Last updated: 11th November 2020
We, at LifeStar Holding (The Group), endeavour to protect your privacy rights at all times, including when you visit and use our website. For this reason, we kindly invite you to read the following information so that you will be better guided as to how we process and protect your personal data.
Who We Are
LifeStar Holding plc is a public limited liability company incorporated under the laws of Malta with company registration number C-19526 and its three regulated subsidiaries GlobalCapital Financial Management limited, LifeStar Health Limited and LifeStar Insurance plc, hereinafter referred to as “we”, “us”, “our”, or “ours”.
We are the Controller of the data that you may provide us at any time, including when visiting and using this website, such as where you provide information to acquire a quote and purchase insurance cover.
The information we collect relating to you
In general, as a user of our Website, you may visit our website without telling us who you and/or revealing any other information about yourself. You may however, choose to provide us with personal information if you complete and submit any of the forms that may be available on our website or send us queries or questions. In such case, we shall also collect your IP address as a requirement to ensure no spamming occurs and to avoid duplicate records.
The information that you are requested to provide is necessary to take steps at your request prior to entering into a contract, or for the proper performance of your contract of insurance/investment, or to enable us to provide you with the service that you request, depending on the circumstances. Therefore, failure to provide us with the requested information might render us unable to accede to your requests.
Furthermore, when it comes to insurance, we may engage in insurance industry standard profiling, wherein the assessment of risk is made by automated means. However, all final decisions which produce any legal effects on data subjects, including without limitation, the decision on whether to underwrite a risk and issue a contract of insurance, are taken with human intervention. We will keep such information as long as is necessary for the purpose(s) for which it was collected, such as underwriting, and in accordance with this Privacy Notice. Data will be securely destroyed when no long required.
Purposes and Legal Bases for Processing
- Contractual necessity: its use is necessary in relation to a service or a contract that you have entered into or because you have asked for something to be done so you can enter into a contract with us. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to provide products and services to you.
- Our legitimate interests: we may process your information where it is in our legitimate interests to do so, without prejudicing your interests or fundamental rights and freedoms. Its use is in accordance with our legitimate interests outlined in this Privacy Notice;
- Legal obligations: when you apply for a product or service (and throughout your relationship with us), we are required by law to collect and process certain personal information about you. Its use is necessary because of a legal obligation that applies to us (except an obligation imposed by a contract); and
- You have consented or explicitly consented to the using of your data (including sensitive data) in a specific manner.
Should you provide your consent accordingly, we may use your data to inform you by direct marketing about our range of products and services or about offers from carefully selected third parties we work with, if we think they are of interest to you. Kindly be informed that your data is only shared for marketing purposes within the LifeStar Group and not with other third parties. You also have the right to unsubscribe from receiving our marketing information at any time, either by sending an email to following email address: email@example.com, or by visiting one of our offices either at Ta’ Xbiex from Monday to Friday between 08:00am and 07:00pm and on Saturday between 09:00am and 12:00pm, or in Victoria, Gozo which is accessible only by appointment.
Sharing of your personal data
The personal data that you submit through this website will be received by the host of the website and transmitted to us.
Such data may then be disclosed or shared by us, only as is strictly necessary in line with the purposes outlined above, with our employees, associates, tied insurance intermediaries, financial planner manager, joint controllers, our actuaries, consultants, legal advisors, auditors, risk assessors, loss adjusters and surveyors, healthcare and other medical institutions and professionals, banks, credit referencing agencies, risk intelligence agencies, the other investment or insurance and reinsurance companies, other professionals, and public, legal and/or judicial authorities. We may also disclose your data to third parties if it is called upon to do so by a competent authority, or by a Court or tribunal, only to the extent required and allowed by law.
