The Guardian Life Privacy Policy

Guardian Life Limited (GLL) is a company with registered offices in Jamaica. GLL is a member of the Guardian Holdings group of companies. We refer to GLL , as "we," "us," or "our" in this Privacy Notice. You can find details about each of the other GHL group companies by visiting www.myguardiangroup.com This privacy policy will explain how our organization uses the personal data we collect from you when you use our website and our services. For the purposes of this privacy policy, "Personal Data" means information that, either separately or together with other identifying information, can identify you. To the extent that the Data Protection Act requires special treatment of specific types of personally identifiable information, GLL shall take such measures as are necessary for compliance with this law.

What data do we collect? As an insurance company we need to collect many categories of personal data (about you and other parties) for the purposes set out in this Privacy Policy. We collect personal information from you that is necessary for us to either provide you with the product or service you’ve requested or to comply with statutory or contractual requirements. The list set out below is non-exhaustive and only indicative of the data we may hold about you. The exact categories may change from time to time. Data may be gathered in relation to both you and other people who are insured under your policy (such as family members and/or beneficiaries ). Categories of personal information collected include: • Personal information such as contact details, name, e-mail address, postal address, telephone, occupation or job. • Information about your identity, such as date of birth, identity no., passport, driver’s license no., • Information concerning other persons included in the insurance policy or listed in the insurance proposal or insurance policy as beneficiaries, dependents, etc

How do we collect your data? We collect information about you so that we can process the insurance transactions you request and administer or service your policy. We also collect information to inform you of new products and services and to engage in studies or research relating to our business. We limit the information collected to what is needed for our business purposes. We may collect your information from the following sources. • From you, either directly or through our financial professionals. This may include information provided on your insurance application or other forms you may complete. • From others, through the process of issuing a policy or handling a claim. This may include information from other reporting agencies and medical or accident reports. • From your doctor or during a home visit by a health care professional. This may include your health records gathered with your written consent. • From your relationship with us. For example, this may include the number of years you have been a customer or the types of products you have purchased. • From data brokers that collect publicly available information about you. This includes household information, financial transactions, and social media activity.

How will we use your data? We mainly use your personal information so that we can provide a quote, underwrite , administer and manage your policy and to assess and pay claims as part of an insurance contract. However, more specifically, we may use the personal data we gather for any or all of the following purposes: • to verify your (or your authorised representative’s) identity in any interactions between GLL and you (or your authorised representative), whether in person, on the telephone, online, in an app or where necessary in any other circumstances; • to verify the accuracy of the information we receive; • to assess your insurance needs and to assess the nature and level of the risk associated with your proposed insurance policy to determine your eligibility and (if you are eligible) your premium. This may include carrying out credit rating searches and making decisions about you in that regard; • to make or receive any payments, whether in relation to your policy, a claim or any other reason and to make decisions regarding deferred payment arrangements, including without limitation whether to continue or to extend an existing deferred payment arrangement; • to manage and administer any products and services you have obtained from us, including making contact with you; • to manage and investigate any claim made by you or any beneficiary under your policy of insurance; • to provide customer loyalty programmes and value-added services; • for statistical analyses, either by us or the GHL Group, and the review and improvement of GLL’s products, services, processes, systems, websites and apps. Where possible we will anonymise the data we analyse; • to carry out market research, to improve our processes, products or services or to investigate the possibility of new processes, products or services and to buy or sell any business or assets; • to inform you of other products and services that may be of interest to you or members of your family, unless you have advised us otherwise; • for staff training, performance reviews and discipline; • for the detection and prevention of fraud, money laundering and other offences and to assist the police or any other authorised investigatory body or authority with any inquiries or investigations. Where permitted by law we also work with and share data with various bodies including other insurers, anti-fraud bodies (for example fraud whistleblowing services) and law enforcement agencies to help prevent fraudulent behaviour. In some cases, we are required by law to report details of certain criminal activities and suspected criminal activities to the appropriate authorities; • to manage and investigate any complaints; • for reinsurance purposes; • GHL Group reporting purposes (where necessary); • in order to store personal data and make back-ups of that data in case of emergencies and for disaster recovery purposes. • for compliance with all relevant laws and regulations; and/or • as otherwise set out in this Privacy Policy or any other data protection notice, policy booklet, website, app terms and conditions or other documentation provided to you by GLL or your broker.

