Effective as of April13, 2021 with amendments as of January 10, 2022.

Olé Insurance Group Corp. I.I. (“Olé“, “we” or “us“) understands the importance of protecting your privacy and we want you to feel comfortable sharing information with us. This Privacy Policy (“Policy“) explains what information we collect about you, how we use that information, how we disclose that information, and the control you have over our access to and use of that information. This Policy applies to all information we collect through the Olé Mobile App (“App“), through the Olé website, www.olelife.com (“Website“), through any communications held by phone, videoconferencing, chat, messaging or other means, including any telehealth, or as a result of providing the services available through the App or Website (“Services“). 

Olé tiene su base en Puerto Rico.  Cualquier Dato Personal (según se define más adelante) que se nos proporcione será transferido a, utilizado en, y mantenido por Olé en los Estados Unidos. Olé proporciona la App, el Sitio Web y los Servicios para usarse únicamente fuera de los Estados Unidos.  Si usted está ubicado en, o es residente en los Estados Unidos, usted no es elegible para nuestros Servicios y no deberá utilizar la App o el Sitio Web.

By visiting the Website, downloading or using the App, using the Services, or otherwise providing information to us, you consent to the collection, use and transfer of your Personal Data for processing in the United States or other identified locations and to the processing and handling of your Personal Data as described in this policy.

PERSONAL DATA & PRIVACY LAWS

These definitions will help you understand this Policy.

“Personal Data” is any information related to an identified or identifiable person (“data subject” or “you”) who can be directly or indirectly identified by such information.

“Privacy Laws” means any international, national, federal, state, or local law, code, or regulation that is binding on Olé and regulates the processing of Personal Information in any way.

1.0       THE INFORMATION WE COLLECT ABOUT YOU

We collect information about you directly from you and indirectly from third parties. We also automatically collect information about you when you use our Website, App, or Services. You may browse our Website without providing us with any Personal Data, but to download our App or set up an account on our Website or through the App, we will collect certain information about you.  Any communication held by phone, videoconferencing, chat, messaging or other means, including any telehealth, that results in us collecting data from you is subject to this Privacy Policy. The collected data will be recorded and/or stored.

1.1       Information We Collect Directly From You

The information that we collect about you depends on how you use our Services.

• Creating An Account. To download our App or to create an account with us through the App or the Website you must provide certain Personal Data, including your name, email address, date of birth, certain medical information and the password you create.
• Signing Up for Service Updates or Promotional Communications. We collect Personal Data when you communicate with us or sign up to receive Services updates or promotional materials via email, push notifications, or text messages – including your email address, mobile number, and other contact information.
• Applying for Coverage. If you want to apply for insurance coverage you will provide additional information so that we can verify your eligibility for coverage. The additional information may include, but is not limited to: your physical address, a government issued identification number, your phone number, information about your family members, information about your medical history and health conditions, information about your finances and lifestyle habits, information about your use of tobacco, alcohol and other medications.
• Purchasing Insurance. If you qualify and decide to purchase insurance from us, you may have to provide us with further information related to managing your policy(ies), including, but not limited to, your billing address. Olé utilizes one or more third party payment processors to facilitate credit card payments.  You may also make payments using your Apple or Google account.  Olé receives a simple confirmation of payment, cancellation or renewal receipt from these payment processors and does not have access to your credit card information, your Google account information or your Apple account information.
• Submitting Claims Information. If you or a family member submits a claim for coverage, we may collect additional information in order to substantiate the claim.

1.2       Information that We Collect from Others.  

We may receive information about you from others in order to provide the Services. We protect and process information obtained from those parties in the same manner as the information we collect directly from you, unless our contractual agreement with the third party requires otherwise. Our sources of information may vary over time and depending on the Services you purchase.  For example, we may receive information from:

• Supplemental information and identity verification providers.
• Customer Support Providers.
• Risk management and anti-fraud providers.
• Joint Offering Partners.
• Publicly-available sources.
• Government agencies.

1.3       Information that We Collect About You from Social Networking Sites.

You can choose to log into our App, Website or Services through certain of your social media account(s) (e.g. Facebook, Google+, Twitter, Instagram, etc.), but to do so, you will be required to enter your social media account login information. If you choose to access our App, Website or Services in that way, we will obtain the information you make publicly available through that social media platform, which may include your name, profile picture, gender, user IDs, lists of contacts within the platform, dates of birth, email addresses, phone numbers or other information depending on the settings you have chosen on the social media platform. You may also choose to grant us information to non-public information in your social media account, and if you do so, we will have access to such information, even if you have chosen not to make that information public.

