WEBCON PTY LTD (trading as WWEBCON) (“WWEBCON”, “we”, “us” or “our”) acts as an administrator and intermediary in relation to international private medical insurance and associated services.
We are not an insurer or underwriter. Insurance cover, underwriting decisions, policy terms, claims decisions and insured benefits remain subject to the terms and decisions of the relevant insurer, underwriter or appointed service provider.
This notice explains how WWEBCON collects, uses, stores and shares personal information when you use our website, request an illustration or quotation, make an enquiry, become a client, use the client portal, or ask us to assist with the administration of your cover.
Our approach is to collect what is reasonably required for the purpose concerned, use it for that purpose, and limit access to those who need it.
The data controller responsible for the processing described in this notice is:
WEBCON PTY LTD (trading as WWEBCON)
P.O. Box 36
Gaborone
Botswana
For data-protection and compliance matters only:
compliance@wwebcon.com
This address is reserved for privacy, data-protection and compliance matters. We aim to acknowledge or respond to enquiries submitted to this address within 14 days. Where applicable law prescribes a different period for exercising a legal right or responding to a formal request, the applicable statutory period takes precedence.
Our ordinary business correspondence details are not published through this notice. Where you make an enquiry through the website and verify your email address, the appropriate correspondence details are provided directly to that verified address.
You can obtain a working illustration without initially providing your full identity.
Depending on the product or illustration concerned, the information used at this stage may include:
age;
country of residence;
Area of Cover;
level of cover;
deductible;
billing frequency; and
benefit or product options selected.
A working illustration is not a formal quotation, an offer of insurance or confirmation that cover will be available.
If you want WWEBCON to proceed with an enquiry or official quotation, we require a valid email address so that the enquiry and communication address can be verified.
A mobile number may be requested or provided but is not compulsory at the initial enquiry stage unless required for a particular process.
Where email verification is required, a verification code is sent to the email address supplied.
Successful verification establishes that the person completing the process had access to the email address at the time of verification. It does not, by itself, establish the person’s legal identity.
WWEBCON may retain an evidential record associated with the enquiry, including:
the email address supplied;
date and time of submission;
date and time of successful verification;
enquiry reference;
confirmation that the required enquiry consent was selected;
the version of the consent wording presented;
the applicable version of this Privacy & Data Protection Notice; and
the applicable version of the Website Terms of Use.
Authentication codes do not need to be retained after their operational purpose has ended.
Where you ask WWEBCON to contact you about an enquiry, the permission you provide relates to that enquiry and any quotation, application or subsequent administration you ask us to proceed with.
Submitting an enquiry does not subscribe you to marketing communications or a newsletter.
The information supplied for an enquiry will not be treated as permission to contact you later for unrelated promotional purposes.
If you ask WWEBCON to proceed to a formal quotation, application or client relationship, additional information may be required.
Depending on the circumstances, this can include:
full name and identifying information;
date of birth;
nationality;
residential or correspondence address;
email address;
telephone number;
dependant or family-member information;
employer or group information where relevant;
insurance requirements and cover selections;
previous insurance information;
insurer or underwriter application information;
policy and membership information;
invoices and payment or reconciliation information;
correspondence and instructions;
emergency-contact information;
application forms;
supplementary questionnaires;
claims information;
supporting documents; and
medical and health information.
The information required depends on the service, insurer, underwriter, application, claim or administrative process concerned.
International private medical insurance can require information concerning health, medical history, treatment, medication, claims and other matters of a sensitive nature.
Medical and health information is treated as sensitive or special-category information where applicable law provides for that classification.
WWEBCON processes this information only where it is reasonably required for a relevant insurance, underwriting, claims, assistance or administrative purpose and where an appropriate legal basis and any additional condition required for sensitive information apply.
Depending on the matter, medical information may need to be provided to or received from an insurer, underwriter, medical assessor, claims administrator, medical-assistance provider, healthcare provider or another authorised party involved in the relevant insurance process.
Information entered under the emergency-information section of the client portal is separate from information supplied for an insurance application, underwriting or claim. Updating emergency information does not amend a previous medical disclosure to an insurer or underwriter and does not replace any disclosure the client may be required to make to them.
WWEBCON may process personal information where reasonably necessary to:
provide illustrations and quotations;
respond to enquiries;
verify communication details;
assist with applications;
communicate with insurers, underwriters and relevant service providers;
establish and administer insurance arrangements;
maintain client and membership records;
administer renewals and requested changes;
issue or maintain client documents;
administer invoices and reconcile payments;
assist with claims and treatment administration;
assist with emergency or medical-assistance processes;
maintain emergency-contact and emergency-card information where supplied;
respond to client instructions;
maintain correspondence and evidential records;
investigate complaints, errors or disputes;
protect WWEBCON’s systems and information;
prevent or investigate unauthorised access, misuse or fraud;
comply with applicable legal or regulatory requirements;
establish, exercise or defend legal rights; and
maintain records reasonably required for the administration and history of the client relationship.
