AAR’s Privacy Centre
This Privacy Policy outlines how we collect, use, disclose, and protect personal information in connection with our services, including processing your medical and general insurance covers.
- Prospective policyholders their dependents and/or next of kin
- Policyholders and their dependents and/or next of kin
- Visitors to the company premises
- Website/Mobile App Users
Personal data may also include sensitive information, such as racial or ethnic origin, religious beliefs, health information (such as medical history), family information including children’s information, biometric data (such as fingerprint data collected when processing a health claim), property records, financial information (such as bank account details or statements of account, utilisation reports, premiums payable etc).
Subject to applicable law and practice, the categories of Personal Data that are typically collected and processed are: –
| Category of data subject | Type of personal data collected | |
| Prospective Policyholders (Medical and Non-Medical) | Identification details: Name of the proposer,ID/Passport, gender, nationality, marital statusContact details: telephone number, email address postal address, postal code. | |
| Medical Insurance Details: – o Information contained in the Membership Application form i.e., current permanent address, KRA PIN, occupation/nature of business, source of income, spouse and dependents details i.e., name, date of birth, height, and weight, confidential medical history, | cover option, weight and height, Next of kin details i.e., relation with applicant. o Information contained in quotations. o Medical Tests: data revealing past, present or future state of physical or mental health of an individual (for prospective members above 45 years with underlying medical conditions) o Reasons for disapproving prospective member(s)’ application. o Information contained in the List of members(for Corporate Clients and SME’s employees) | |
| Non-Medical Insurance: – o Information contained in Non-Medical Insurance Application Forms such as travel insurance, personal accident, home insurance, professional indemnity, Landlord Insurance. o Information contained in quotations. | ||
| Passport photos | ||
| Correspondence: Email/Phone calls/SMS | ||
| Online identifiers i.e., Cookies and IP addresses | ||
| CCTV footage (when you visit our premises) | ||
| Policyholders (Medical and Non-Medical) | Identification details: Name of the proposer,ID/Passport, gender, date of birth, nationality.Contact details: telephone number, email address postal address, postal code. | |
| Medical Insurance Details: – o Information contained in Member Application form: current permanent address, KRA PIN Occupation/Nature of business, source of income, spouse and dependents such | ||
| as name, date of birth, height, and weight, confidential medical history, and next of kin details such name, contact details and relationship to the applicant.o Information contained in list of members (Corporate and SME’s employees) o Information contained in medical policy covers o Claims details: pre-authorisation, admission and treatment details i.e., membership number, diagnosis and treatment notes, prescription, biometrics (like fingerprints) attending doctor’s name and signature. o Medical Cards o Scheme renewal details: information contained in scheme renewal forms, Copies of children’s birth certificates, proof of guardianship. o Information required to reimburse members i.e., invoices, treatment notes, diagnosis. | ||
| Non-Medical Insurance: – o Information contained in non-medical insurance forms such as Travel insurance, Home Insurance, Personal Accident forms,Professional Indemnity, Landlord Insurance o Information contained non-medical insurance policy covers. o Claims details: nature of claim, investigation results, claims payment details, reasons of disapproving claims and adjustment of payment details. o Policy covers renewal details. | ||
| • Payment details: KRA PIN, bank account details, premiums payable, information contained in cash receipts and invoices. • Information required to onboard members to the wellness program i.e., confidential medical history. • Passport Photos. • Customer complaints/Queries/ Complaints submitted through email, phone calls or through the website, social media or mobile app. • Online identifiers such as cookies and IP addresses • CCTV footage (when you visit our premises) | ||
| Agents and Brokers | Please refer to the Agents and Brokers Privacy Policyview policy | |
| Third-party Service Providers (Medical Service Providers, Loss Assessors, Loss Adjusters, Investigators) | Please refer to Third Party Service Providers PrivacyPolicy | |
| Job Applicants | Please refer to the Job Applicants Privacy Policy | |
| Office Visitors | • Contact details: phone number. • Identification details: name, ID, car registration number • CCTV records • Complaints/requests | |
| Website/App Users | • Identification details: name, date of birth, ID/Passport • Contact details: phone number/email address. • Information contained in online medical and nonmedical forms (when you apply insurance cover through our website or Mobile App) | |
| Online identifiers such as cookies and related tags, IP addresses | ||
| Category of Data Subject | How we Collect Your Personal Data | Purpose of Collection | Lawful Basis for Collection |
| Prospective Policyholders |
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For example, if you are a prospective policyholder and you do not provide contact details or other necessary information, we may not be able to effectively communicate with you, provide relevant product information, or process your inquiries. Similarly, if you are a policyholder and fail to provide required identification or payment details, it may hinder our ability to fulfil contractual obligations or complete necessary financial transactions.
We encourage you to carefully consider the personal data requested and its importance for the intended purposes. If you have concerns about providing certain information, please contact us to discuss your specific circumstances and requirements.
We may share your personal data with third parties in the following circumstances:
- Service Providers: We may engage third-party service providers to perform various services on our behalf, such as our medical claims providers i.e. MTIBA and SMART, medical service providers, accountants, actuaries, loss assessors/adjusters, claims investigators, auditors, outsourced legal service providers, travel agencies, re-insurance service providers, call center service providers; IT systems support and hosting service providers, printing, advertising, marketing and market research and analysis service providers; banks and financial institutions that service our accounts, document and records management providers, construction consultants, engineers and document storage providers. These service providers will have access to your personal data as necessary to perform their functions but are strictly prohibited from using your personal data for any other purposes.
- Business Partners: We may share your personal data with trusted business partners who collaborate with us to provide products or services to you. These partners may use your personal data only for the purposes specified in our agreement with them.
- Legal Obligations: We may disclose your personal data if required to do so by law or in response to a valid legal request, such as a court order or government inquiry or with insurance regulators, tax auditors or other authorities when we believe in good faith that the law or other regulations requires us to share this data.
- Corporate Transactions: In the event of a merger, acquisition, or any form of corporate restructuring, we may transfer your personal data to the involved parties, if they agree to treat your personal data in accordance with this privacy policy and data protection laws.
- Consent: We may share your personal data with third parties if you have given us explicit consent to do so. You have the right to withdraw your consent at any time.
We carefully select and evaluate third-party service providers, business partners, and other recipients of your personal data. We enter into contractual agreements with these parties, imposing obligations to protect your personal data and restricting their use of the information solely for the specified purposes outlined in our agreement. Furthermore, we require these third parties to implement appropriate technical and organisational measures to prevent unauthorised access, disclosure, alteration, or destruction of your personal data.
- Technical Safeguards: To protect your information during transmission, we utilise industry-standard encryption protocols, ensuring the confidentiality of your data. Our secure network infrastructure incorporates firewalls, intrusion detection systems, and other security measures to prevent unauthorised access and mitigate external threats. Additionally, access controls are in place, restricting data access to authorised individuals through unique user credentials, strong passwords, and role-based privileges. Regular data backups and recovery processes are performed to maintain data integrity and availability.
- Organisational Safeguards: Our commitment to data security extends to our employees and third-party service providers. Strict confidentiality agreements bind them, emphasising the importance of maintaining the security and confidentiality of your personal data. Regular training programs are conducted to educate employees on data protection best practices, security protocols, and their responsibilities. Access controls and authorisation mechanisms ensure that only authorised personnel can access your data. We have established comprehensive data protection policies and procedures to guide the proper handling, storage, retention, and disposal of personal data. In the event of any security incidents, our incident response plan enables swift identification, mitigation, and notification, as well as measures to prevent future occurrences.
If you suspect any misuse or loss of or unauthorised access to your personal data, please let us know immediately by sending us an email privacy@aar.co.ke
Once the retention period expires, we securely delete or anonymise your data to ensure it is no longer identifiable or accessible.
The retention periods for each category of data subjects and their respective personal data may vary based on the specific circumstances and legal requirements. Here are some general guidelines regarding data retention:
- Prospective Policyholders: We retain your personal information as outlined in Clause 5 of this Privacy Policy period of two (2) years from the date of collection or until consent is withdrawn. This allows us to maintain effective communication, improve our marketing strategies and fulfil the purposes outlined in this Privacy Policy.
- Policy holders: We retain your personal information as outlined in Clause 5 of this Privacy Policy for the duration of your policy with AAR and seven (7) years thereafter. However, such retention may be subject to any legal or regulatory requirements, further processing historical, statistical, journalistic, literature, art or research purposes or any you give consent for longer retention periods. Where we collect information based on consent, we retain your information until you withdraw your consent.
- Website User and Visitors to the Company premises: If you are a Website/Mobile App User or a visitor to the company premises, we will retain your personal data for as long as it is necessary which duration, we have determined to be one (1) year to achieve the purpose stipulated in clause 6. If this time has come or you have expressly indicated that you are not interested in our website or mobile app services anymore, we will delete it from our systems unless we believe in good faith that the law or other regulation requires us to preserve it for example because of our obligations
- right to information: you have a right to be informed of how AAR will use your personal data.
- right of access: you are entitled to access your personal data that is in our possession or custody.
- right to object: you can object to the processing of all part of your personal data, unless we can demonstrate a compelling legitimate interest for the processing which overrides your interests or for the establishment, exercise or defence of a legal claim.
- right to rectification: you have the right to request us to rectify or correct, without undue delay, personal data in our possession or under our control that is inaccurate, outdated, incomplete or misleading.
- right to erasure: you can request us to delete or destroy, without undue delay personal data that we are no longer authorised to retain, or which is irrelevant, excessive, or obtained unlawfully.
- right to data portability: you have the right to receive personal data concerning you in a structured, commonly used and machine-readable format and to transmit the data to another data controller without hindrance. Where technically possible. have personal data transmitted directly from us to another data controller or data processor.