We store the information we receive from social media platforms with other information we collect from you in accordance with this Policy. The third-party social networking platform control the information they collect from you, and we do not have any control over how any third-party site uses or discloses the personal information it collects from you.  For information about how social networks may use and disclose your information, including any information you make public, please review their respective privacy policies. 

1.4       Information We Collect Automatically.

We automatically collect information about your use of our App and Website through cookies, web beacons, and other tracking technologies. The information we automatically collect will not identify you, but we may combine this automatically collected information with other information we collect about you, including your Personal Data. Please see the section <<Our Tracking Mechanisms>> below for more information on your options regarding these tracking mechanisms. The following list illustrates the information we collect automatically:

• When you access or use the Website we may collect:
  • The date and time you access the Website;
  • The name of the domain from which you access the Website;
  • The type of browser and operating system you use;
  • The type of device you use to access the Website;
  • The language in which you view the Website;
  • Which pages of our Website that you view;
  • How long you view each of those pages;
  • The links that you click on the Website;
  • Which search words lead you to our Website, and
  • If you have allowed the collection of location data from your device, your location. We may collect location data in several ways, such as through your wireless carrier, based on WiFi access point location, via Bluetooth beacons, through a connected device, or directly from the device on which you use the Services. We use that information to provide Services to you, including, but not limited to, showing you policy options available in your area; and
  • Photos and files that you upload through the Website;

• When you download or use the App we may collect:
  • The operating system/type of device you use to download and access the App;
  • The ID of the mobile device you are using or the name/model of the device you are using;
  • The language in which you use the App;
  • Which features and functionality you access in the App;
  • How long you use or view each of those features and functionality;
  • If you have allowed the collection of location information from your device, your location. We may collect location data in several ways, such as through your wireless carrier, based on WiFi access point location, via Bluetooth beacons, through a connected device, or directly from the device on which you use the Services. We use that information to provide Services to you, including, but not limited to, showing you policy options available in your area;
  • Photos and files that you upload to the App;
  • Information from your camera (with your permission); and
  • Links from other applications or websites that direct you to our Website or our App.

2.0       HOW WE USE YOUR INFORMATION

We use your information, including your Personal Data, for the following purposes:

• To provide our Services to you.
• To communicate with you about your use of our Services.
• To respond to your inquiries or otherwise provide customer service, technical support, or online services.
• To enable our vendors and suppliers to provide their services, such as underwriting, issuing and administering your policy(ies).
• To tailor the content and information that we display on the Website or through the App to your preferences. For example, we may display to you the different insurance policies available to you.
• To better understand how users access and use our App, Website, and Services, for purposes of improving our App, Website, and Services.
• To comply with our legal obligations.
• Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our <<Terms of Use>> or this Policy.
• To send promotional communications which are relevant and tailored to you, unless you have opted out of such communications.
• For other purposes with your consent or authorization.
• To take other legally permissible actions with regard to your Personal Data.

3.0       HOW WE SHARE YOUR INFORMATION

• Vendors/Service Providers – We may share your Personal Data with our affiliates, third party vendors, service providers, contractors or agents who are under contract to perform functions or services on our behalf.

• Business Transfers – If we are or may be acquired by, merged with, or invested in by another individual or company, requiring the transfer of our assets to another organization or where the Personal Data of our users is considered key to the transaction under consideration, we may transfer the Personal Data we have collected from you to the other individual or company.

• Marketing Partners – We may share your Personal Data with advertising and marketing partners for advertising and marketing purposes on our behalf and on behalf of third parties with whom we have agreements.
• In Response to Legal Process – We will comply with all legal proceedings and law enforcement requests. We may share your Personal Data to comply with the law, judicial proceedings, court orders and other legal processes.
• To Protect Us and Others – We may share your Personal Data when we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our <<Terms of Use>> or this Policy, or as evidence in litigation involving Olé.

• As You Allow – We may share your Personal Data for any purpose with your consent or authorization.

• De-Identified Information – We may share de-identified information about our users with third parties for marketing, advertising, research or any other legally permissible purposes.

4.0       OUR USE OF TRACKING MECHANISMS

We and our third-party service providers may collect information about your use of the App, Website, or Services using cookies and other tracking mechanisms such as web beacons, device IDs, advertising IDs, geolocation, HTML5 local storage, flash cookies, and IP addresses.  We may combine this information with other Personal Data we collect from you (and our third-party service providers may do so on our behalf).

