This Statement sets out how American Life Insurance Company (MetLife) may collect, use, transfer, disclose and retain your personal information when you apply to or subscribe to any of our products or services or communicate with us directly, online or via our applications and devices. In return, we may use this data to provide you with our products or services, maintain our records or send you relevant information. This Statement applies to all products and services provided by MetLife.

For the purposes of this Privacy Statement, please note that:

• “MetLife” refers to American Life Insurance Company (MetLife) and its Parent Company, direct and indirect subsidiaries, associates, affiliates and or related companies.
• “Personal information” refers to any information which relates directly or indirectly to you and/or your transactions with us. With respect to MetLife’s business that can include information such as  your caste, birth certificate, marital status, education or academic qualification, address, telephone or address of electronic letter (email), passport, citizenship certificate, national identity card number, driving license, thumb impressions, blood group, fingerprints, but in unusual situations could also include your ethnicity, origin, religion, color, voter identity card, any other identity card issued by a public body, a letter sent or received to or from anybody mentioning your personal information, retina of eye or other biometric information, criminal background or description of the sentence imposed for a criminal offence, related documents and any other information that shall be deemed to be personal information under the Privacy Laws of Nepal from time to time.
• “Sensitive Personal Information” refers to information relating to your political affiliation, religious faith or belief, physical or mental health or condition, sexual orientation or event relating to sexual life or details relating to property.

Your privacy is therefore important to us and we are committed to protecting your Personal Information and Sensitive Information (collective “Personal Data”) by collecting and using your Personal Data in accordance with the privacy laws of Nepal.

1. Purpose for collection, use, transfer, disclosure and retention of your Personal Data

In order to enable us to deal with your inquiries, open and operate an insurance policy for you or to provide you with our products and services, we may be required to collect, use, transfer,  disclose and retain (i.e. “process”) your personal and/or financial information.

It is necessary for customers and other individuals (including without limitation the insured persons and beneficiaries) to supply MetLife with Personal Data in connection with the purchase and continuation of the insurance policies with MetLife, provision of insurance and financial services and compliance with any laws, regulations, codes or guidelines issued by regulatory or other authorities by MetLife.

Personal Data are to be collected from customers in the ordinary course or during the continuation of the business relationship between the customers and MetLife, for example, when the customers make any claims or change the personal particulars or beneficiaries under the insurance policies.

Failure to supply such Personal Data may result in MetLife being unable to offer or continue the insurance policies, provide insurance, financial products, services and continue the business relationship between the customers and MetLife.

2. How we obtain your Personal Data   

We may collect Sensitive Personal Information related to your health, when you apply for our insurance products and services.

We may also obtain your Personal Data from the following sources:

• your relationship with us, for example information provided by you in application forms when applying for our products or services, when transacting on your insurance policy, when using our online or electronic services, when taking part in customer surveys, competitions and promotions.
• your verbal, written, telephonic and/or electronic communications with us or our authorized agents;
• third parties connected with you, such as your employer, joint policy owner, other partners in your partnership, or through our corporate customers or corporate security providers where you are a director, shareholder, officer or authorized signatory;
• analysis and research on the way you use and manage your insurance policy(ies) with us;
• your access and use of our services, transactions you make and payments effected through your insurance policy(ies);
• images captured by closed circuit television (CCTV) cameras at our branches and office premises or third party premises (where our self-service terminals are located), when you visit our branches or office premises or use our self-service terminals at third party premises;
• credit reporting agencies and publicly available sources such as through searches at relevant government authorities or agencies; and/or
• any other sources which you have given your consent to disclose information relating to you and/or where not otherwise restricted.

When you provide Personal Data related to third parties to us, such as your next of kin or nominees, you confirm that you have obtained their consent or are otherwise entitled to provide their Personal Data to us.

The Personal Data we collect can be either mandatory or optional. Mandatory Personal Data consists of your information that we require so that we can provide you with the required products and services. If you do not provide us with the mandatory Personal Data, we will not be able to provide you with those products and services. Optional Personal Data consists of your information that is not obligatory to be provided to us. If you do not wish to provide your optional Personal Data, you may still apply for our products and services. Mandatory and optional Personal Data may differ for our various products and services and these will be indicated in the application forms of our products and services.