How long we hold your information
In line with our regulatory and legal obligations, including inter alia the Anti-Money Laundering regime and the Maltese Tax legislation, and for the purpose of underwriting and/or claims handling, we will keep your personal data, whether sensitive or otherwise, on the following basis:
- Our legal obligation for retention of your information;
- The term of the contractual relationship and necessary services to carry out such relationship; and
- Any request of the deletion of data by the relevant party, where applicable.
The information will be destroyed as soon as it is no longer required for the lawful purpose(s) for which it was obtained. We may on exception retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that we will be able to produce records as evidence, if they’re needed. Nevertheless, data collected for inquiries which will not result in any type of contract will not be retained and will be discarded immediately.
Providing and holding personal information comes with significant rights on your part and significant obligations on ours. You have several rights in relation to how we use your information:
The right to be informed – You shall have the right to request us to inform you about the personal data that we process about you, the purpose of the processing, the categories of data that are being processed, the recipients of the data and the type of processing. If at any point you believe that the information we process on you is incorrect then you can request to see this information, have a copy of such data and have it corrected or deleted. Any such access/ratification requests must be made to us in writing and must further be signed by you as the data subject.
If you later wish to raise a complaint on how we handled your personal data, you can contact us to have the matter investigated. In the event that you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can then file a complaint with the Office of the Information and Data Protection Commissioner by accessing the following link: https://idpc.org.mt/en/Pages/contact/complaints.aspx.
The right to maintain your personal data accurate and up to date – We make every effort to ensure that all the personal data that we process about you is accurate and regularly updated. However, should you become aware of any errors or omissions in respect of your personal data you are kindly requested to inform us about such errors in writing. If it transpires that the information held is inaccurate, we will make the necessary amendments and inform you that these have been made.
The right to be forgotten – Where applicable, and in exceptional cases as allowed by law, you shall also have the right to request erasure of your personal data on inter alia the following grounds:
- Subject to our legal and regulatory obligation where processing is no longer necessary for its intended purpose;
- If your personal data has been given to us solely for consultation purposes, such as a life policy estimation, and you choose not to avail yourself of any of our services;
- When erasure is necessary for compliance with a legal obligation by the judiciary of Malta;
- When you object to the processing, unless there are overriding legitimate grounds for us to process;
- When the data concerns a child and has been collected solely for marketing purposes and not arising out of a contractual relationship for services required from us; and
- Where any data has been collected solely for marketing purposes.
Instead of requesting erasure, you can also request a restriction of the processing of data in cases where the personal data is inaccurate, unlawful or pending a decision on a complaint lodged by you. In such case we can only store your personal data and any further processing is only possible with your consent or in a limited number of situations.
The right to data portability – Since your personal data is subject to automated processing on the basis of our contractual relationship, you are thus allowed to request a copy of the data concerned in order for you to be able to transmit your processed data to another controller without any hindrance from our part.
The right to object– You have a right to object to us processing your personal information where the legal basis for our use of your data is our legitimate business interests or the performance of a task in the public interest. However, in doing so this may have an impact on the services and products we can/are willing to provide. You also have the right to object to the use of your personal data for direct marketing purposes. If you object to this use, we will stop using your data for direct marketing purposes.
The right to withdraw your consent- where we rely on your permission to process your personal information, you have a right to withdraw your consent at any time. We will always make it clear where we need your permission to undertake specific processing activities.
It is important to note that, in certain circumstances, you may not be able to exercise your rights as stipulated above or you may be able to exercise such rights but only in a limited manner, as dictated by law.
We recognize the importance of confidentiality and uses secure servers and various other technological means to ensure the security of your personal information.. All our employees and data processors, who have access to and are associated with the processing of personal data, are further obliged to respect the confidentiality of our clients’ and visitors’ personal data.
We will update this Notice from time to time. Any changes will be communicated to you without delay, and where appropriate, notified to you by SMS or email.
How to contact us
If you have any questions about how your personal data is gathered, stored, shared, or used, or if you wish to exercise any of your data rights, please contact our Data Protection Officer at: