such transfers occur, we take appropriate steps to make sure that, when we transfer Personal Information to another country, appropriate protection and security is in place, in line with the applicable data-protection laws. Often, this protection is set out under a contract executed by Bupa with the organization who receives that Personal Information.

We comply with applicable legal requirements providing adequate safeguards for the transfer of Personal Information to countries other than the country where you are located. When applicable, we may also transfer Personal Information: a) to countries for which adequacy decisions have been issued; b) use contractual protections for the transfer of Personal Information to third parties; or, c) rely on third parties’ relevant certifications obtained by the recipients of the Personal Information.

 

Protection of Personal Information

Because Bupa respects your privacy, and values your trust, the only persons to whom we give access to your Personal information are those who we need to use it to provide our products and/or services to you, or to conduct other activities which are described in this Privacy Notice.

We use technical, administrative and physical safeguards to protect the confidentiality, integrity, security and availability of your Personal Information. These safeguards are periodically reviewed, tested, and designed to protect your Personal Information from unauthorized access, disclosure, use and modification.

However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information that you provide us with. We cannot and do not guarantee that communications to or from this Site, or that data transmitted or stored on or through the Site, are or will be totally secure from loss, misuse or unauthorized access by third parties.

 

How long we keep your Personal Information for

We keep your Personal Information in line with set periods calculated using the following criteria:

• How long you have been a customer with us, the types of products or services you have with us, and when you will stop being our customer.
• How long it is reasonable to keep records to show we have met the obligations we have to you and/or by law.
• Any time limits that are applicable for making a claim.
• Any periods for keeping information which are set by applicable law or recommended by regulators, professional bodies or associations.
• Any relevant proceedings that apply.

 

Cookie Policy

A cookie, also known as a browser cookie, is a text file containing small amounts of information which a server may download to your computer, mobile or tablet when you visit a website or use an app. Sites that you visit may ask your browser to store cookies on your computer or mobile device. Cookies allow a site to “remember” your actions or preferences over time. So, when you visit our site, the cookies may be dropped to store or retrieve information on your browser, information which may be about the user’s preference and/or the device used. Cookies reside on your device and allow us to recognize if a user returns to visit our Site from the same device and through the same browser, however Bupa cannot identify you from the data that our cookies collect as we only collect anonymous user preferences and website behavior information to be used for marketing purposes. 

There are different types of cookies which are used to do different things, such as letting you navigate between different pages on a website efficiently, remembering preferences you have given and helping us to identify ways to improve your overall Site experience. Others are used to provide you with advertising which is more tailored to your interests or to measure the number of site visits and the most popular pages users visit.

Cookies can be categorized either as first-party or third-party cookies. Our websites use both types of cookies:

• First party cookies: First-party cookies are set directly by us, from the domain name of the site displayed in the URL window. 
• Third party cookies: Third party cookies are those cookies that are set by a domain name other than the one being visited by the user. For example, if we set a cookie on www.Bupasalud.com/en using a cookie from another domain name that we own or control, that cookie is a “third party” cookie. Similarly, we may also permit our service providers or partners to set cookies directly on our website from their own domain name; these, too, are third party cookies.

Due to their core role of enhancing and enabling usability or site processes, disabling certain cookies may prevent you from using certain aspects of a Bupa website, such as for example generating a quote or placing an order. 

Broadly speaking, there are two different types of browser cookies which may be used by our sites:

• Session cookies: allow a website to remember your actions during a browsing session and expire once you close your web browser. These cookies are stored in the computer's memory during a user's browsing session and are automatically deleted from the user's computer when the browser is closed, or the session is deemed to have ended. These cookies usually store a session ID that is not personally identifiable to users, allowing the user to move from page to page without having to log-in repeatedly. They are widely used by commercial websites, for example to keep track of items that a consumer has added to a shopping basket. Session cookies do not collect any information from the user's device, and they expire at the end of the user's browser session. They can also become inaccessible after the session has been inactive for a specified length of time, usually 20 or 30 minutes. Session cookies may be used for a variety of purposes, including remembering that you logged in to one of our websites.
• Persistent cookies: are stored on the user's device and may continue to exist until they expire, or you delete them. This type of cookies is not deleted when the browser is closed. Persistent cookies can be used to retain user’s preferences and choices when using a site, allowing those preferences to be used in future browsing sessions and may also be used for target advertising purposes. Persistent cookies usually assign a unique ID to the user’s browser and they are usually configured to identify a user’s browser for a prolonged period of time, from days to months or even years.

 

How Does Bupa Use Cookies?

Bupa only uses browser cookies to measure non-Personal Information, for example to learn about the behavior of visitors to our website and how they respond to our marketing communications. The more we learn, the better we are able to provide relevant and interesting content and services.