3. Use of your Personal Data

Your Personal Data may be collected and/or used by MetLife and/or transferred, disclosed to the entities or individuals for the following purposes:

1. processing applications for insurance products or services, as well as any changes, cancellations, renewals, reinstatements, and any other relevant matters;
2. verifying customers’ identities and background, and establishing customers financial standing and creditworthiness for insurance or financial products or services and ensuring ongoing due diligence of the customers;
3. facilitating the daily operation of the insurance or financial or related services or products provided by MetLife, including without limitation arranging insurance contracts, managing customers’ accounts, monitoring sum assured, performing ongoing and future administration and assessment and underwriting any insurance policy issued by MetLife;
4. establish the condition of health for customers who wish to procure insurance policies offered by us;
5. assess your eligibility or suitability for our products which you had applied for and to verify your identity or financial standing.
6. to notify you of more and up to-date information such as improvements and new features to the existing products and services, development of new products and services, competitions, promotions and offers from MetLife or third party business partners which may be of interest to you;
7. manage and maintain your insurance policy(ies) through regular updates, consolidation and improving the accuracy of our records. In this manner we can respond to your enquiries, complaints and to generally resolve disputes quickly so that we can improve our business and your relationship with us;
8. conduct research for analytical purposes, data mining and analyses of your transactions /use of products and services to better understand your current financial/investment position and future needs. We will also produce data, reports and statistics from time to time. However, such information will be aggregated so that your identity will remain confidential;
9. comply with the requirements of any law and regulations binding on us such as conducting anti money laundering checks, crime detection/prevention, prosecution, protection and security;
10. enforcement of our rights to recover any debt owing to us, including transferring or assigning our rights, interests and obligations under any of your agreement with us;
11. perform shared services within MetLife such as audit, compliance, legal, human resource, finance and risk management;
12. outsourcing of business and back-room operations within MetLife; and
13. providing and designing any insurance or financial or related product or service;
14. enforcing the customers’ obligations under the insurance contracts including without limitation collection of insurance premiums and identification documents;
15. marketing insurance or financial product or service (including without limitation reward, loyalty or privilege programs or members’ club) of MetLife, or of any of its parent companies, subsidiaries, affiliates, related companies or group companies, or partnering banking and/or financial services providers and telecommunications and social media companies or entities, by mail, fax, electronic mail or other means of communications, or telephone calls addressed to the customers, in respect of which MetLife may or may not be remunerated (collectively “ Direct Marketing Purposes”);
16. processing (including but not limited to investigating and analyzing) any claim under any insurance policy issued by MetLife and any credit, medical security and underwriting checks;
17. matching Personal Data (including without limitation sum assured) to determine and recommend any insurance or financial or related products or services that may be of customers’ interest;
18. creating and maintaining MetLife’s customer profile and segregation and business model and performing risk management;
19. complying with the compliance program and internal policies of MetLife and with all laws, regulations, codes or guidelines issued by regulatory or other authorities binding to MetLife or its parent companies, subsidiaries, affiliates, related companies or group companies;
20. meeting any disclosure requirements imposed by laws, regulations, codes or guidelines issued by regulatory or other authorities on or binding to MetLife, or of any of its parent companies, subsidiaries, affiliates, related companies or group companies, or partnering banking and/or financial services providers and telecommunications and social media companies or entities;
21. comparing Personal Data of the customers and other individuals for de-duplication, sum assured monitoring, credit-checking, data verification or otherwise producing or verifying data, whether or not for the purpose of taking adverse action against the customers;
22. maintaining a history of the customers (whether or not there exists any relationship between the customers and MetLife) for present and future reference;
23. providing customer services (including but not limited to processing enquiries and complaints, performing policy review or needs analysis);
24. performing marketing research or survey or analysis or statistics which may be beneficial to the improvement of customer services and daily operation and provision of the insurance and financial and related products and services by MetLife or of any of its parent companies, subsidiaries, affiliates, related companies or group companies, or partnering banking and/or financial services providers and telecommunications and social media companies or entities;
25. communicating with the customers via telephone, mail, e-mail, facsimile or any other means of communications;
26. evaluating the policy intended to be the subject of reinsurance by an actual or proposed reinsurer of MetLife;
27. conducting medical or health reference checks;
28. exercising any right of subrogation or any other right given to MetLife under the insurance policies;
29. any other purpose(s) that is required or permitted by any law, regulations, standards, guidelines, code of practice and/or by relevant regulatory authorities.

