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ZIO Members App Privacy Notice

Zurich ZIO Members App Privacy Notice

Introduction

Welcome to the Zurich ZIO Members App ("ZIO App"). At Zurich International Life Limited (“ZILL”) and Zurich Eurolife S.A (“ZEL”) (referred to together in this Privacy Notice as "Zurich" “we”, “us” or “our”), we, as independent controllers, are committed to protecting your personal information and ensuring that your privacy is respected. This Privacy Notice explains how we collect, use, and safeguard your personal information when you use the ZIO App. It also outlines your rights regarding your personal information.

Information We Process

In providing the ZIO App, we may process the following data:

  • Basic Information: address, email address, telephone number, title, marital status, nationality, country of residence.
  • Device Information: device locale, time zone, platform, notification opt-in status, app version, message reads and deletes, device model, manufacturer, OS version, carrier, connection type, time in app, screen tracking, and push notification interaction events.
  • Zurich Unique Identifier: a unique number associated with your Zurich International Online (ZIO) account (this is not a policy number).

We may collect this information through your input into the ZIO App or other sources such as external service providers, brokers, intermediaries, financial advisers or ZIO.

How We Use Your Information

We may collect and use personal information where the processing is necessary in relation to a contract of insurance and/or provision of related services that have been requested or to meet our legal or regulatory obligations for purposes of:

  • Communication: To communicate with you and your appointed representatives, if necessary, including through push notifications and the message centre.
  • Beneficiary Nominations: To allow you to nominate beneficiaries (first name, surname, date of birth, relationship to member). If we are provided with personal information on other individuals (such as beneficiaries) in connection with a contract of insurance and/or provision of related services, it is understood that in doing so all necessary permissions and consents have been received.
  • Personal Information Management: To enable you to add, remove, or modify personal information such as marital status, title, work phone, home phone, preferred email, alternative email, country of nationality, address, postcode, and country.
  • Fund Switching Instructions: To allow you to instruct fund switching.
  • Regulatory Compliance: To comply with legal and regulatory obligations

We also process information for our general legitimate interests which include:

  • App Functionality: To enhance user experience, improve functionality, and develop our services.
  • Feedback: To conduct surveys and obtain feedback on our services.
  • Protection of the ZIO App: Reviewing compliance with the applicable terms and conditions, ensuring the security of our business and preventing or detecting fraud or abuses of our online platform.

We also process personal data where we have consent to do so which includes:

  • Analytics: device information may be anonymised and aggregated into analytic data to help us understand user behaviour, identify trends and areas for improvement, enhance user experience, improve the ZIO App's functionality and develop our services.

If we are processing personal information with your consent, your consent may be withdrawn at any time (however, please note withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal). If your consent is not provided when requested or is withdrawn for certain features within the ZIO App, we may not be able to provide you with the relevant feature.

Sharing Your Information

We may share your personal information with third parties and we do so in accordance with data protection laws.

We may share personal information with the following categories of recipients:

  • Zurich Group Companies
  • Appointed Agents including brokers, intermediaries, financial advisers
  • Regulatory and legal authorities
  • Service Providers including third parties that enable our communication functionality and policy administration.

The third party which enables our communication functionality may process, anonymise and aggregate limited usage information for the improvement of their services (however, opting out of ‘Analytics’ within the ‘Settings’ area of the ZIO App will disable this functionality if preferred).

International Data Transfers

Given the global nature of our business, we may transfer personal information to other countries. Where we transfer personal information to countries that are outside of the Isle of Man and the European Union (EU) we will ensure that it is protected and that the transfer is lawful. We will do this by ensuring that there is either an adequacy decision relating to the safeguards for personal information from the European Commission, or that the personal information is given adequate safeguards by using ‘standard contractual clauses’ which have been adopted or approved by the Isle of Man and the EU, or other solutions that are in line with the requirements of European data protection laws.

Retention of Your Information

We retain your personal information for as long as necessary to fulfil the purposes for which it was collected, subject to legal, tax, and regulatory requirements.

Your Rights

You have the following rights regarding your personal information:

  • Informed: to be informed about the collection and use of your personal data.
  • Access: To access your personal data.
  • Rectification: To correct inaccurate or incomplete data.
  • Deletion: To request the deletion of your data in certain circumstances.
  • Restriction: To restrict the processing of your data in certain circumstances.
  • Portability: To obtain and reuse your data across different services.
  • Objection: To object to the processing of your data.
  • Automated Decision-Making: To not be subject to decisions based solely on automated processing.

You can exercise these rights by contacting our Data Protection Officer.

Contact Us

For any questions or concerns about this Privacy Notice or your personal information, please contact our Data Protection Officer:

For ZILL:

Email: ZILLPrivacy@Zurich.com
Address: Data Protection Officer, Zurich International Life Limited, Zurich House, Isle of Man Business Park, Douglas, Isle of Man, IM2 2QZ.

For ZEL:

Email: ZELprivacy@zurich.com
Address: Data Protection Officer, Zurich Eurolife S.A. , 21 rue Léon laval, L-3372 Leudelange, Luxembourg

Complaints

For ZILL: If you are dissatisfied with our handling of your personal information, you can file a complaint with the Information Commissioner’s Office at:

Address: First Floor, Prospect House, Prospect Hill, Douglas, Isle of Man, IM1 1ET.

For ZEL: If you are dissatisfied with our handling of your personal information, you can file a complaint with the National Commission for Data Protection at:

Address: 15, Boulevard du Jazz, L-4370 Belvaux, Luxembourg.

Updates to This Notice

This Privacy Notice is effective as of April 2025. We may update it from time to time, for example to reflect changes in our practices or legal requirements, and any such amended Privacy Notice will only apply from the time of amendment.

More Information

If you would like to learn more about how we process your personal data, for Zurich International Life Limited please click here or for Zurich Eurolife S.A. please click here.