- automated decision making you have the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning or that significantly affects you. AAR may from time to time make decisions based on the automated processing of your personal data. In such instances, you will be informed, in writing, whenever a decision based on automated processing is taken. In addition, you can request us to reconsider any decisions made based on automated processing or to take a new decision that is not based solely on automated processing.
- right of restriction: You have the right to request us to restrict the processing of personal data where: – oyou contest the accuracy of the personal data o the personal data is no longer required for the purpose of the processing
- the processing is unlawful, or you have opposed the erasure of the personal data and requested for restriction of its use instead.
- you have objected to the processing of personal data, pending verification as to whether the legitimate interests of the data controller or data processor override those of the data subject.
- right to raise a complaint: You can raise a complaint about our processing with the Regulator i.e., the Data Commissioner in Kenya. You may also be able to seek a remedy through the courts if you believe that your rights have been breached.
If you wish to exercise any of our rights above, please contact us on privacy@aar.co.ke We will seek to deal with your request without undue delay and in any event in accordance with the Data Protection Act, 2019 and the Data Protection (General) Regulations, 2021.
To ensure the security and accuracy of the personal data we provide, we may request additional information and verification of your identity. This is necessary to confirm that we are releasing the data to the rightful owner.
While we strive to fulfil all valid requests, there may be cases where we are unable to comply. If such a situation arises, we will inform you of the reasons for our inability to fulfil your request.
We are committed to ensuring that any transfer of personal data outside of Kenya complies with the provisions set forth by the Data Protection Act, 2019.
We prioritise the security and protection of your personal data throughout the transfer process. Therefore, we have implemented the following policy regarding international data transfers:
- Appropriate Safeguards: Before transferring personal data to another country, we ensure that we have appropriate safeguards in place to ensure the security and protection of your data. These safeguards may include technical, organisational, and legal measures to uphold data privacy standards. We will document these safeguards and provide proof to the Data Commissioner as and when required.
- Legal Grounds: We will only transfer personal data outside of Kenya when it is necessary and lawful. This includes situations where the transfer is required for the performance of a contract between you and AAR, the establishment, exercise, or defense of legal claims, the protection of vital interests, matters of public interest, or compelling legitimate interests that are not overridden by your rights and freedoms.
- Consent and Sensitive Data: If the transfer involves sensitive personal data, we will obtain your explicit consent and confirmation of appropriate safeguards before processing such data outside of Kenya.
- Data Commissioner Oversight: We acknowledge the authority of the Data Commissioner to request demonstrations of the effectiveness of security safeguards or the existence of compelling legitimate interests prior to the transfer
We are committed to maintaining the privacy and security of your personal data, regardless of its location. If you have any questions or concerns regarding our international data transfer practices, please contact our Data Protection Officer (DPO) at privacy@aar.co.ke We will strive to address your inquiries and provide you with transparent information regarding the transfer of your personal data outside of Kenya.
A “cookie” is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system. We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. However, rejecting all cookies through your browser’s privacy settings means that you may not be able to take full advantage of all our website’s features.
For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
Data Protection Officer
Real Towers Upperhill
P.O. Box 41766 – 00100
Nairobi, Kenya.
Tel: +254 703 063 000, +254 730 633 000, +254 202 895 000
Website: https://aar–insurance.com/ke.
By providing your personal data to AAR you agree to adhere to the following responsibilities:
- Accuracy and Updates: You are responsible for providing accurate and up-todate personal data to the Company. Please inform us promptly of any changes or updates to your contact details or other relevant information.
- Third-Party Data: If you give us personal data of third parties, such as family members or associates, next of kin or your dependents, it is your responsibility to ensure that you have obtained the necessary consent or authority to share their information. Inform these individuals about the processing activities and possible international transfers of their data.
- Exercise of Rights: If you wish to exercise your rights with respect to your personal data, including the rights of access, rectification, erasure, objection, or data portability, please follow the procedures outlined in our Privacy Policy. We may require additional information or verification to process your request and ensure the security and confidentiality of your data.
- Reporting Concerns: If you have any concerns or complaints regarding the processing or transfer of your personal data, please contact our designated Data Protection Officer (DPO) at privacy@aar.co.ke We appreciate your feedback and will promptly address any issues raised.
- Prospective policyholders their dependents and/or next of kin
- Policyholders and their dependents and/or next of kin
- Visitors to the company premises
- Website/Mobile App Users
Welcome to AAR’s Job Applicant Privacy Policy.
AAR Insurance Limited (“AAR”, “We”, “Us”, “Our”) is committed to protecting the privacy and
personal data of all individuals who apply for employment with us. We recognise the importance of
handling your personal data responsibly and are committed to processing it in a lawful, fair and
transparent manner.
This Privacy Notice explains how AAR collects, uses, stores, shares, retains and otherwise processes
your personal data during the recruitment and selection process. It also explains your rights under
the Data Protection Act, 2019 and how you may exercise those rights.
AAR processes your personal data in accordance with the Data Protection Act, 2019, the Data
Protection (General) Regulations, 2021 and other applicable laws.
AAR Insurance Limited ("AAR") is a licensed insurance company offering medical and general
insurance solutions to individuals, families and businesses.
For the purposes of the Data Protection Act, 2019, AAR is the Data Controller in relation to the
personal data collected and processed during the recruitment process. This means that AAR
determines the purposes for which, and the manner in which, your personal data is processed.
Our registered office is located at:
AAR Insurance Limited
Real Towers
Upper Hill Road
P.O. Box 41766 - 00100
Nairobi, Kenya
As part of the recruitment process, AAR collects and processes personal data that is necessary to
assess your suitability for employment, communicate with you throughout the recruitment process,
comply with applicable legal obligations and, where applicable, establish an employment relationship.
The table below sets out the categories of personal data we collect, the purposes for which it is
processed and the lawful basis relied upon.
| Type of Information | Personal Data Collected | Purpose of Collection | Lawful Basis |
|---|---|---|---|
| Personal and Identification Contact Information | Full name, national identification card or passport number, nationality, passport photograph (where applicable), postal and physical address, telephone number, email address and other contact details. | To identify you, communicate with you, administer your application and verify your identity. | Pre-contractual steps; legitimate interests; compliance with legal obligations where applicable. |
| Employment, Education and Professional Information | Curriculum vitae (CV), cover letter, employment history, positions held, work experience, skills, competencies, professional memberships, academic qualifications, professional certifications, licences, transcripts and training records. | To assess your qualifications, experience, competence and suitability for the position applied for. | Pre-contractual steps; legitimate interests. |
| Recruitment and Assessment Information | Application forms, interview notes, interview recordings (where applicable), assessment results, psychometric test results, practical exercises, presentations, evaluator comments and recruitment correspondence. | To assess your application, conduct interviews and assessments, compare candidates and make recruitment decisions. | Pre-contractual steps; legitimate interests. |
| Reference and Background Verification Information | Referee names and contact details, employment references, reference responses, background verification reports, right-to-work documentation and other verification information. | To verify the information provided during the recruitment process and conduct lawful pre-employment screening. | Pre-contractual steps; legitimate interests; compliance with legal obligations where applicable. |
| Compensation Information | Current remuneration, salary expectations, benefits expectations and other compensation-related information provided during the recruitment process. | To evaluate remuneration expectations and prepare an employment offer where appropriate. | Pre-contractual steps; legitimate interests. |
| Technical Information | IP address, browser type, device information, cookies, online identifiers and information relating to your use of AAR's recruitment portal or careers website. | To administer and secure recruitment systems, improve website functionality, maintain system security and analyse recruitment platform usage. | Legitimate interests; consent where required by law. |
| Special Categories of Personal Data (where applicable) | Health information relating to fitness for work, disability information required to provide reasonable accommodation, criminal record information where authorised by law, and any other special categories of personal data permitted under applicable law. | To comply with legal obligations, facilitate reasonable accommodations, conduct lawful pre-employment checks where permitted and fulfil other employment-related legal requirements. | Compliance with legal obligations; employment obligations; explicit consent where required by law; other lawful grounds under the Data Protection Act, 2019. |
Some of the personal data requested during the recruitment process is mandatory because it is necessary for AAR to assess your application, verify your identity, conduct lawful pre-employment checks, comply with legal or regulatory obligations and determine whether to enter into an employment relationship with you. Other information is voluntary and is collected only where you choose to provide it or where it is required for a specific purpose.
AAR does not ordinarily request sensitive personal data unless it is necessary for a lawful recruitment purpose or required by applicable law. Where such information is required, AAR will process it in accordance with the Data Protection Act, 2019 and implement appropriate safeguards to protect your privacy.
If you are offered and accept employment with AAR, the personal data collected during the recruitment process will become part of your employment record and will thereafter be processed in accordance with AAR's Employee Privacy Notice.
If your application is unsuccessful, AAR will retain your personal data in accordance with this Privacy Notice and the Company's Data Retention and Disposal Policy. Where appropriate and permitted by law, we may retain your information to consider you for future employment opportunities, unless you request otherwise.
| Source of Personal Data | Examples of Personal Data Collected | Purpose of Collection |
|---|---|---|
| Directly from You | Information provided in your application form, curriculum vitae (CV), cover letter, identification documents, academic and professional certificates, interview responses and any other information you choose to provide during the recruitment process. | To assess your suitability for employment, communicate with you, verify your identity and administer the recruitment process. |
| Recruitment Assessments and Interviews | Interview notes, interview recordings (where applicable), assessment results, psychometric test results, presentations, practical exercises and evaluator comments. | To evaluate your knowledge, skills, competencies and suitability for the position. |
| Recruitment Agencies and Referrals | CVs, application details and other recruitment information received from recruitment agencies, head-hunters or employee referrals. | To identify and assess potential candidates for employment opportunities. |
| Referees and Background Verification Providers | Employment references, reference responses, background verification reports, right-to-work verification and other pre-employment screening information. | To verify the information you have provided and conduct lawful pre-employment checks. |
| Publicly Available Sources | Information from professional networking platforms (such as LinkedIn) and other publicly available professional sources, where permitted by law. | To verify professional qualifications, employment history and identify suitable candidates for employment opportunities. |
| AAR Recruitment Systems and Website | IP address, browser type, device information, cookies, online identifiers and information relating to your use of AAR's careers portal or recruitment website. | To administer recruitment systems, maintain security, improve website functionality and analyse recruitment platform usage. |
AAR may store or process your personal data using systems or service providers located outside Kenya. This may result in your personal data being transferred to, stored in or accessed from jurisdictions outside Kenya. Where such transfers occur, AAR will ensure that they are carried out in accordance with the Data Protection Act, 2019 and any other applicable laws.