We will provide additional notice or seek your consent before using your Personal Data for a purpose other than those that are set out in this Privacy Statement and/or in the terms of any of your agreement(s) with MetLife.

4. Disclosure of Your Personal Data

As part of providing you with our products and services we may be required to disclose certain information about you and/or your accounts, facility(ies) and/or insurance policy(ies) with us to the following third parties:

1. our product distributors, authorized agents, and service providers who assist us in processing, administering, fulfilling transactions or providing services to you on our behalf, or to fulfill value added services that you have requested; insurance companies and intermediaries of MetLife;
2. our external professional advisors and consultants who provide services to us, for the purposes of our business, operational, legal and regulatory requirements;
3. any person(s) authorized or appointed by you to give instructions to us on your behalf such as your employer, family member making a claim on your behalf, agents, accountants, auditors, lawyers, financial advisers, brokers and intermediaries;
4. Other insureds or beneficiaries on your policy;
5. If you have an online account with MetLife, others that you allow to access this account;
6. any person(s) connected to the enforcement or preservation of any of our rights or transferring the rights, interests and obligations under your insurance policy(ies) with us;
7. any third party(ies) arising from assignment of your insurance policy with us, sale of debts, acquisition or sale of any company by MetLife provided that the recipient uses your information for the same purpose(s) as it was originally supplied to us and/or used by us;
8. insurance broker(s), re-insurers and in the event of default of a facility granted to you, to debt collection agencies;
9. any parent companies, subsidiaries, affiliates, related companies or group companies of MetLife in which you had earlier subscribed to a product or service, to other MetLife Companies, for marketing of their products and services that may be of interest to you; and/or
10. any competent authority(ies) and/or regulator(s) for the performance of their functions subject at all times to any laws (including regulations, standards, guidelines, and/or obligations) applicable to MetLife, or its parent companies, subsidiaries, affiliates, related companies or group companies.
11. partnering banking and/or financial services providers, telecommunications companies or entities, social media companies or entities of MetLife for the purpose of fulfilling the transactions required by you;
12. call centres, mailing houses, research house, data processing companies engaged by MetLife;
13. debt collection agencies, credit reference agencies, any financial institution or credit / charge card issuer related to premium payment account engaged by MetLife;
14. professional advisors, reinsurance and claims investigation company, any loss adjusters, providers of risk intelligence engaged by MetLife;
15. persons or entities which provides administration, operational, technical, data-processing, marketing and promotion, research, payment, printing, redemption, information technology, hosting, mailing, and telecommunications, customer service, and reward, loyalty or privileges programs or club membership support to MetLife;
16. any relevant industry association or federation, and any member or committee of such association or federation, any governmental and judicial bodies, and tax authorities or regulators, any person to whom MetLife or its parent companies, subsidiaries, affiliates, related companies or group companies is required to transfer and make disclosure of the relevant Personal Data; and
17. other parties as notified to the customers at the time of collection.

5. Your Personal Data may be transferred to a location outside Nepal:

Without compromising the confidentiality of any Personal Data MetLife may provide any such Personal Data to the following parties outside Nepal (the “Recipients”) for any of the purposes set out in this Statement, in respect of which MetLife may or may not be remunerated.

1. when the vendor or service provider providing various types of services to us (including data storage services), is based in a location outside Nepal, in which instance, we will take reasonable precautions to ensure that such vendor or service provider has the relevant technical and organizational security measures to protect Personal Data;
2. for the purposes of legal proceedings outside Nepal and for us to obtain legal advice or to defend our legal rights;  
3. to any competent authority(ies) and/or regulator(s) for the performance of their functions subject at all times to any laws (including regulations, standards, guidelines, and/or obligations) applicable to MetLife, or its parent companies, subsidiaries, affiliates, related companies or group companies.

6. Retention of your Personal Data

Your Personal Data will be retained in compliance with this Privacy Statement and/or the terms and conditions of your agreement(s) with any parent companies, subsidiaries, affiliates, related companies or group companies of MetLife for the duration of your relationship or for such period required by the laws and to protect the interest of both MetLife and you. Such retention is also necessary as required by law or in accordance with our internal policies and the prevailing laws.