How do we store your data? We protect your information using safeguards that comply with applicable laws. This includes measures that are administrative, physical, and technical in nature. We use commercially reasonable measures to secure our websites and protect the information that may be shared over these sites. We instruct our employees with access to your information that it is to be used only in accordance with the principles set forth in this Privacy Policy and the privacy laws and regulations applicable to GLL. Employees who misuse customer information are subject to disciplinary action up to and including termination of employment. We have a comprehensive record retention schedule. The retention periods differ depending on the purpose of the processing and the nature of the information. How long we keep data is primarily determined by how long we need it for the purposes we told you we were going to use it for, time periods set out in law and the period we need to keep it to defend ourselves against legal action. Please note that we will take all appropriate steps to keep your personal data safe. In the unlikely event that we have a security breach, we will notify you without undue delay about the circumstances of the incident in accordance with our legal obligations. Marketing We may use some of the personal data that we hold about you, such as your contact data, for the purpose of informing you about our products, services or offers that may be of interest to you. You have control over how we use your information for marketing the products and services that we offer and that is why we ask for your consent for the marketing of our products. Sometimes, if we do not have your consent for the marketing of our products and you are an existing customer of ours, we can use GHL’s legitimate interests as a basis for informing you on our products, services or offers in informing you about products that may be of interest to you. If you do not wish to be informed about our services, products or offers, you may inform us at any time of your wish or you may withdraw or recall your consent that you granted previously and we will stop contacting you for this purpose. If you no longer wish to be contacted for marketing purposes, please click here. Please remember that if you change your marketing preferences, it may take a short time for those preferences to become effective. By opting out of marketing communications, you will continue to receive communications (including emails) related to your User Account and the Services, including product updates, trainings, and communications related to billing, maintenance, and support.

What are your data protection rights? We recognize that the personal data that we process belongs to you and we are continually making efforts to ensure that you have control over your personal data. Based on the existing legislation governing the processing of personal data, you have the right to submit various requests regarding the personal data that we process Based on the law, you have the following rights in relation to your personal data: • Right to access: You have the right to be informed, as well as the right to receive a copy of the data that we hold about you. A copy of the data is usually provided free of charge. We can provide you with a copy of your data in print or electronic form. • Right to rectification: We take reasonable measures to ensure that the information that we hold about you is accurate. Nevertheless, if you believe that certain information about you is incorrect or it is not up to date, you have the right to ask us to correct the inaccurate information about you as well as the right to complete same. • Right to restriction: You have the right to request the restriction of the processing of your data in certain cases, including where the accuracy of the personal data is contested for a period enabling us to verify the accuracy of the personal data or where the data is no longer necessary to be held by GLL and its subsidiaries but you wish for the data to be retained for the purposes of a legal claim or where you exercise your right of restriction pending your request. • Right to object: You have the right at any time to object to the processing of your personal data. For instance, you have the right to object to processing for direct marketing purposes where such processing is based on our legitimate interests. If you make an application for the exercise of your right to object, processing will cease unless GLL is able to show a superior legitimate interest or if such data is required in order to support legal claims. If you object to the processing of your personal data for direct marketing, we will stop processing your data for this purpose within a reasonable time after receiving your objection and we will stop contacting you for the purpose of marketing our products. • Right to withdraw consent: You have the right to recall or withdraw the consent you have given to us for the processing of your data. Nevertheless, please note that the withdrawal of consent does not affect the lawfulness of processing that used to be based on consent prior to its withdrawal. In some cases, the withdrawal of your consent to the processing of your data may mean that we will not be able to serve you in view of the fact that the processing of certain data is inextricably linked to the provision of the service that we offer to you. Right to file a complaint: You have the right to file a complaint with the relevant Authority if you have a complaint about the processing of your personal data that is carried out by us

What are Cookies? Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology For further information, visit allaboutcookies.org.

Changes to our privacy policy GLL keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 26 September 2023.