AAR currently utilises cloud-based platforms and authorised third-party service providers, including infrastructure hosted in the Western Europe region, to support its recruitment processes. Such providers are required to implement appropriate security measures and process personal data only in accordance with AAR's instructions and applicable law.
AAR takes appropriate steps to ensure that your personal data is accessed only by those who require it to perform their duties and by third parties with a legitimate need to process the data for the purposes described in this Privacy Policy. Where we engage third parties to process personal data on our behalf, we require them to process the data only for authorised purposes, maintain its confidentiality, implement appropriate technical and organisational security measures, and comply with applicable data protection laws and contractual obligations.
We may share your Personal Data in the following ways:
- Authorised AAR personnel, including Human Resources, recruiting managers, interview panel members and other employees involved in the recruitment and selection process, where access is necessary for the performance of their duties.
- Third-party service providers, including recruitment agencies, applicant tracking system providers, background verification providers, psychometric assessment providers, cloud hosting providers and other service providers who support AAR's recruitment activities.
- Professional advisers, including legal advisers, auditors and other consultants, where access to your personal data is necessary for the provision of professional services or the establishment, exercise or defence of legal claims.
- Regulators, law enforcement agencies, courts or other competent authorities, where disclosure is required or authorised by law, court order or other lawful process.
- Corporate transaction parties, where disclosure is necessary in connection with a merger, acquisition, restructuring, sale of business or other corporate transaction, subject to appropriate confidentiality and data protection safeguards.
- Other third parties, where you have provided your consent or where disclosure is otherwise permitted or required under applicable law. AAR does not sell your personal data. We only share your personal data where there is a lawful basis for doing so and where appropriate safeguards have been implemented to protect your personal data.
AAR has taken appropriate technical, administrative, physical and procedural security measures, consistent with local and international information practices, to protect the personal data from misuse, unauthorised access or disclosure, loss, alteration, or destruction. These measures include:
- Physical safeguards, such as locked doors and file cabinets, controlled access to our facilities, and secure destruction of media containing personal data.
- Technology safeguards, such as use of anti-virus and endpoint protection software, passwords, encryption, and monitoring of our systems and data centres to ensure compliance with our security policies.
- Organisational safeguards, through training and awareness programs on security and privacy, to ensure employees understand the importance and means by which they must protect personal data, as well as through privacy policies and policy standards that govern how AAR treats personal data.
If you suspect any misuse, loss, or unauthorised access to your personal data, please let us know immediately by sending us an email on privacy@aar.co.ke
- Our ability to consider your application, communicate with you, verify your information, conduct lawful checks, ,comply with legal obligations, and decide whether to offer you employment may depend on AAR receiving and using certain personal data.
- If you do not provide personal data that is required for the recruitment process, or if you ask us to stop processing personal data that we need for that process, we may be unable to progress your application, conduct necessary checks, communicate with you, comply with applicable legal or regulatory obligations, or make an offer of employment. Where the information requested is optional, choosing not to provide it will not affect your application unless the information is necessary for a specific purpose that you have asked us to consider.
The Data Protection Act accords you several rights. However, these rights are not absolute and may be subject to some exceptions under data protection law.
- The right to be informed about the collection and use of your personal data, including
the purposes for which it is processed and the lawful basis for such processing.
- The right to access your personal data and obtain information about how it is processed.
- The right to object to the processing of your personal data where such processing is based on AAR's legitimate interests, unless AAR demonstrates compelling legitimate grounds or is otherwise permitted by law to continue the processing.
- The right to correction of inaccurate, incomplete, outdated or misleading personal data.
- The right to erasure of your personal data in circumstances permitted by law.
- The right to data portability, where applicable, by receiving your personal data in a structured, commonly used and machine-readable format or requesting that it be transmitted to another data controller where technically feasible.
- The right not to be subject to a decision based solely on automated processing, including profiling, where such a decision produces legal effects concerning you or similarly significantly affects you, except where permitted by law.
- The right to request restriction of processing in circumstances permitted under the Data Protection Act, 2019.
You may exercise your rights by submitting a written request to the Data Protection Officer using the contact details provided in this Privacy Policy. AAR will consider and respond to all requests in accordance with the Data Protection Act, 2019 and may request additional information to verify your identity before processing your request. In certain circumstances, AAR may decline or limit a request where permitted or required by law, in which case you will be informed of the reasons for that decision.
If you have any questions about this Privacy Notice, wish to exercise your rights under the Data Protection Act, 2019, or have any concerns regarding the processing of your personal data, you may contact AAR's Data Protection Officer using the contact details below:
Data Protection Officer
AAR Insurance Limited
Email: privacy@aar.co.ke
Telephone: +254 703 063 000, +254 730 633 000, +254 202 895 000 Postal Address: 41766 – 00100, Nairobi, Kenya.
Physical Address: Real Towers, Upper Hill Road, Nairobi, Kenya
AAR will endeavour to respond to your enquiry or complaint within the timelines prescribed under the Data Protection Act, 2019 and any other applicable laws.
If you are dissatisfied with AAR's response or believe that your personal data has been processed in contravention of the Data Protection Act, 2019, you have the right to lodge a complaint with the Office of the Data Protection Commissioner or seek any other remedy available under applicable law.
AAR may review and update this Privacy Notice from time to time to reflect changes in applicable laws, regulations, business operations, technology or the manner in which we process personal data.
Where material changes are made to this Privacy Notice, AAR will take reasonable steps to notify applicants through appropriate communication channels, including updates on our careers portal, recruitment platforms, website or other appropriate means.
The latest version of this Privacy Notice will be made available on AAR's website and through other appropriate recruitment channels and will supersede all previous versions.
The "Effective Date" and "Version Number" set out in this Privacy Notice indicate when it was last reviewed and updated.
Welcome to the AAR’s Agents Privacy Policy. We appreciate you taking the time to read all our notices carefully.
AAR Insurance Limited (“AAR”, “We” “Us” “Our”) is committed to processing your personal information in a lawful, fair and transparent manner and in accordance with data protection laws in Kenya.
This Privacy Policy outlines how we collect, use, disclose, and protect personal information in connection with our services, including provision of medical and general insurance products and services.
Please take time to read this Privacy Policy to understand how and why we collect and use your information in connection with our insurance business.
AAR Insurance Kenya Limited is a leading medical and general insurance company, providing innovative underwriting solutions to individuals, families, and businesses. We offer products ranging from Family Plans, Personal Accident Insurance, School Insurance, Homeowners Insurance, Medical Insurance for SMEs and Corporates, Professional Indemnity, WIBA Cover, Travel Insurance, Marine Insurance and Landlord Insurance.
Our offices are located at Real Towers, Upperhill, Nairobi, Kenya.
This Privacy Policy applies to all AAR Insurance Kenya Limited Agents in connection with our insurance business.
In this Privacy Policy, "personal data" refers to any information relating to an identified or identifiable individual. This includes, but is not limited to, identification details, contact details, commissions, lead management details, performance appraisals, social media profiles, HMIS Code and any other data that can be used to directly or indirectly identify an individual.
Personal data may also include sensitive information, such as racial or ethnic origin, religious beliefs, health information, family information including children’s information, biometric data, property records, financial information, transaction records, where applicable and subject to applicable laws and regulations.
- We collect Personal Data directly from you as well as from other available sources to the extent permitted by law. We endeavour to only collect Personal Data that is necessary for the purpose(s) for which it is collected and to retain such data for no longer than necessary for such purpose(s). Subject to applicable law and practice, the categories of Personal Data that are typically collected and processed are:
Data Subject | Type of personal data collected | Purpose of Collection | Lawful Basis |
Agents | § Identification details: name, date of birth, ID/Passport, HMIS Code | § For identification purposes § To grant access to My Wakalaar § To confirm that the details provided on registration on My Wakalaar match with those in AIK Agent database. § To allow for background data synchronization on My Wakaalar | § Legal Obligation
|
§ Contact details: telephone number, WhatsApp number, email address | § For communication purposes including OTP delivery § To facilitate user-agent interactions including enabling users communicate their needs and enquiries to the agent, foster engagement and communication with agent on my Wakalaar platform.
| § Legitimate interests | |
§ Recruitment details: CV, Academic Certificates, Passport Photographs, examination results | § To your determine suitable for role applied | § Legitimate interests | |
§ Onboarding details: Insurance certificate, contractual details | § To onboard you to AAR Insurrance | § Contract § Legal Requirement | |
§ Performance Management details: Weekly activity templates, productivity appraisals | § To assess your performance against set KPIs | § Contract | |
§ Commission details: Commission, monthly statements, payment details including bank account numbers | § To process your commissions | § Contract | |
§ Consent details: Consent to receive marketing communications, consent to receive OTP, consent to process customer information | § For marketing/promotional purposes § To enable you perform accurate calculations of quotations, personalize the quotation process, communicate with client and track the progress of quotation and see its eventual closure. | § Consent | |
§ One Time Password (OTP) & agents’ passwords | § For validation and authentication of agents during registration to My Wakaalar § To ensure that you have control over your account on My Wakaalar and update it when necessary. | § Legitimate interests | |
§ Social Media details: social media accounts, consent to post on linked social media accounts, access tokens | § To enable you seamlessly link your social media accounts with My Wakalaar. | § Consent | |
§ Lead Management details: lead source, lead probability, lead value, tags, notes consent to process potential customer’s information | § To enable you save lead information on My Wakaalar platform and effectively manage lead data
| § Legitimate interests | |
§ CCTV Records | § To secure company premises and assets | § Legitimate interests | |
§ Complaints/requests
| § To receive, register and resolve your complaints | § Legitimate interests | |
§ Online identifiers: such as cookies and related tags, IP addresses | § To improve your experience when you access our website | § Legitimate interests |
We collect your information directly when you call, message, email or populate your details on the Agents’ platform My Wakalaar.