4.1       Cookies

We use both “session cookies” that exist only during your online session and “persistent cookies” that remain on your device after you close your browser.  The cookies are used for personalization, performance/analytics, advertising, uniquely identifying you while you are using the Services, processing your online transactions and requests, enabling a faster log-in process, or allowing us to track your activity on the App, Website, or Services.  Third party vendors, including Google, may show our ads on sites across the Internet.  These third party vendors use cookies to serve ads based on your past visits to our Website.  Information about how you can opt out of Google’s use of cookies can be found by visiting Google’s privacy settings. 

Most web browsers automatically accept cookies, but you can edit your browser options to block cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies you will be able to browse the Website, but some features may not work properly unless cookies are enabled.

4.2       Cached Information

The App and Website automatically store small bits of information to the local data storage on your browser and mobile device about your use of the App and Website and your preferences (“Cached Information”). We use Cached Information to enhance your experience on our App and Website. If you log out of the Website, Cached Information stored on the browser will be deleted. If you delete the App from your device, Cached Information stored on the device will be deleted.

4.3       IP Address

An IP address refers to an identifier assigned by a network to a computer, mobile device, Internet of Things (IoT) device, or routing device. IP addresses, for purposes of this Policy, include “public” IP addresses, such as the IP address for a home router that is visible to the Internet, as well as “local” IP addresses, which are IP addresses assigned to computers and mobile devices “behind” a router (such as a home router). Our advertising and analytics partners may use IP addresses to group or correlate devices for purposes of analytics, security and anti-fraud purposes, interest-based advertising, ad targeting, ad attribution, and limiting ad frequency. If such IP address is provided through the use of cookies, you can choose not to have your IP address used in this manner by disabling cookies. 

4.4       Third Party Analytics

We use automated devices and applications to evaluate how our App and Website are used. We may use other methods to evaluate our App and Website. We use these tools to help us improve the performance of our App and Website and the user experiences with our App and Website. These devices and applications may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services.

4.5       Third-Party Data Collection

We may use third-party data collectors to record and store information about how our App and Website are used. These third-party service providers use tracking technologies to analyze a visitor’s real-time interactions with our App and Website, including for example, clicks, mouse movements, and data inputs. They then store such information on our behalf. We may provide these third-party data collectors with information, including Personal Data, about you.

4.6       Biometric Authentication

You may choose to enable biometric authentication (using fingerprint, Touch ID, or Face ID) to sign in to our Website or App. To do this, you are required to save your Olé account ID on your mobile device. We do not control the functionality of fingerprint, Touch ID or Face ID and we do not have access to your fingerprints or facial recognition information. You understand and agree that any fingerprint stored on your mobile device can be used to access your account at through our App. For more information on how biometric functionality works for your device, please refer to your device manufacturer’s support resources. There may be circumstances where biometric authentication will not function as expected and you will be required to sign in to your account using your passcode.

4.7       Do-Not-Track

We do not currently recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).

4.8       Third-Party Ad Networks

Third party vendors, such as, but not limited to, Google, may show our ads on sites across the Internet.  These third party vendors use cookies to serve ads based on your past visits to our Website.  These third-party cookies and other technologies are governed by each third-party’s specific privacy policy, not this one. Information about how you can opt out of a third-party’s use of cookies should be available in the third-party’s privacy settings. 

4.9       Google and Apple Services

While we endeavor to ensure the links in this section are up to date, but we cannot guarantee their accuracy or completeness.  Please refer to the providers policies directly.

(a)        Google.

Google provides a variety of services to Olé, including Firebase Real-Time Database and Authentication for new account generation and login; Google SDKs (Software Development Kits) to provide functionality in Android apps; and Google Health and Google Fit in Android apps, to help you track your nutritional and health information. Google’s privacy policy can be found here: https://policies.google.com/privacy.

Privacy terms for Google’s analytics and advertising services are governed by the separate Google Ads Data Processing Terms, available here https://privacy.google.com/businesses/processorterms/

We also recommend visiting https://myaccount.google.com/privacycheckup to review your current Google privacy settings.

(b)        Apple.

Apple provides a variety of services to Olé, including Apple – Sign-In & Authentication for the authentication and creation of new user accounts; Apple – Sync and Storage of App Data for iOS; and  Apple – HealthKit for the information that you choose to share with us.  Apple’s privacy policy can be found here: https://www.apple.com/uk/legal/privacy/.

Further information on Apple’s approach to privacy available here https://www.apple.com/uk/privacy/approach-to-privacy/.

5.0       LEGAL BASIS FOR PROCESSING

For purposes of this Policy, Olé is a Data Controller of your Personal Data. 