To help you understand the different types of cookies we use and what they do, we have conducted a full audit of our sites and grouped cookies into four categories:

• Strictly necessary cookies
• Performance cookies
• Functionality cookies
• Targeting cookies

Below, you will find a list of the types of cookies that may be used on our websites and a brief description of the information they gather.

Strictly Necessary Cookies

'Strictly necessary' cookies let you move around the website and use essential features such as accessing secure areas of the website and identifying you as being logged in. These cookies are strictly necessary to provide you with services available through our websites and to enable you to use some of their features. These cookies cannot be disabled in our systems and enable core functionality such as security, network management and accessibility. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. These cookies are used to collect information such as whether you are logged in and which pages you navigate between during a browsing session. These cookies don't gather any information about the user that could be used for marketing or to remember where the user have been on the internet. Accepting these cookies is a condition for using this Site, as they are required for its proper operation. If you prevent them, we cannot guarantee how our Site will perform.

Performance Cookies / Analytics Cookies

We use these cookies to collect information about how visitors use our website, including details of the site where the visitor has come from and the total number of times a visitor has been to our website. We use the information to improve our website and enhance the experience of its visitors. All information these cookies collect is aggregated and therefore anonymous.

While the specific cookies we deploy change regularly, examples of more permanent types of Performance or Analytic cookies we use include cookies provided by Google Analytics, Google Tag Manager, and Adobe SiteCatalyst (formerly Omniture). These cookies are all used to give us insights into how many people visit our website, and how our users interact with it. These cookies are used when you share information using a social media sharing button or “like” (or similar) button on our websites or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. These cookies collect information about your social media interaction with our site, such as whether you have or not an account with the social media site and whether you are logged into when you interact with the content on our site. Again, please note that Bupa cannot identify individual users from the data that our cookies collect; we collect anonymous user preferences and website behaviors only. For questions or more information regarding these cookies, please contact us at privacyoffice@bupalatinamerica.com.

By using this Site, you agree that we can place these types of cookies on your device.

Functionality cookies / Application or Site-specific cookies

These cookies are used to collect information about traffic to our websites and how users use our websites. These cookies allow the website to remember choices you make (such as your username, your language or the region that you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect cannot track your browsing activity on other websites. The information gathered through these cookies may include your computer or mobile device operating system type and version number, manufacturer and model, device identifier, browser type, screen resolution, IP address, the site you visited before browsing to our Site, general location information such as city, state or geographic area; and information about your use of and actions on or in our sites, such as pages you accessed, how long you spent on a page, navigation paths between pages, information about your activity on a page, access times, and length of access.

By using this Site, you agree that we can place these types of cookies on your device.

Targeting cookies / advertising

These cookies track your browsing habits to enable third-party advertising networks to deliver ads that may be of interest to you. These cookies use information about your browsing history to group you with other users who may have similar interests or browsing behaviors. Based on the cookies that the third-party advertising network sets on our Sites and on other sites, advertisers can display advertisements that may be relevant to your interests or our Sites and while you are on third party websites. These type of cookies are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of advertising campaigns.

This type of cookies are usually placed on our sites either directly by us or by third party advertising networks. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality or content provided by the other organization.

By using the website, you agree that we can place these types of cookies on your device.

 

How can you Control the use of Cookies?

Your use of this Site constitutes your consent to this website setting cookies on your device.

If you do not want this Site to set cookies on your device then you should not use this Site and you should delete any Bupa cookies which may have been placed on your device while you visited the Site. You can typically remove or reject cookies via your browser settings. This will set your cookie preferences for all sites, not just our Sites. In order to do this, follow the instructions provided by your browser (usually located within the “Settings”, “Help”, “Tools” or “Edit” menus). Please note that many browsers are set to accept cookies until you change settings. However, because cookies allow you to take advantage of some of the Site's essential features, we recommend you leave them turned on. If you do not accept our cookies, you may experience some inconvenience in your use of our websites. For example, we may not be able to recognize your computer or mobile device and you might need to log in every time that you visit some of our sites.

You may disable cookies by changing your internet browser preferences, however this may limit your full use or functioning of certain features on the site. 

Please note that we do not currently respond to browser “Do Not Track” signals.

We may also allow third party service providers to use cookies and other technologies to collect information and to track browsing activity over time and across third party websites, for example to deliver targeted advertisements to you. However, this policy does not cover the use of third-party cookies. This will be covered by that third party’s privacy policies and practice and we would recommend that you take a look at these which in most cases will be found on that third-party company’s website. For questions or comments related to this, please contact privacyoffice@bupalatinamerica.com.