MetLife takes all practicable steps to:-

• ensure the accuracy of Personal Data and to erase such Personal Data after fulfillment of the purposes as set out in this Statement;
• erase Personal Data no longer required for the purposes as set out in this Statement unless prohibited under any law or public interest requires otherwise;
• ensure that Personal Data is protected against unauthorized or accidental access, processing, erasure, loss or use other than such purposes as set out in this Statement;
• ensure that Personal Data will be kept in a secure manner and not be kept longer than necessary for the purposes as set out in this Statement;
• comply with all the relevant requirements under the Privacy Act.

7. Security of Your Personal Data

We place great importance in ensuring the security and confidentiality of your Personal Data and regularly review and implement up-to-date technical and organizational security measures when processing your Personal Data.

8. Exercising your choice in respect of the disclosure and use of your personal Data for purposes of marketing

You may exercise your choice in respect of the disclosure and use of your Personal Data with us. In the event you choose not to receive any marketing material(s) from us or any of our third party business partners, you may either (i) contact us at the contact details provided below; or (ii) by choosing to opt out from receiving marketing material, a choice provided for in the relevant application/proposal forms of our products or services.

Please note that:

• irrespective of the choice you make in relation to the above, you may still contact us subsequently through the channels provided below in order to change your choice. Your latest choice communicated to us will apply. We shall update your most recent marketing preference in our database within a reasonable period of time after we receive the communication of your choice;
• we may not be able to remove your Personal Data from the databases of third party business partners with whom we have already shared your Personal Data, when you had provided your express consent earlier;
• certain communications such as our statements of account, correspondence and websites may contain standard information regarding our other products and services that cannot be removed without affecting the delivery/provision of our services and/or products, the operation of your account(s) and/or facility(ies) with us, and/or additional costs to you.

9. Outsourcing Arrangements

Personal Data may be processed by MetLife, its affiliates and third-party service providers in Nepal and outside Nepal for any of the purposes set out in this Statement. To the extent that Personal Data is processed by an affiliate or third-party service provider, MetLife takes steps to procure that such affiliate or third party employs adequate information security measures to comply with the applicable data privacy laws. Outsourcing arrangements are subject to due diligence and ongoing monitoring to ensure an adequately high standard of data privacy protection throughout the life of the outsourcing.

10. Foreign Tax Reporting Obligations

The Personal Data may be transmitted by MetLife to the Inland Revenue Department or any other relevant domestic or foreign tax authority of another jurisdiction related to tax reporting obligations.

11. Additional information for MetLife Applications and Devices (Access to location, built in camera and folders)

We may, only after obtaining your permission from our applications and devices to allow/enable access to your location, track your location only for the purpose of assisting you in finding our nearest MetLife Office addresses. Your Location will not be stored, transferred or replicated by us for any other use and purpose.

• Built in camera and folders

Subject to obtaining your permission from our applications and devices to allow/enable access the built-in camera and folders stored in your computer, tablet or smartphone, we may use your camera and folders for the purpose of enabling  face- id login option and capturing, scanning, uploading and submitting documents through our applications and devices.

12. Revisions to the Privacy Policy Statement

Our Privacy Policy Statement may be revised from time to time and if there is/are any revision(s), it will be posted on our website and/or other means of communication deemed suitable by us. However, any revision(s) will be in compliance with the Privacy laws and regulations of Nepal.

13. Your Rights to Access and Correct Personal Data

Any request for access to Personal Data or correction of Personal Data, or for information regarding policies and practices and kinds of Personal Data held can be addressed in writing to:

MetLife c/o The Data Privacy Officer

Narayani Complex, Pulchowk, Lalitpur,PO Box: 11590

Toll Free: 1660-01-55555 (NTC) , Fax: +977-1-5555173

+977-1-5555166, Call Center No: +977-1-5970166

service-nepal@metlife.com.np

While making an application for correction of Personal Data you are required to submit the details as to why such correction is required along with the required documents to prove the request.

Please note that we may withhold access to your Personal Data in certain situations, for example when we are unable to confirm your identity, where the information requested is of a confidential commercial nature or when there are repeated requests for the same information. Nevertheless, we will notify you of the reason(s) for not being able to agree to your request. We may also request for more documentary evidence to avoid incidence of fraud and/or inaccurate information.

In order to enable us to serve you better, we seek your assistance to continuously keep your Personal Data up to-date.

If any individual has any questions concerning this Statement, or if the customer does not wish to receive any direct marketing promotions or offers from MetLife, please contact the Data Privacy Officer of MetLife at Narayani Complex, Pulchowk, Lalitpur, Nepal.

                  [April 23, 2021]