Our legal basis for collecting and using your Personal Data, as described in this Policy, depends on the particular information and the specific context in which we collect it. 

5.1       For the performance of a contract – We may use your Personal Data to perform our contractual obligations to you, including account registration, accepting and processing applications, providing insurance, processing claims, contacting you in relation to any of the Services you have purchased, where we need to provide your Personal Data to third parties in order to provide the Services, where we collect data from third parties or publicly-available sources, or to aggregate and centralize data for the performance of the Services.

5.2       To meet legal obligations – We may use your Personal Data to comply with laws, regulations, court orders, or other legal obligations to assist in an investigation.

5.3       For Our Legitimate Interests – We may use your Personal Data to operate our business and provide Services, other than in performing our contractual obligations to you. Examples include:

• Communication/Responding to Requests. Communicating with you regarding the Services and addressing your requests, inquiries, and complaints, including accessing your account to address technical support requests. You may not opt-out of these types of communications.
• Promotional Messages. We process your Personal Data to provide you with promotional messages and personalized marketing, including: when you communicate with us or sign up for promotional materials; when you participate in special activities, offers, or programs; when you engage with our online communities or advertising; to provide you geographically relevant Services, offers, or advertising; when we aggregate and centralize data; and when we share Personal Data with companies or ventures that are owned or controlled by us and with our service providers and vendors.
• Surveys. We may use your Personal Data to send you surveys in connection with our Services, unless commercial in nature. In cases of commercial surveys, a survey request may be sent to you if you have given us your consent to receive marketing from us.
• Compliance with Law and Public Safety. We may use your Personal Data to assist in the investigation of suspected illegal or wrongful activity, including in-store tracking and sharing information with other entities for fraud, loss, and crime prevention purposes. To protect and defend our rights and property, or the rights or safety of third parties.
• Improvement and Development. We may use your Personal Data to develop, provide, enhance, and improve our Services and your experience. We may use your Personal Data for internal purposes related to certain research, analytics, innovation, testing, monitoring, customer communication, risk management, and administrative purposes.
• Enforcing Terms and Notice. We may use your Personal Data to enforce our <<Terms of Use>> or this Policy, or agreements with third parties.
• Merger or Acquisition. We may use your Personal Data to support a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction.

5.4       Consent as a Basis for Processing.  In some cases, we will ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including by ticking a box (or equivalent action) or signing or speaking your name, as it may be applicable, when (i) providing us with your Personal Data through our App, Website, or Services; or (ii) registering or creating an account with us.

Such consent will be used to process data collected by us by phone or video conferencing, including any telehealth.. We may request your consent for a number of activities including:

• Marketing and Communication. We may ask for your consent to contact you by telephone, text message, and/or email about other offers, products, promotions, events, or services that we think may be of interest to you and for other marketing purposes.
• Sharing with Third Party Services. We may ask for your consent to share your Personal Data with certain third party business partners in order for them to offer certain goods, services, or programs.
• Collecting Mobile Device IDs, Advertising IDs, and Data from Sensors. When you use our App, Website or Services we may ask for your consent to collect this data, and this consent is often captured at the operating system level on your device. To change your consent status for this information please go to the preferences of the specific device. If you choose not to provide this information, certain Services features may be unavailable or not function properly.
• Processing Sensitive Personal Data. We may request your consent to process sensitive Personal Data in conjunction with evaluating your application for insurance coverage or providing other Services. If you choose not to provide sensitive Personal Data, the Services or certain options within the Services may not be available to you.
• Collecting and Sharing Location Data. We may request your consent to collect your precise location data. Our Services may require this data to provide the Services and location data may be used to display your live location and movement and to provide you with tailored information and advertising about products and services. If you choose not to provide this information, certain Services features may be unavailable or not function properly.
• Research. We may request your consent to use your Personal Data for research purposes. We may also request your consent to contact you to determine your interest to participate in certain research initiatives and to share identifying results. For market research, we may ask questions on behalf of business partners and share your response with business partners. Your consent is not required to use your de-identified Personal Data for research purposes.
• Advertising. We use cookies, pixels (including email pixels), mobile device and advertising IDs, location data, app or service usage data and data from sensors for purposes of interest-based and cross-app, cross-device advertising. The consent for which may be managed at the operating system level.
• Automated Processing. To provide you with valuable personalized advice, recommendations and experiences, we may process your personal information using automated and manual (human) methods. Our automated methods include artificial intelligence (AI) and a range of technologies that help our services learn and reason to improve our ability to personalize and enhance your experience with our Services.
• Social Media. We may ask for your consent when you connect with us through social media.
• Promotions. We may ask you for permission to use your Personal Data for special offers, events, sweepstakes, and other promotions. We may use the Personal Data we collect during promotions, to administer the promotion, verify identity and age, and to communicate with you about the promotion.