We also collect personal data indirectly when you use our website or access My Wakalaar, social medial platforms or when you visit our offices, and your images are captured by CCTV.
In some cases, if you choose not to provide certain personal data requested by us, it may impact our ability to fulfil our contractual obligations or provide you requested services or information. The specific consequences of not providing personal data will depend on the context and the purpose for which the data is requested.
For example, if you fail to provide us accurate bank account details, we may fail to process your commission statements.
We encourage you to carefully consider personal data requested and its importance for the intended purposes. If you have concerns about providing certain information, please contact us to discuss your specific circumstances and requirements. We will endeavor to find alternative solutions or assess if there are any legal or contractual obligations that require the provision of the requested data.
We may share your personal data within the Company to facilitate our internal operations and provide you with efficient services.
We may share your personal data with third parties in the following circumstances:
- Service Providers: We may engage third-party service providers to perform various services on our behalf, such as IT service providers and legal services providers. These service providers will have access to your personal data as necessary to perform their functions but are strictly prohibited from using your personal data for any other purposes.
- Business Partners: We may share your personal data with trusted business partners who collaborate with us to provide products or services to you. These partners may use your personal data only for the purposes specified in our agreement with them.
- Obligations: may disclose your personal data if required to do so by law or in response to a valid legal request, such as a court order or government inquiry.
- Corporate Transactions:In the event of a merger, acquisition, or any form of corporate restructuring, we may transfer your personal data to the involved parties, if they agree to treat your personal data in accordance with this privacy policy.
- Consent:We may share your personal data with third parties if you have given us explicit consent to do so. You have the right to withdraw your consent at any time.
When sharing your personal data with third parties, we prioritise the security and confidentiality of your information. We take stringent measures to ensure that these parties comply with strict data protection standards and handle your personal data in accordance with our instructions.
We carefully select and evaluate third-party service providers, business partners, and other recipients of your personal data. We enter into contractual agreements with these parties, imposing obligations to protect your personal data and restricting their use of the information solely for the specified purposes outlined in our agreement. Furthermore, we require these third parties to implement appropriate technical and organisational measures to prevent unauthorised access, disclosure, alteration, or destruction of your personal data.
We understand the importance of keeping your personal data secure and take appropriate measures to protect it against unauthorized access, loss, misuse, or alteration. We have implemented robust security measures to ensure the confidentiality, integrity, and availability of your information, including: -
- Technical Safeguards: To protect your information during transmission, we utilize industry-standard encryption protocols, ensuring the confidentiality of your data. Our secure network infrastructure incorporates firewalls, intrusion detection systems, and other security measures to prevent unauthorised access and mitigate external threats. Additionally, access controls are in place, restricting data access to authorised individuals through unique user credentials, strong passwords, and role-based privileges. Regular data backups and recovery processes are performed to maintain data integrity and availability.
- Organisational Safeguards: Our commitment to data security extends to our employees and third-party service providers. Strict confidentiality agreements bind them, emphasizing the importance of maintaining the security and confidentiality of your personal data. Regular training programs are conducted to educate employees on data protection best practices, security protocols, and their responsibilities. Access controls and authorization mechanisms ensure that only authorised personnel can access your data. We have established comprehensive data protection policies and procedures to guide the proper handling, storage, retention, and disposal of personal data. In the event of any security incidents, our incident response plan enables swift identification, mitigation, and notification, as well as measures to prevent future occurrences.
While we continually enhance our security measures, it is important to note that no security measure can provide absolute protection. However, we are dedicated to maintaining the highest possible standards of data security and will continue to invest in measures to safeguard your information
If you suspect any misuse or loss of or unauthorised access to your personal data, please let us know immediately by sending us an email on privacy@aar.co.ke
We retain your personal data only for as long as necessary to fulfill the purposes outlined in our Privacy Policy, or as required by applicable laws and regulations.
Once the retention period expires, we securely delete or anonymise your data to ensure it is no longer identifiable or accessible.
The retention periods for each category of data subjects and their respective personal data may vary based on the specific circumstances and legal requirements.
Your personal data such as contact details, identification details, contract details, payment details, CCTV records, social media profiles, complaints/requests, and cookies/online identifiers, is generally retained for the duration of the business relationship and for six [6] years thereafter. This allows us to maintain effective communication, fulfil contractual obligations, and comply with legal requirements.
ice providers and agents: We may make certain Personal Data available to third parties who provide services to us such as our human resource management software, background checks and psychometric service providers, headhunter firms, cloud service providers, and recruitment service providers. When we share with these third parties, we do so on a need-to-know basis and under clear contractual terms and instructions for the processing of the Personal Data.
- With other third parties: We may also share your information with other types of third parties, such as our legal representatives, industry groups or self-regulatory bodies, on lawful grounds. For example:
- with your consent.
- to comply with our legal obligations (including to comply with laws, regulations, and contracts, to respond to court orders, administrative or judicial process and search warrants, or to meet national security and law enforcement requests);
- to establish, exercise, or defend against potential, threatened, or actual litigation.
- to protect the safety, property, or vital interests of a person.
- to protect AAR’s rights or property.
- to protect AAR our other employees, customers, or the public from harm or illegal activities.
- to respond to an emergency that we, in good faith, believe requires us to disclose data to prevent harm; and
- in connection with the sale, assignment, merger, or other reorganisation or transfer of all or part of our business.
Under the Data Protection Act, 2019, you have serval rights regarding your personal data.
- right to information: you have a right to be informed of how the Company will use your personal data.
- right to access: you are entitled to access your personal data that is in our possession or custody.
- right to object: you can object to the processing of all part of your personal data, except when we can demonstrate a compelling legitimate interest for the processing which overrides your interests or for the establishment, exercise or defence of a legal claim.
- right to rectification: you have the right to request the correction of inaccurate, outdated, incomplete or misleading personal data in our possession or under our control, without undue delay.
- right to erasure: you have the right to request deletion or destruction, without undue delay, of personal data that we are no longer authorised to retain, or that is irrelevant, excessive, or obtained unlawfully.
- right to data portability: you have the right to receive personal data concerning you in a structured, commonly used, and machine-readable format and to transmit the data to another data controller without hindrance. Where technically feasible, you may also request direct transmission of your personal data from us to another data controller or data processor.
- automated decision making : you have the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects affects you. If we make automated decisions based on your personal data, you will be notified in writing. You can also request us to reconsider any decisions made solely through automated processing or to make a new decision that is not solely automated
- right of restriction: : You can request the restriction of processing your personal data in certain circumstances, such as when you contest the accuracy of the data, it is no longer needed for processing, it was processed unlawfully, or you have objected to the processing pending verification of our legitimate interests.
If you wish to exercise any of the rights outlined above, please write an email to the Data Protection Officer (DPO) on privacy@aar.co.ke
We will make every effort to address your inquiries and requests via email within the timelines specified by applicable data protection laws and regulations.
To ensure the security and accuracy of the personal data we provide, we may request additional information and verification of your identity. This is necessary to confirm that we are releasing the data to the rightful owner.
While we strive to fulfill all valid requests, there may be cases where we are unable to comply. If such a situation arises, we will inform you of the reasons for our inability to fulfill your request.
As part of our business operations, we may transfer personal data to recipients located in countries outside Kenya.
We are committed to ensuring that any transfer of personal data outside of Kenya complies with the provisions set forth by the Data Protection Act, 2019.
We prioritise the security and protection of your personal data throughout the transfer process. Therefore, we have implemented the following policy regarding international data transfers:
- Appropriate Safeguards Before transferring personal data to another country, we ensure that we have appropriate safeguards in place to ensure the security and protection of your data. These safeguards may include technical, organisational, and legal measures to uphold data privacy standards. We will document these safeguards and provide proof to the Data Commissioner as and when required.
- Legal Grounds: We will only transfer personal data outside of Kenya when it is necessary and lawful. This includes situations where the transfer is required for the performance of a contract between you and AAR establishment, exercise, or defense of legal claims, the protection of vital interests, matters of public interest, or compelling legitimate interests that are not overridden by your rights and freedoms.
- Consent and Sensitive Data: If the transfer involves sensitive personal data, we will obtain your explicit consent and confirmation of appropriate safeguards before processing such data outside of Kenya.Consent and Sensitive Data: If the transfer involves sensitive personal data, we will obtain your explicit consent and confirmation of appropriate safeguards before processing such data outside of Kenya.
- Data Commissioner OversightWe acknowledge the authority of the Data Commissioner to request demonstrations of the effectiveness of security safeguards or the existence of compelling legitimate interests prior to the transfer of personal data. We will cooperate with the Data Commissioner and comply with any conditions or restrictions imposed to protect the rights and fundamental freedoms of data subjects.
13.4. We are committed to maintaining the privacy and security of your personal data, regardless of its location. If you have any questions or concerns regarding our international data transfer practices, please contact our Data Protection Officer (DPO) at privacy@aar.co.ke We will strive to address your inquiries and provide you with transparent information regarding the transfer of your personal data outside of Kenya.
iries via email within the timelines stipulated in law.
When your information is processed by third-party services providers, we will promptly request third parties to your personal data.
To ensure that we release information to the correct individual, we may request identification verification.
In some cases, we will not be able to comply with your request. If this happens, you will be duly notified.
