Privacy Policy

1. Introduction

Comfort Insurance ("We", "Us", "Our") respects your privacy and is committed to protecting your personal information in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA") and other applicable South African laws.

This Privacy Policy applies to personal information processed by Comfort Insurance in connection with our funeral cover products, intermediary services, website, customer communications, and claims support.

By using our website, submitting your information, applying for cover, or communicating with us, you acknowledge that you have read and understood this Privacy Policy.

2. Personal Information We Collect

We collect personal information that is reasonably necessary for us to provide insurance-related services, verify identity, administer policies, support claims, comply with legal obligations, and communicate with you.

The information we may collect includes:

• Full name, identity number, passport number, date of birth, gender, and nationality
• Contact details, including physical address, email address, and telephone number
• Employment, income, affordability, and payment information where required
• Banking details and debit order information for premium collection or claim payments
• Policy information, plan selections, beneficiaries, dependants, and covered family members
• Claims information, including death certificates, medical reports, proof of relationship, and supporting documents
• Website usage information, device information, IP address, browser type, and cookie data
• Records of enquiries, complaints, calls, forms, emails, WhatsApp messages, or other communications with us

3. Special Personal Information

In certain cases, we may process special personal information, including health, medical, biometric, or death-related information, where it is necessary for underwriting, policy administration, claims assessment, fraud prevention, or compliance with legal and regulatory duties.

We will only process special personal information where POPIA allows us to do so, where you have given consent, where it is necessary for insurance purposes, or where another lawful basis applies.

4. How We Collect Information

We may collect personal information directly from you or from authorised third parties. Sources may include:

• Online forms, quote requests, policy applications, and claim submissions
• Telephone calls, emails, WhatsApp messages, and in-person communications
• Identity documents, supporting documents, and information you provide to our representatives
• Underwriters, insurers, reinsurers, administrators, payment providers, and verification providers
• Public or official sources where legally permitted, including regulatory or government databases
• Website analytics tools and cookies when you use our website

5. Why We Use Your Information

We use personal information only for legitimate, lawful, and necessary purposes connected to our services. These purposes include:

• Responding to enquiries and providing quotations
• Assessing, processing, and submitting insurance applications
• Arranging, administering, servicing, amending, and cancelling policies
• Collecting premiums and processing debit orders or other payments
• Verifying identity, banking details, eligibility, beneficiaries, and relationships
• Submitting, facilitating, assessing, validating, and paying claims
• Communicating policy information, notices, renewal information, and service updates
• Detecting, preventing, and investigating fraud, unlawful activity, or misuse of our services
• Handling complaints, disputes, regulatory enquiries, and legal processes
• Meeting our duties under insurance, financial services, tax, anti-money laundering, and data protection laws
• Improving our website, products, service quality, customer support, and internal operations

6. Lawful Basis for Processing

We process personal information where one or more lawful grounds apply under POPIA, including:

• You have consented to the processing
• Processing is necessary to conclude or perform a contract with you
• Processing is required to comply with a legal obligation
• Processing protects your legitimate interests or the legitimate interests of another person
• Processing is necessary for our legitimate business interests, provided your rights are not unjustifiably affected

7. Sharing of Personal Information

We do not sell your personal information. We may share personal information only where necessary, lawful, and relevant to the services we provide.

Your information may be shared with:

• Insurers, underwriters, reinsurers, and policy administrators
• Claims assessors, medical practitioners, funeral service providers, and verification providers
• Banks, payment processors, debit order providers, and collection service providers
• Technology, hosting, analytics, customer support, and document management providers
• Professional advisers, auditors, legal representatives, and compliance consultants
• Regulators, ombuds, law enforcement agencies, courts, and government authorities where required by law

Where we appoint service providers to process personal information on our behalf, we require them to protect that information and use it only for the authorised purpose.

8. Cross-Border Transfers

Some of our service providers, systems, or technology partners may store or process information outside South Africa. Where personal information is transferred across borders, we will take reasonable steps to ensure that appropriate safeguards are in place and that the information remains protected in accordance with POPIA.

9. Cookies and Website Technologies

Our website may use cookies and similar technologies to operate the site, remember preferences, improve performance, understand visitor behaviour, and support security. A cookie is a small file placed on your device when you visit a website.

You can usually adjust your browser settings to block or delete cookies. If you disable cookies, some parts of the website may not function as intended.

Where required, we will request your consent before using non-essential cookies or similar tracking technologies.

10. Direct Marketing

We may use your contact details to send you information about our products, services, policy updates, or related offers where permitted by law or where you have consented to receive such communications.

You may opt out of direct marketing at any time by using the unsubscribe method provided in the communication or by contacting Comfort Insurance directly. We will not send you further direct marketing once you have opted out, unless you later consent again.

11. Security of Personal Information

We take reasonable technical and organisational measures to protect personal information against loss, unauthorised access, interference, misuse, disclosure, alteration, or destruction.

These measures may include access controls, password protection, secure storage, staff confidentiality obligations, system monitoring, secure document handling, and restrictions on who may access personal information.

No method of electronic storage or transmission is completely secure. If we become aware of a data breach that affects your personal information, we will take appropriate steps in accordance with POPIA and applicable law.

12. Retention of Personal Information

We retain personal information only for as long as necessary for the purpose for which it was collected, or for as long as required or permitted by law, regulation, contract, complaints handling, claims administration, audit, or record-keeping duties.

When personal information is no longer required, we will take reasonable steps to delete, destroy, de-identify, or securely archive it.

13. Your Rights

Subject to POPIA and applicable law, you have the right to:

• Ask whether we hold personal information about you
• Request access to your personal information
• Ask us to correct or update inaccurate, incomplete, or outdated information
• Object to certain processing of your personal information
• Withdraw consent where processing is based on consent
• Request deletion or destruction of personal information where legally permitted
• Submit a complaint to the Information Regulator of South Africa

We may need to verify your identity before processing any privacy-related request. Some requests may be limited by legal, regulatory, contractual, or insurance record-keeping obligations.

14. Accuracy of Information

You are responsible for ensuring that the personal information you provide to us is accurate, complete, and up to date. Please notify Comfort Insurance as soon as reasonably possible if your contact details, banking details, beneficiary details, dependant details, or other relevant information changes.

15. Children's Information

We may process information relating to children where they are listed as covered members, dependants, or beneficiaries under a policy, or where the information is required for claims administration. We will process children's information only where lawful and necessary, and with appropriate care.

16. Complaints

If you believe that your personal information has been processed unlawfully, or if you are dissatisfied with how we handled a privacy request, please contact Comfort Insurance first so that we can try to resolve the matter.

You may also lodge a complaint with the Information Regulator of South Africa:

• Website: inforegulator.org.za
• Email: complaints.IR@justice.gov.za

17. Changes to This Privacy Policy

Comfort Insurance may update this Privacy Policy from time to time to reflect changes in our services, website, legal requirements, regulatory guidance, or operational practices.

The most current version of this Privacy Policy will be available on our website at comfortinsurance.co.za/privacy-policy. Where required, we will take reasonable steps to notify you of material changes.

18. Contact Us

If you have any questions about this Privacy Policy, want to exercise your privacy rights, or need to update your personal information, please contact Comfort Insurance:

• Website: comfortinsurance.co.za