6.0       Changing Your Sharing Preferences / Withdrawing Consent

Details on how to update your sharing preferences and the default settings for our Services are outlined here.  As a data subject, you have the right to control the use of your Personal Information including the following rights:

6.1       Requests to access, update or delete your Personal Data/ Requests for Correction. 

You may request that we provide you with a list of the types of Personal Data (a) that we have stored about you, (b) that we update or correct any of the Personal Data that we have stored about you, or (c) that we delete the Personal Data we have stored about you.

We will not delete your Personal Data if it is necessary for us to (a) complete the transaction for which we collected your Personal Data, (b) or take actions reasonably anticipated with the context of our ongoing business relationship with you, (c) detect security incidents or protect against malicious, deceptive, fraudulent or illegal activity or prosecute those responsible for such actions, (d) debug products to identify and repair efforts, (e) exercise free speech, (f) comply with our legal obligations, (g) enable solely internal uses that are reasonable aligned with consumer expectations based on our relationship with you, (h) make other internal and lawful uses of that information that are compatible with the context in which you provided it.  We will not delete your Personal Data or make changes to it if we cannot verify the request, or if doing so would preclude us from meeting our legal or contractual obligations.

6.2       Objections to Processing or Requests to Restrict Processing.

You may object to our processing of your Personal Data or ask us to restrict the processing of your Personal Data. Such an objection will not preclude us from processing your Personal Data in order to provide the Services you have purchased unless you cancel those Services. If we have a legal obligation to process your Personal Data, your objection or request for restriction will not prevent us from processing your Personal Data. 

6.3       Requests for Portability/Copies.

You may request that we make your information portable and provide it to you in a form that can be accessed by others.

6.4       Withdrawal of Consent.  If we have collected or processed your Personal Data on the legal basis of consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on another legal basis.

6.5       Requests to Manage your Communication, Marketing or Privacy Preferences.

You may update your communication or marketing preferences or privacy settings at any time in your account settings. Alternatively, you may contact us as provided below. However, you may not opt out of communications necessary to provide you with the requested Services or to meet our legal obligations.

To exercise any of the  rights in this Section 6, you must send us a verifiable request so that we can confirm your identity before taking the requested action. If we are unable to verify your request, we will not be able to provide you with your data rights until you are able to provide us the appropriate documentation.  Any of these rights may be exercised through your personal account settings.  You are not required to submit the requests or changes through your account, but we do consider requests from your account to be verified.

7.0       USER GENERATED CONTENT

We may allow you to post public content on the App or on the Website. All information you post will be available to all registered users on our App and Website. Once posted, other users may copy and redistribute your posting, and Olé is not responsible for your post being used in a manner that may violate this Policy, the law, or your personal privacy. Please carefully consider the content of any messages or reviews that you post to the App or Website.

8.0       THIRD-PARTY LINKS

The App and Website may contain links to third-party websites or apps. Any access to and use of such linked websites and apps is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites, and recommend you review their individual privacy policies before using their services. 

9.0       SECURITY OF YOUR PERSONAL DATA

We utilize reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. However, you should know that the transfer of information via the internet and storage of information in electronic format can never be completely secure, no matter the security measures that are used. 

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a unique password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account that is a result of unauthorized password activity.

10.0     CHILDREN UNDER 18

Our Services are not designed to be used by children under 18. If we discover that a child under 18 has provided us with Personal Data, we will delete such information from our systems.

11.0     HOW LONG YOUR DATA IS KEPT

Personal Data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. Different retention periods apply for different types of data. Personal Data will be retained:

• As long as needed to provide you with the Services you purchase;
• To the extent that we are required to do so by law;
• If we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
• In order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and risk reduction).

12.0     CONTACT US

If you have questions about the privacy aspects of our App, Website, or Services or if you wish to submit any requests or objections related to our processing of your Personal Information, please contact us at: 

954 PONCE DE LEON AVENUE, SUITE 802

SAN JUAN, PR 00907

Or by email at: [email protected]

13.0     CHANGES TO THIS POLICY

This Policy is current as of the Effective Date listed above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our App and Website. If we make any substantial changes to this Policy regarding how we use the Personal Data that we have already collected, we will do our best to provide you with advance notice of such changes by highlighting the changes on our App and Website.