As a data subject, it is important that you understand and fulfill certain responsibilities to ensure the protection and privacy of your personal data. By providing your personal data to the Company, you agree to adhere to the following responsibilities:
- Accuracy and Updates:You are responsible for providing accurate and up-to-date personal data to the Company. Please inform us promptly of any changes or updates to your contact details or other relevant information.
- Third-Party Data: If you give us personal data of third parties, such as prospective member, it is your responsibility to ensure that you have obtained the necessary consent or authority to share their information. Inform these individuals about the processing activities and possible international transfers of their data.
- Exercise of Rights: If you wish to exercise your rights with respect to your personal data, including the rights of access, rectification, erasure, objection, or data portability, please follow the procedures outlined in our Privacy Policy. We may require additional information or verification to process your request and ensure the security and confidentiality of your data.
- Reporting Concerns: If you have any concerns or complaints regarding the processing or transfer of your personal data, please contact our designated Data Protection Officer (DPO) at privacy@aar.co.ke .We appreciate your feedback and will promptly address any issues raised.
We may periodically update or revise this Privacy Policy to ensure its alignment with legal requirements and our evolving business practices. We encourage you to review this Policy periodically to stay informed about how we handle your personal data.
If we make any material changes to this Policy, we will notify you through appropriate means, such as by posting a notice on our website or sending a direct communication. Your continued use of our services after the effective date of any revised Privacy Policy constitutes your acceptance of the revised Policy. We recommend that you regularly check this Privacy Policy to stay updated on any changes. If you disagree with any modifications to this Policy, you should discontinue using our services and contact us to exercise your rights or request the removal of your personal data, as outlined in this Policy.
Welcome to the AAR’s Agents Privacy Policy. We appreciate you taking the time to read all our notices carefully.
AAR Insurance Limited (“AAR”, “We” “Us” “Our”) is committed to processing your personal information in a lawful, fair and transparent manner and in accordance with data protection laws in Kenya.
This Privacy Policy outlines how we collect, use, disclose, and protect personal information in connection with our services, including provision of medical and general insurance products and services.
Please take time to read this Privacy Policy to understand how and why we collect and use your information in connection with our insurance business.
AAR Insurance Kenya Limited is a leading medical and general insurance company, providing innovative underwriting solutions to individuals, families, and businesses. We offer products ranging from Family Plans, Personal Accident Insurance, School Insurance, Homeowners Insurance, Medical Insurance for SMEs and Corporates, Professional Indemnity, WIBA Cover, Travel Insurance, Marine Insurance and Landlord Insurance.
Our offices are located at Real Towers, Upperhill, Nairobi, Kenya.
This Privacy Policy applies to all AAR Insurance Kenya Limited Agents in connection with our insurance business.
In this Privacy Policy, "personal data" refers to any information relating to an identified or identifiable individual. This includes, but is not limited to, identification details, contact details, commissions, lead management details, performance appraisals, social media profiles, HMIS Code and any other data that can be used to directly or indirectly identify an individual.
Personal data may also include sensitive information, such as racial or ethnic origin, religious beliefs, health information, family information including children’s information, biometric data, property records, financial information, transaction records, where applicable and subject to applicable laws and regulations.
- We collect Personal Data directly from you as well as from other available sources to the extent permitted by law. We endeavour to only collect Personal Data that is necessary for the purpose(s) for which it is collected and to retain such data for no longer than necessary for such purpose(s). Subject to applicable law and practice, the categories of Personal Data that are typically collected and processed are:
Data Subject | Type of personal data collected | Purpose of Collection | Lawful Basis |
Agents | § Identification details: name, date of birth, ID/Passport, HMIS Code | § For identification purposes § To grant access to My Wakalaar § To confirm that the details provided on registration on My Wakalaar match with those in AIK Agent database. § To allow for background data synchronization on My Wakaalar | § Legal Obligation
|
§ Contact details: telephone number, WhatsApp number, email address | § For communication purposes including OTP delivery § To facilitate user-agent interactions including enabling users communicate their needs and enquiries to the agent, foster engagement and communication with agent on my Wakalaar platform.
| § Legitimate interests | |
§ Recruitment details: CV, Academic Certificates, Passport Photographs, examination results | § To your determine suitable for role applied | § Legitimate interests | |
§ Onboarding details: Insurance certificate, contractual details | § To onboard you to AAR Insurrance | § Contract § Legal Requirement | |
§ Performance Management details: Weekly activity templates, productivity appraisals | § To assess your performance against set KPIs | § Contract | |
§ Commission details: Commission, monthly statements, payment details including bank account numbers | § To process your commissions | § Contract | |
§ Consent details: Consent to receive marketing communications, consent to receive OTP, consent to process customer information | § For marketing/promotional purposes § To enable you perform accurate calculations of quotations, personalize the quotation process, communicate with client and track the progress of quotation and see its eventual closure. | § Consent | |
§ One Time Password (OTP) & agents’ passwords | § For validation and authentication of agents during registration to My Wakaalar § To ensure that you have control over your account on My Wakaalar and update it when necessary. | § Legitimate interests | |
§ Social Media details: social media accounts, consent to post on linked social media accounts, access tokens | § To enable you seamlessly link your social media accounts with My Wakalaar. | § Consent | |
§ Lead Management details: lead source, lead probability, lead value, tags, notes consent to process potential customer’s information | § To enable you save lead information on My Wakaalar platform and effectively manage lead data
| § Legitimate interests | |
§ CCTV Records | § To secure company premises and assets | § Legitimate interests | |
§ Complaints/requests
| § To receive, register and resolve your complaints | § Legitimate interests | |
§ Online identifiers: such as cookies and related tags, IP addresses | § To improve your experience when you access our website | § Legitimate interests |
We collect your information directly when you call, message, email or populate your details on the Agents’ platform My Wakalaar.
We also collect personal data indirectly when you use our website or access My Wakalaar, social medial platforms or when you visit our offices, and your images are captured by CCTV.
In some cases, if you choose not to provide certain personal data requested by us, it may impact our ability to fulfil our contractual obligations or provide you requested services or information. The specific consequences of not providing personal data will depend on the context and the purpose for which the data is requested.
For example, if you fail to provide us accurate bank account details, we may fail to process your commission statements.
We encourage you to carefully consider personal data requested and its importance for the intended purposes. If you have concerns about providing certain information, please contact us to discuss your specific circumstances and requirements. We will endeavor to find alternative solutions or assess if there are any legal or contractual obligations that require the provision of the requested data.
We may share your personal data within the Company to facilitate our internal operations and provide you with efficient services.
We may share your personal data with third parties in the following circumstances:
- Service Providers: We may engage third-party service providers to perform various services on our behalf, such as IT service providers and legal services providers. These service providers will have access to your personal data as necessary to perform their functions but are strictly prohibited from using your personal data for any other purposes.
- Business Partners: We may share your personal data with trusted business partners who collaborate with us to provide products or services to you. These partners may use your personal data only for the purposes specified in our agreement with them.
- Obligations: may disclose your personal data if required to do so by law or in response to a valid legal request, such as a court order or government inquiry.
- Corporate Transactions:In the event of a merger, acquisition, or any form of corporate restructuring, we may transfer your personal data to the involved parties, if they agree to treat your personal data in accordance with this privacy policy.
- Consent:We may share your personal data with third parties if you have given us explicit consent to do so. You have the right to withdraw your consent at any time.
When sharing your personal data with third parties, we prioritise the security and confidentiality of your information. We take stringent measures to ensure that these parties comply with strict data protection standards and handle your personal data in accordance with our instructions.
We carefully select and evaluate third-party service providers, business partners, and other recipients of your personal data. We enter into contractual agreements with these parties, imposing obligations to protect your personal data and restricting their use of the information solely for the specified purposes outlined in our agreement. Furthermore, we require these third parties to implement appropriate technical and organisational measures to prevent unauthorised access, disclosure, alteration, or destruction of your personal data.
We understand the importance of keeping your personal data secure and take appropriate measures to protect it against unauthorized access, loss, misuse, or alteration. We have implemented robust security measures to ensure the confidentiality, integrity, and availability of your information, including: -
- Technical Safeguards: To protect your information during transmission, we utilize industry-standard encryption protocols, ensuring the confidentiality of your data. Our secure network infrastructure incorporates firewalls, intrusion detection systems, and other security measures to prevent unauthorised access and mitigate external threats. Additionally, access controls are in place, restricting data access to authorised individuals through unique user credentials, strong passwords, and role-based privileges. Regular data backups and recovery processes are performed to maintain data integrity and availability.
- Organisational Safeguards: Our commitment to data security extends to our employees and third-party service providers. Strict confidentiality agreements bind them, emphasizing the importance of maintaining the security and confidentiality of your personal data. Regular training programs are conducted to educate employees on data protection best practices, security protocols, and their responsibilities. Access controls and authorization mechanisms ensure that only authorised personnel can access your data. We have established comprehensive data protection policies and procedures to guide the proper handling, storage, retention, and disposal of personal data. In the event of any security incidents, our incident response plan enables swift identification, mitigation, and notification, as well as measures to prevent future occurrences.
While we continually enhance our security measures, it is important to note that no security measure can provide absolute protection. However, we are dedicated to maintaining the highest possible standards of data security and will continue to invest in measures to safeguard your information
If you suspect any misuse or loss of or unauthorised access to your personal data, please let us know immediately by sending us an email on privacy@aar.co.ke
We retain your personal data only for as long as necessary to fulfill the purposes outlined in our Privacy Policy, or as required by applicable laws and regulations.
Once the retention period expires, we securely delete or anonymise your data to ensure it is no longer identifiable or accessible.
The retention periods for each category of data subjects and their respective personal data may vary based on the specific circumstances and legal requirements.