Personal information collected for one purpose will not be used for an unrelated purpose merely because WWEBCON possesses it.
The legal basis applicable to processing depends on the information, purpose and law concerned.
Depending on the circumstances, processing may be necessary:
to take steps requested before entering into an insurance or service arrangement;
to perform or administer an existing arrangement;
for WWEBCON’s legitimate administrative, security, compliance or evidential interests where those interests are not overridden by applicable individual rights;
to comply with a legal or regulatory obligation;
with consent where consent is the appropriate basis; or
for another lawful ground recognised by the legislation applicable to the particular processing.
Where medical or other sensitive information is processed, WWEBCON will also rely on an additional condition permitting that category of information to be processed where applicable law requires one.
Consent is therefore not represented as the legal basis for every activity WWEBCON performs.
Where processing specifically depends on consent, withdrawal of that consent will apply prospectively and will not make processing already lawfully undertaken invalid.
WWEBCON does not sell personal information.
Information may be disclosed where reasonably necessary to organisations or persons involved in the service or transaction concerned, including:
insurers;
underwriters;
insurance administrators;
medical assessors;
claims administrators;
assistance providers;
healthcare providers;
employer or group-scheme administrators where relevant;
professional advisers where reasonably required;
authorities or regulators where disclosure is legally required; and
technology and infrastructure providers used to operate, secure, communicate or store WWEBCON information.
A recipient should receive only the information reasonably required for its role or the relevant purpose.
International private medical insurance is inherently cross-border. A client may live in one country, obtain cover from an underwriter in another, receive treatment in another and require assistance from a service provider elsewhere.
Personal information may therefore be processed or transferred outside the country in which it was originally collected.
Technology infrastructure may also involve processing or storage in other countries.
Where a transfer is subject to data-protection requirements governing international transfers, WWEBCON will use the mechanism or safeguards applicable to that transfer and the circumstances concerned.
We do not represent that every country provides identical privacy protection. The safeguards available and the legal requirements applicable to a transfer may differ according to the countries and organisations involved.
WWEBCON uses technical and organisational measures intended to protect personal information against unauthorised access, alteration, disclosure, loss or destruction.
The safeguards used depend on the information, system and stage of processing concerned and may include controlled access, authentication, protected devices, encrypted connections, secured hosting, access restrictions and protected cloud or local storage.
WWEBCON maintains internal procedures dealing with record retention, access, information incidents and the handling of sensitive information.
No internet, email, cloud or computer system can be represented as completely immune from compromise. Security measures are therefore reviewed against the nature of the information, the systems used and the risks reasonably associated with the processing.
WWEBCON does not apply a single retention period to every type of information.
Information is retained according to its purpose, sensitivity, continuing administrative or evidential relevance, applicable contractual requirements and any legal or regulatory obligation.
As a general framework:
an uncompleted or unverified enquiry should have a short operational retention period;
a verified enquiry that does not progress may be retained for a limited period together with an appropriate verification and consent record;
a formal quotation or application may justify longer retention because it forms part of a substantive insurance transaction;
active-client records are retained while required to administer the relationship;
former-client records may be retained where reasonably required to establish the history of the insurance relationship, previous disclosures, instructions, administration, claims, complaints or other matters;
medical and claims information is reviewed according to its continuing purpose and sensitivity rather than retained indefinitely merely because storage is available;
financial and accounting information may be retained for an applicable statutory or business-record period; and
records relevant to a complaint, investigation, claim, dispute or legal proceeding may be retained while the matter remains active and for an appropriate period afterwards.
Where continued identification is no longer necessary but statistical or operational information remains useful, WWEBCON may anonymise information rather than retain an identifiable record.
Clients should provide information that is accurate and complete to the best of their knowledge and should notify WWEBCON where relevant contact or administrative information changes.
WWEBCON may correct ordinary administrative information where an error is established.
Where information concerns a substantive insurance, medical, underwriting or claims disclosure, WWEBCON will not silently alter the record on assumption.
Where WWEBCON identifies information that appears inconsistent or incomplete, we may ask you to confirm it rather than altering substantive insurance or medical information on assumption.
The responsibility for disclosure under an insurance application or policy remains subject to the terms of that application or policy.
Historical information held by WWEBCON may be used to draw a previous disclosure or administrative fact to a client’s attention, but a previous medical answer will not automatically be treated as a new or current declaration.
Your rights depend partly on the data-protection law applicable to the particular processing.