For more information about third party advertising networks and similar entities that use these technologies, see https://youradchoices.com/control, and to opt-out of such ad networks’ and services’ advertising practices, go to https://optout.aboutads.info/?c=2&lang=EN.

Please note that our Cookie Policy does not apply to, and we are not responsible for, the cookie practices of the third-party websites to which we may link from our sites.

 

Changes to our Privacy Notice

From time to time, we may change this Privacy Notice and our privacy practices because of changes in applicable legal or regulatory requirements, in our business practices, or in our attempts to better serve your needs and those of our clients. When we do so, we will post a revised Privacy Notice on this Site and a new effective date. Any such change will be effective immediately upon posting on the site. You are responsible for checking the Privacy Notice for such changes, and we recommend visiting the page frequently to stay informed. If we update our Privacy Notice, in certain circumstances we may also seek your consent.

 

Questions and Contacts

If you have any questions, comments, concerns or suggestions relating to how we process information about you, please contact our Legal and Privacy team at privacyoffice@bupalatinamerica.com, or at the below address:

Bupa Global Latin America
FAO: Privacy Officer
17901 Old Cutler Road, Suite 400
Palmetto Bay, Florida 33157 USA

 

Acknowledgement

By accessing or using this website, you acknowledge that you have read, understand, and consent to our privacy practices and to the uses and disclosures of information that we collect about you. You also agree to be bound by the Terms of Use applicable to you. 

Annex 1 - Bupa Insurance Company and its subsidiaries, affiliates, and related group of companies

Bupa Insurance Company
17901 Old Cutler Road, Suite 400
Palmetto Bay, Florida 33157 USA
privacyoffice@bupalatinamerica.com

Amedex Insurance Company (Bermuda) Limited
Commerce Building, 2nd Floor Suite 202
54 Reid Street
Hamilton, HM 12, Bermuda
privacyoffice@bupalatinamerica.com

Amedex Services, Ltd.
Amory Building, PO Box 1058
Basseterre
St. Kitts
privacyoffice@bupalatinamerica.com

Bupa Dominicana, S.A.
Av. Winston Churchill No.1099,
Acropolis Center, 3er Nivel,
Piantini. Santo Domingo, Dominican Republic
privacyoffice@bupalatinamerica.com

Bupa Ecuador S.A. Compania de Seguros
Ave. República de El Salvador N34-229 y Moscú,
Edif. San Salvador, Piso 4,
Quito, Ecuador
privacyoffice@bupalatinamerica.com

Bupa Guatemala, Compania de Seguros S.A.
5 Avenida 5-55 zona 14
Europlaza World Business Center,
Torre III, nivel 11, Oficina 1103,
Ciudad de Guatemala 2300-8000, Guatemala
privacyoffice@bupalatinamerica.com

Bupa Insurance (Bolivia) S.A.
Avenida Beni, Calle Guapomó No. 2005, 
Edificio Spazio, of. 202 y 203
Santa Cruz de la Sierra, Bolivia
privacyoffice@bupalatinamerica.com

Bupa Investment Corporation, Inc.
17901 Old Cutler Road, Suite 400
Palmetto Bay, Florida 33157 USA
privacyoffice@bupalatinamerica.com

Bupa Panama, S.A.
P.H. Prime Time, Piso 25B,
Ave. La Rotonda, Costa del Este,
Panama
privacyoffice@bupalatinamerica.com

Bupa U.S. Holdings, Inc.
17901 Old Cutler Road, Suite 400
Palmetto Bay, Florida 33157 USA
privacyoffice@bupalatinamerica.com

Bupa Worldwide Corporation
17901 Old Cutler Road, Suite 400
Palmetto Bay, Florida 33157 USA
privacyoffice@bupalatinamerica.com

U.S.A. Medical Services Corp.
17901 Old Cutler Road, Suite 400
Palmetto Bay, Florida 33157 USA
privacyoffice@bupalatinamerica.com

U.S.A. Medical Services Corporation, DR Branch
Av. Winston Churchill No.1099,
Acropolis Center, 3er Nivel,
Piantini. Santo Domingo, Dominican Republic
privacyoffice@bupalatinamerica.com

AngloLab S.A.
Av. Guardia Civil 664
Distrito de San Isidro
Lima 15036, Perú
privacyoffice@bupalatinamerica.com

Integramédica Perú S.A.C.
Av. Guardia Civil 664
Distrito de San Isidro
Lima 15036, Perú
privacyoffice@bupalatinamerica.com

MediPeru S.A.
Av. Guardia Civil 664
Distrito de San Isidro
Lima 15036, Perú
privacyoffice@bupalatinamerica.com