Your personal data such as contact details, identification details, contract details, payment details, CCTV records, social media profiles, complaints/requests, and cookies/online identifiers, is generally retained for the duration of the business relationship and for six [6] years thereafter. This allows us to maintain effective communication, fulfil contractual obligations, and comply with legal requirements.
ice providers and agents: We may make certain Personal Data available to third parties who provide services to us such as our human resource management software, background checks and psychometric service providers, headhunter firms, cloud service providers, and recruitment service providers. When we share with these third parties, we do so on a need-to-know basis and under clear contractual terms and instructions for the processing of the Personal Data.
- With other third parties: We may also share your information with other types of third parties, such as our legal representatives, industry groups or self-regulatory bodies, on lawful grounds. For example:
- with your consent.
- to comply with our legal obligations (including to comply with laws, regulations, and contracts, to respond to court orders, administrative or judicial process and search warrants, or to meet national security and law enforcement requests);
- to establish, exercise, or defend against potential, threatened, or actual litigation.
- to protect the safety, property, or vital interests of a person.
- to protect AAR’s rights or property.
- to protect AAR our other employees, customers, or the public from harm or illegal activities.
- to respond to an emergency that we, in good faith, believe requires us to disclose data to prevent harm; and
- in connection with the sale, assignment, merger, or other reorganisation or transfer of all or part of our business.
Under the Data Protection Act, 2019, you have serval rights regarding your personal data.
- right to information: you have a right to be informed of how the Company will use your personal data.
- right to access: you are entitled to access your personal data that is in our possession or custody.
- right to object: you can object to the processing of all part of your personal data, except when we can demonstrate a compelling legitimate interest for the processing which overrides your interests or for the establishment, exercise or defence of a legal claim.
- right to rectification: you have the right to request the correction of inaccurate, outdated, incomplete or misleading personal data in our possession or under our control, without undue delay.
- right to erasure: you have the right to request deletion or destruction, without undue delay, of personal data that we are no longer authorised to retain, or that is irrelevant, excessive, or obtained unlawfully.
- right to data portability: you have the right to receive personal data concerning you in a structured, commonly used, and machine-readable format and to transmit the data to another data controller without hindrance. Where technically feasible, you may also request direct transmission of your personal data from us to another data controller or data processor.
- automated decision making : you have the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects affects you. If we make automated decisions based on your personal data, you will be notified in writing. You can also request us to reconsider any decisions made solely through automated processing or to make a new decision that is not solely automated
- right of restriction: : You can request the restriction of processing your personal data in certain circumstances, such as when you contest the accuracy of the data, it is no longer needed for processing, it was processed unlawfully, or you have objected to the processing pending verification of our legitimate interests.
If you wish to exercise any of the rights outlined above, please write an email to the Data Protection Officer (DPO) on privacy@aar.co.ke
We will make every effort to address your inquiries and requests via email within the timelines specified by applicable data protection laws and regulations.
To ensure the security and accuracy of the personal data we provide, we may request additional information and verification of your identity. This is necessary to confirm that we are releasing the data to the rightful owner.
While we strive to fulfill all valid requests, there may be cases where we are unable to comply. If such a situation arises, we will inform you of the reasons for our inability to fulfill your request.
As part of our business operations, we may transfer personal data to recipients located in countries outside Kenya.
We are committed to ensuring that any transfer of personal data outside of Kenya complies with the provisions set forth by the Data Protection Act, 2019.
We prioritise the security and protection of your personal data throughout the transfer process. Therefore, we have implemented the following policy regarding international data transfers:
- Appropriate Safeguards Before transferring personal data to another country, we ensure that we have appropriate safeguards in place to ensure the security and protection of your data. These safeguards may include technical, organisational, and legal measures to uphold data privacy standards. We will document these safeguards and provide proof to the Data Commissioner as and when required.
- Legal Grounds: We will only transfer personal data outside of Kenya when it is necessary and lawful. This includes situations where the transfer is required for the performance of a contract between you and AAR establishment, exercise, or defense of legal claims, the protection of vital interests, matters of public interest, or compelling legitimate interests that are not overridden by your rights and freedoms.
- Consent and Sensitive Data: If the transfer involves sensitive personal data, we will obtain your explicit consent and confirmation of appropriate safeguards before processing such data outside of Kenya.Consent and Sensitive Data: If the transfer involves sensitive personal data, we will obtain your explicit consent and confirmation of appropriate safeguards before processing such data outside of Kenya.
- Data Commissioner OversightWe acknowledge the authority of the Data Commissioner to request demonstrations of the effectiveness of security safeguards or the existence of compelling legitimate interests prior to the transfer of personal data. We will cooperate with the Data Commissioner and comply with any conditions or restrictions imposed to protect the rights and fundamental freedoms of data subjects.
13.4. We are committed to maintaining the privacy and security of your personal data, regardless of its location. If you have any questions or concerns regarding our international data transfer practices, please contact our Data Protection Officer (DPO) at privacy@aar.co.ke We will strive to address your inquiries and provide you with transparent information regarding the transfer of your personal data outside of Kenya.
iries via email within the timelines stipulated in law.
When your information is processed by third-party services providers, we will promptly request third parties to your personal data.
To ensure that we release information to the correct individual, we may request identification verification.
In some cases, we will not be able to comply with your request. If this happens, you will be duly notified.
As a data subject, it is important that you understand and fulfill certain responsibilities to ensure the protection and privacy of your personal data. By providing your personal data to the Company, you agree to adhere to the following responsibilities:
- Accuracy and Updates:You are responsible for providing accurate and up-to-date personal data to the Company. Please inform us promptly of any changes or updates to your contact details or other relevant information.
- Third-Party Data: If you give us personal data of third parties, such as prospective member, it is your responsibility to ensure that you have obtained the necessary consent or authority to share their information. Inform these individuals about the processing activities and possible international transfers of their data.
- Exercise of Rights: If you wish to exercise your rights with respect to your personal data, including the rights of access, rectification, erasure, objection, or data portability, please follow the procedures outlined in our Privacy Policy. We may require additional information or verification to process your request and ensure the security and confidentiality of your data.
- Reporting Concerns: If you have any concerns or complaints regarding the processing or transfer of your personal data, please contact our designated Data Protection Officer (DPO) at privacy@aar.co.ke .We appreciate your feedback and will promptly address any issues raised.
We may periodically update or revise this Privacy Policy to ensure its alignment with legal requirements and our evolving business practices. We encourage you to review this Policy periodically to stay informed about how we handle your personal data.
If we make any material changes to this Policy, we will notify you through appropriate means, such as by posting a notice on our website or sending a direct communication. Your continued use of our services after the effective date of any revised Privacy Policy constitutes your acceptance of the revised Policy. We recommend that you regularly check this Privacy Policy to stay updated on any changes. If you disagree with any modifications to this Policy, you should discontinue using our services and contact us to exercise your rights or request the removal of your personal data, as outlined in this Policy.
This Privacy Policy outlines how we collect, use, disclose, and protect personal information in connection with our services including our offering medical and non-medical insurance products.
Please take time to read this Privacy Policy to understand how and why we collect and use your information in connection with our services, including offering medical and non-medical insurance products.
Our offices are located at Real Towers, Upperhill, Nairobi, Kenya.
Personal data may also include sensitive information, such as biometric data, property records, financial information, transaction records, where applicable and subject to applicable laws and regulations.
| Data Subject | Type of personal data collected | Purpose of Collection | Lawful Basis |
| Suppliers |
|
|
|
You are responsible for providing accurate and up-to-date personal data to the Company. Please inform us promptly of any changes or updates to your contact details or other relevant information.
We may also collect your personal data indirectly when you use our website, submit tenders through our tendering platforms, access our social medial platforms or when you visit our offices, and your images are captured by our CCTV cameras.
We may share your personal data with third parties in the following circumstances:
- Service Providers: We may engage third-party service providers to perform various services on our behalf, such as IT data processors and legal services providers. These service providers will have access to your personal data as necessary to perform their functions but are strictly prohibited from using your personal data for any other purposes.
- Business Partners: We may share your personal data with trusted business partners who collaborate with us to provide products or services to you. These partners may use your personal data only for the purposes specified in our agreement with them.
- Legal Obligations: We may disclose your personal data if required to do so by law or in response to a valid legal request, such as a court order or government inquiry.
- Corporate Transactions: In the event of a merger, acquisition, or any form of corporate restructuring, we may transfer your personal data to the involved parties, if they agree to treat your personal data in accordance with this privacy policy.
- Consent: We may share your personal data with third parties if you have given us explicit consent to do so. You have the right to withdraw your consent at any time.
- When sharing your personal data with third parties, we prioritise the security and confidentiality of your information. We take stringent measures to ensure that these parties comply with strict data protection standards and handle your personal data in accordance with our instructions.
We carefully select and evaluate third-party service providers, business partners, and other recipients of your personal data. We enter into contractual agreements with these parties, imposing obligations to protect your personal data and restricting their use of the information solely for the specified purposes outlined in our agreement. Furthermore, we require these third parties to implement appropriate technical and organisational measures to prevent unauthorised access, disclosure, alteration, or destruction of your personal data.
We understand the importance of keeping your personal data secure and take appropriate measures to protect it against unauthorized access, loss, misuse, or alteration. We have implemented robust security measures to ensure the confidentiality, integrity, and availability of your information, including: –
- Technical Safeguards: To protect your information during transmission, we utilize industry-standard encryption protocols, ensuring the confidentiality of your data. Our secure network infrastructure incorporates firewalls, intrusion detection systems, and other security measures to prevent unauthorised access and mitigate external threats. Additionally, access controls are in place, restricting data access to authorised individuals through unique user credentials, strong passwords, and role-based privileges. Regular data backups and recovery processes are performed to maintain data integrity and availability.