Where applicable, you may have rights to:
ask whether we hold personal information about you;
obtain access to that information;
request correction of inaccurate or incomplete information;
request deletion where there is no lawful reason for continued retention;
request restriction of particular processing;
object to particular processing;
withdraw consent where processing depends on consent;
request information about recipients or categories of recipients;
request information concerning relevant international transfers; and
complain to an applicable data-protection or supervisory authority.
These rights are not absolute. A request to delete information, for example, does not require WWEBCON to destroy information that it is legally required or otherwise lawfully entitled to retain.
Privacy and data-protection requests may be sent to:
compliance@wwebcon.com
We may take reasonable steps to verify the identity of the person making a request before releasing, changing or deleting personal information.
Submitting an enquiry, requesting an illustration or quotation, becoming a client or using the client portal does not by itself subscribe you to marketing communications.
If WWEBCON introduces a newsletter or similar optional publication, subscription will be separate from the insurance enquiry and administration process.
Where consent is required, the subscription mechanism will require a separate positive choice and will provide a means of withdrawing from future communications.
Choosing not to receive a newsletter or other optional marketing communication will not affect an insurance enquiry, application or existing cover.
Email addresses can be entered incorrectly and messages can occasionally be directed to an unintended recipient.
If you receive a WWEBCON communication that you reasonably believe was not intended for you, you should not use or distribute information concerning another person contained in that communication.
Please notify us using the contact information contained in the message, where available, or through the website contact form so that the matter can be investigated and appropriate action taken.
Receipt of an unintended communication does not enrol the recipient in any marketing or continuing-contact programme.
WWEBCON does not use cookies on wwebcon.com or in the WWEBCON client portal. No analytics service, advertising network, tag manager or tracking pixel is used, and WWEBCON does not track visitors across other websites.
The client portal uses storage on the device being used to provide portal functions, maintain relevant client information and support authentication. Where the portal is installed as an application, browser caching also allows parts of the portal to remain available without an internet connection.
Information held on a device remains subject to the security of that device. Clients should sign out when using a device they do not control and should remove stored site or application data before disposing of, transferring or permanently ceasing to use a device.
Where device-based biometric authentication is enabled, the biometric check is performed by the device. WWEBCON does not receive or store the client’s fingerprint, facial image or other biometric data. The device returns only the authentication result required to complete the sign-in process.
The website is hosted by a third-party hosting provider. The hosting infrastructure may generate technical records associated with requests made to the website, including information such as IP addresses, request times and browser or device information. Those records are processed as part of operating, securing and maintaining the hosting service.
WWEBCON does not use technical information generated for the operation, security or authentication of the website as permission to send marketing communications.
This section describes the website implementation in force when this notice was prepared. If cookies, analytics, advertising technologies or other material tracking technologies are introduced, the privacy information and any consent mechanism required by applicable law will be reviewed before those technologies are enabled.
The website may use information entered by you to calculate or display indicative figures, apply eligibility rules, validate fields or determine which information is displayed.
An automated illustration is not an underwriting decision and does not confirm that insurance will be offered.
Formal cover remains subject to the applicable quotation, application, underwriting requirements, policy terms and acceptance by the relevant insurer or underwriter.
WWEBCON maintains an internal process for assessing and responding to actual or suspected incidents involving personal information.
Where an incident occurs, WWEBCON will assess the information involved, the circumstances of the incident, the potential consequences and any notification or other action required under the data-protection law applicable to the particular processing.
The existence of an information incident does not automatically mean that every affected person or authority must be notified. Notification will be determined according to the applicable legal requirements and the circumstances and risk of the incident.
WWEBCON may update this notice where our services, systems, legal obligations or information-handling practices change.
The current version will carry its effective date.
A material change affecting the way existing client information is processed will be communicated where required or where the nature of the change makes direct communication appropriate.
WEBCON PTY LTD (trading as WWEBCON) is established in Botswana and processes information in connection with an international client base and international insurance arrangements.
The data-protection law applicable to particular processing may depend on the establishment involved, the location and circumstances of the individual, the services concerned and the reach of the relevant legislation.
This notice is intended to establish a consistent privacy standard across WWEBCON’s operations. It does not state that the law of every country from which the website can be accessed automatically applies to WWEBCON, nor does it exclude rights that an individual has under legislation that does apply to the particular processing.
For a quotation or ordinary insurance enquiry, please use the contact process provided through the website or the correspondence details supplied to your verified email address.
For a privacy, data-protection or compliance matter relating to this notice:
compliance@wwebcon.com
This compliance address is not an alternative route for quotations, policy administration or general enquiries.
WEBCON PTY LTD (trading as WWEBCON) aims to acknowledge or respond to correspondence sent to this address within 14 days. Where applicable legislation imposes another response or notification period, that statutory requirement takes precedence.