- Organisational Safeguards: Our commitment to data security extends to our employees and third-party service providers. Strict confidentiality agreements bind them, emphasizing the importance of maintaining the security and confidentiality of your personal data. Regular training programs are conducted to educate employees on data protection best practices, security protocols, and their responsibilities. Access controls and authorization mechanisms ensure that only authorised personnel can access your data. We have established comprehensive data protection policies and procedures to guide the proper handling, storage, retention, and disposal of personal data. In the event of any security incidents, our incident response plan enables swift identification, mitigation, and notification, as well as measures to prevent future occurrences
While we continually enhance our security measures, it is important to note that no security measure can provide absolute protection. However, we are dedicated to maintaining the highest possible standards of data security and will continue to invest in measures to safeguard your information.
If you suspect any misuse or loss of or unauthorised access to your personal data, please let us know immediately by sending us an email on privacy@aar.co.ke
The retention periods for each category of data subjects and their respective personal data may vary based on the specific circumstances and legal requirements.
Once the retention period expires, we shall securely dispose your personal data in accordance with our Data Retention and Disposal Policy.
- right to information: you have a right to be informed of how the Company will use your personal data.
- right of access: you are entitled to access your personal data that is in our possession or custody.
- right to object: you can object to the processing of all part of your personal data, except when we can demonstrate a compelling legitimate interest for the processing which overrides your interests or for the establishment, exercise or defence of a legal claim.
- right to rectification: you have the right to request the correction of inaccurate, outdated, incomplete or misleading personal data in our possession or under our control, without undue delay.
- right to erasure: you have the right to request deletion or destruction, without undue delay, of personal data that we are no longer authorised to retain, or that is irrelevant, excessive, or obtained unlawfully.
- right to data portability: you have the right to receive personal data concerning you in a structured, commonly used, and machine-readable format and to transmit the data to another data controller without hindrance. Where technically feasible, you may also request direct transmission of your personal data from us to another data controller or data processor.
- automated decision making you have the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects affects you. If we make automated decisions based on your personal data, you will be notified in writing. You can also request us to reconsider any decisions made solely through automated processing or to make a new decision that is not solely automated.
- right of restriction: You can request the restriction of processing your personal data in certain circumstances, such as when you contest the accuracy of the data, it is no longer needed for processing, it was processed unlawfully, or you have objected to the processing pending verification of our legitimate interests.
If you wish to exercise any of the rights outlined above, please write an email to the Data Protection Officer (DPO) on privacy@aar.co.keWe will make every effort to address your inquiries and requests via email within the timelines specified by applicable data protection laws and regulations.
To ensure the security and accuracy of the personal data we provide, we may request additional information and verification of your identity. This is necessary to confirm that we are releasing the data to the rightful owner.
While we strive to fulfill all valid requests, there may be cases where we are unable to comply. If such a situation arises, we will inform you of the reasons for our inability to fulfill your request
- Appropriate Safeguards: Before transferring personal data to another country, we ensure that we have appropriate safeguards in place to ensure the security and protection of your data. These safeguards may include technical, organisational, and legal measures to uphold data privacy standards. We will document these safeguards and provide proof to the Data Commissioner as and when required.
- Legal Grounds: We will only transfer personal data outside of Kenya when it is necessary and lawful. This includes situations where the transfer is required for the performance of a contract between you and AAR Insurance the establishment, exercise, or defense of legal claims, the protection of vital interests, matters of public interest, or compelling legitimate interests that are not overridden by your rights and freedoms.
- Consent and Sensitive Data: If the transfer involves sensitive personal data, we will obtain your explicit consent and confirmation of appropriate safeguards before processing such data outside of Kenya.
- Data Commissioner Oversight: We acknowledge the authority of the Data Commissioner to request demonstrations of the effectiveness of security safeguards or the existence of compelling legitimate interests prior to the transfer of personal data. We will cooperate with the Data Commissioner and comply with any conditions or restrictions imposed to protect the rights and fundamental freedoms of data subjects.
We are committed to maintaining the privacy and security of your personal data, regardless of its location. If you have any questions or concerns regarding our international data transfer practices, please contact our Data Protection Officer (DPO) at privacy@aar.co.ke We will strive to address your inquiries and provide you with transparent information regarding the transfer of your personal data outside of Kenya.
- Third-Party Data: If you give us personal data of third parties, it is your responsibility to ensure that you have obtained the necessary consent or authority to share their information. Inform these individuals about the processing activities and possible international transfers of their data.
- Exercise of Rights: If you wish to exercise your rights with respect to your personal data, including the rights of access, rectification, erasure, objection, or data portability, please follow the procedures outlined in our Privacy Policy. We may require additional information or verification to process your request and ensure the security and confidentiality of your data.
- Reporting Concerns: If you have any concerns or complaints regarding the processing or transfer of your personal data, please contact our designated Data Protection Officer (DPO) at privacy@aar.co.ke We appreciate your feedback and will promptly address any issues raised.
Unauthorized access to the company premises including employee offices, stores or restricted areas such as the company vault can expose confidential data, leading to potential data breaches or information leakage.
Compliance with this policy is essential for meeting legal and regulatory requirements related to data protection.
The Company has installed the CCTV system to: –
- increase personal safety within the premises and reduce the fear of crime
- assist in the prevention and detection of crime
- assist with potential investigation and identification of offenders
- protect the company’s assets
- as a means of assistance to employees in case of emergency situations.
The Company understands that all systems, information, documents and recordings obtained and used as data is protected by the Data Protection Laws.
The viewing and copying of the images will be strictly controlled. Provision of images to external agencies will only be provided in line with clause 8.
Head of IT is responsible for the overall management and operation of the CCTV system, including activities relating to installations, recording, reviewing, monitoring, and ensuring compliance with this policy.
The Data Protection Officer(“DPO”) is responsible for the privacy and data protection aspects of this policy. Please refer any questions relating to this policy to the DPO.
This policy shall be reviewed annually by the Head of IT in collaboration with the DPO.
MANAGEMENT AND CONTROL OF THE CCTV SYSTEM
- The CCTV system is owned and managed by the Company. The Head of IT is in charge of the day-to-day running of the system.
- For the purpose of images collected and processed, the Company is a Data Controller. This means that AAR Insurance Company Limited is responsible for determining the purposes collecting and using CCTV images.
- The CCTV system operates to meet the requirements of the Data Protection Laws and the relevant CCTV regulatory standards in Kenya and internationally.
DESCRIPTION OF SYSTEM
- The Company’s CCTV cameras are located in various locations within the Company such as areas leading into employees offices, stores,
- The CCTV system is operational and is capable of being monitored for 24 hours a day, every day of the year.
- CCTV signs are placed at conspicuous places within the Company to inform visitors that the Company is under CCTV surveillance. The signage indicates that the system is managed by the Company.
- Any proposed new CCTV installation is subject to a Data Protection Impact Assessment.
SITING OF CAMERAS
- Cameras are sited to ensure that they secure the Company’s premises as far as possible by monitoring vulnerable public facing areas.
- Cameras are sighted in prominent positions where they are clearly visible.
- Cameras are not sited to focus on areas not intended to be monitored.
- The Company will make all reasonable efforts to ensure that areas outside of our premises are not recorded.
- Cameras will not be cited in areas where individuals have heightened expectation of privacy such as washrooms.
- respect the privacy of an individual when processing personal data.
- process personal information lawfully, fairly and transparently.
- collect data for specific and explicit legitimate purposes and restricts processing to those purposes.
- retain your images/likeness for no longer than necessary for the purpose to which the information is collected.
- shall not transfer your images outside the country. Where we do so, we have put in place appropriate technical and organizational measures to safeguard your personal information.
- process personal data in a manner that ensures appropriate security and confidentiality of that information. We employ appropriate technical or organizational measures to protect your data against unauthorized access, accidental loss, destruction or damage.
- Right to information
- Right of access
- Right to rectification
- Right to erasure
- Right to restrict processing
- Right to data portability
- Right to object
- Right to automated decision making
Where the Company is unable to comply with a Data Subject request without disclosing personal data of another individual who can be identified from that information, we are not obliged to comply with the request.
We may disclose personal information to third parties when it is required by law, in relation to the prevention or detection of a crime, or to comply with a written law or court order.
Such disclosures will be made at the discretion of the Head of IT in collaboration the Legal and the Data Protection Officer.
Where a suspicion of misconduct arises, we may use CCTV images in employee disciplinary cases.
Where it is necessary to hold an image for longer the period stipulated in 9.1, for example for evidentiary purposes, the investigation of an offence or as required by law, this request will be in writing and directed to the Data Protection Officer.
The images held beyond their retention period will be reviewed and any not for the specified in 9.2. above will be deleted.
Data Subjects may inquire or request for any information regarding any matter relating to the processing of their personal data under the custody of Company, including data privacy and security policies implemented to ensure the protection of their personal data. They may write to the DPO and briefly discuss the inquiry, together with their contact details for reference.
The DPO shall maintain a log of all inquiries and complaints.
11.2. Non-compliance may result in disciplinary action, up to and including termination of employment.
In order to access any of the Services you will be required to accept these terms and conditions. You will be deemed to have accepted these terms by: Completing our online registration process and confirming that you have read and accepted these terms; or Viewing, accessing or using content on the Site which does not require registration.
We suggest that you print out and keep a copy of these terms for your records. In addition to these terms, there may be additional terms and conditions which apply to individual Services which you will be required to accept when registering for that Service.
Registration and use of the Services In order to access or continue to use certain Services, you may be required to provide information about yourself (such as identification or contact details). You agree to provide true, accurate, current and complete information when registering for the Services.
You agree to use the Services only for purposes that are permitted by
(i) these terms and (ii) any applicable law or regulation. You specifically agree not to access (or attempt to access) any of the Services through any automated means (including use of scripts or web crawlers) and shall ensure that you comply with the instructions set out in any part of the Site. You agree that you will not engage in any activity that interferes with or disrupts the Services (or the servers and networks which are connected to the Services). You agree that you will not reproduce, duplicate, copy, sell, trade or resell the Services for any purpose. You agree that you are solely responsible for (and that AAR has no responsibility to you or to any third party for) any breach of your obligations under these terms and for the consequences (including any loss or damage which AAR may suffer) of any such breach.
Password and Account Security For certain Services e.g. registration for use of the AAR Online services you will be required to choose a user name and a password. For any such Services: The user name you choose must not be obscene, threatening, menacing, racist, offensive, derogatory, defamatory or in violation of any intellectual property or proprietary rights of any third party; and If we consider in our sole and absolute discretion that the user name selected by you is inappropriate, we reserve the right to reject and prevent your use of such user name at any time with or without notice to you.
You will be prompted to change your password from time to time in a span of one month in accordance to AIK IT policy. Your password is confidential and being aware of this you agree and understand that you are responsible for maintaining the confidentiality of password(s) associated with your account(s). Accordingly, you agree that you will be solely responsible to AAR for all activities that occur under your account.
You, and any persons you allow to use the Services through your access to the Services, are not allowed to: Copy, disclose, modify, reformat, display, distribute, licence, transmit, sell, perform, publish, transfer, link to, reverse engineer or decompile (except to the extent expressly permitted by applicable law) or otherwise make available the Services or any part thereof except as set out in these terms; Include or create links (including deep-links) to or from the Services; Replicate the Site or create a separate border around any part of the Services (also known as “framing”); Use the Services for storing, reproducing, transmitting, communicating or receiving any Offending Material.
For the purpose of these terms Offending Material means any content transmitted using the Service that is: In breach of any law, regulation or code of practice invoked by AAR, industry regulator or any other competent authority or any policy adopted by AAR with regard to the acceptable use of the Services, or Abusive, indecent, defamatory, obscene, pornographic, offensive or menacing (or that has the effect (as may be contemplated by a reasonable person) of causing the recipient to feel so harassed, abused or offended; or Designed to cause annoyance, inconvenience or needless anxiety to any person; or In breach of confidence, intellectual property rights, privacy or any right of a third party.
Hack into, make excessive traffic demands, probe or port scan other computers, deliver viruses, mail bombs, chain letters or pyramid schemes or otherwise engage in any other behaviour intended to inhibit other users from using and enjoying the Services or any other website; Collect and process others’ personal data except in accordance with applicable data protection law; Advertise or offer to sell goods or services on the pretext that the same are endorsed, offered for sale or originate from AAR; Infringe any other person’s intellectual property rights; Use the Services to harvest or collect information about users of the Services or to post or otherwise distribute unauthorized or unsolicited advertising, junk or bulk email (also known as “spam”); Use the Services or the Content in any way that we in our sole and absolute discretion consider objectionable, inappropriate, likely to injure our brand and reputation or otherwise unacceptable; Use the Services to send emails and other content coached, phrased or written in such a manner as to give an impression that the email is correspondence from AAR.
You are responsible for any misuse of the Services even if it is by another person using your access to the Services.
4.3 We reserve the right to block, remove, edit or refuse to post any material that you attempt to transmit through the Services that we deem to be in contravention of these terms and to take such other action as we in our sole and absolute discretion consider necessary to prevent or remedy any breach of these terms. If you become aware of any content or material circulated using the Services and that is in breach of these terms or content or material on the Site that is similarly in breach of these terms then we encourage you to promptly inform us by contacting our customer care service.
We are not responsible or liable for any failure to remove, block or delay in removing, any such infringing content or material or third party material from the Service or for any good faith but wrongful removal of third party material.
Equipment You will need to provide all equipment necessary to access the Service. If your equipment does not support the relevant technology allowing you to access the internet then you will not be able to use this Service.
Cost and Charges AAR will currently not charge you to sign up/register for the Services, save as may otherwise be communicated by AAR from time to time. However, AAR reserves the right to charge for access or all of Services in the future, subject to a clear notice when accessing Services that are charged.
Although AAR will take all reasonable steps to ensure that the Services are available to you at all times, it cannot guarantee a continuous fault free service. The quality and availability of Services may be affected by factors including (but not limited to) acts of God, planned maintenance or rectification work, or your equipment may interfere adversely with the quality and provision of the Services. We therefore do not warrant and shall not be liable for any delay or failure to send, receive or process messages, pictures, video clips and other communications or the quality of the materials received.
You accept and recognise that the Internet is not a secure environment and as such messages, pictures, video clips and other communications may be intercepted or accessed by those other than the intended recipient, manipulated, distorted, adapted, modified, stored or forwarded by others to you which may give unauthorised persons access to information stored on your PC or mobile device or may cause damage to your PC or mobile device. AAR accepts no liability for any loss or damage resulting from the receipt of any messages, pictures, video clips or other communications from any third parties. You will be required to take reasonable precautions while accessing websites, sending or receiving emails using the Services.
AAR may establish limits concerning the use of the Services for example the maximum number of characters that may be posted or received on the online services, the maximum capacity allocated to you for storage and/or transmission of Content.
You irrevocably agree to indemnify us (AAR Holdings Limited) and any of our third party providers (“together indemnified persons”)fully against and to hold the indemnified persons harmless on demand from all losses, costs, proceedings, damages, expenses (including reasonable legal costs and expenses) or liabilities howsoever incurred by the indemnified persons as a result of any claim by a third party resulting from your use of the Service (or use of the Service by anyone who accesses the Service via your password) in breach or non-observance of these terms.
We shall notify you of any claim that we or any of the other indemnified persons receives and you hereby agree to provide us and/or any of the indemnified persons with full authority to defend or settle such claims and shall provide us and/or any of the indemnified persons with all reasonable assistance necessary to defend such claims, at your sole expense.
AAR reserves the right to vary the terms and conditions of this Agreement at any time by placing the revised terms and conditions on its website www.aar-insurance.com and you will be deemed to have been bound by such variation by continuing to use the Services. You should periodically check the websites www.aar-insurance.com to make yourself aware of any variations.
The construction, validity and performance of these terms and conditions shall be governed in all respects by the Laws of Kenya.
If any provision of these terms and conditions are declared by any judicial or other competent authority to be void, voidable, illegal or otherwise unenforceable, such a term shall be amended or at the discretion of AAR it may be severed from these terms and conditions and the remaining provisions of these terms and conditions shall remain in full force and effect.
Except where this terms and conditions provides otherwise, the rights and remedies contained in it are cumulative and not exclusive to rights or remedies provided by law. The failure by AAR to enforce at any time or for any period any one or more of the terms and conditions shall not be a waiver of them or of the right at any time subsequently to enforce all terms and conditions.
No delay or failure by AAR shall constitute a breach or give rise to any claim for damages or loss of anticipated profits if such delay or failure is caused by force majeure. Force majeure shall mean an occurrence which is beyond and without fault or negligence of AAR affected and which AAR is unable to prevent or provide against by the exercise of reasonable diligence including, but not limited to, acts of God or of the public enemy, appropriation of confiscation of facilities, terrorists activity or other catastrophe, strike or any other concerted acts of employees or other similar occurrences.
You shall not assign these terms and conditions to a third party. Any unauthorized assignment or attempt to assign will automatically terminate this Service. AAR may assign these terms and conditions in whole or part to any third party at its discretion.
14.7 You acknowledge and agree that in entering into this Agreement you do not rely on, shall have no remedy in respect of, any statement, representation, warranty or understanding (whether negligently or innocently made) of any person (whether party to these terms and conditions or not) other than as expressly set out in these terms and conditions as a warranty. Nothing in this clause shall, however, operate to limit or exclude liability for fraud.
We may suspend, vary or terminate your use of the Service or the Site without compensation for any period during which: AAR is required or requested to comply with an order or instruction of or a recommendation from the government, court, regulator or other competent authority; AAR reasonably suspects or believes that you are in breach of these terms and conditions; Such a suspension or variation is necessary as a consequences of technical problems or for reasons of safety; In order to update or upgrade the contents or functionality of the Service from time to time; Upon any detection of abuse/misuse, breach of content, fraud or attempted fraud relating to your use of the Service; Where you remain inactive for any period of time chosen by us in our reasonable discretion or where we believe, in our sole and absolute discretion; AAR suspends the provision of the Services for its commercial reasons or for any other reason as it may determine in its absolute discretion.
If we suspend your access to the Service to investigate or prevent a potential breach of these, terms shall continue to apply during such period of suspension and you shall remain liable for any charges payable by you during such period.
If your access to the Services is terminated for any reason then we may proceed to delete all information that you have stored on the Service. We therefore recommend that you save copies of all information that you wish to keep on another storage device apart from the Service.
If we terminate your access to the Service for material breach of these terms (including non-payment of any sums due by you-where applicable) then you shall remain liable for any such sums and for any other sums which you have contracted to pay prior to such termination, whether or not such charges relate to Services to be provided before or after such termination date and whether.
15.5 In the event that we decide to permanently withdraw the Services then we shall communicate this decision using such means as we shall deem. However please remain aware that depending on the nature of the reason for the suspension, change or termination of the services it may not always be possible to give advance notice. Consequently AAR shall not be liable to you for any ensuing loss or damages occasioned to you from such a suspension, change or termination. Termination shall however not affect the accrued rights and liabilities of either you or us.
You may terminate your use of the Services at any time by sending a message to the email address info@aar.co.ke or following such other instructions as may be communicated on the website or contacting us, as set out above. Termination of the Service will not affect your obligation to pay for Services used by you or any third party services or goods previously purchased using the Services.
Identify in sufficient detail the copyrighted work or intellectual property that you claim has been infringed so that we can locate the material. For example, “The copyrighted work is my content that appears at https://www.mycontentpage.com/content If multiple copyrighted works at a single online site are covered by your Notification, you may provide a representative list of such works at that site.
Identify the URL or other specific location on the application or website provided by us that contains the material that you claim infringes your copyright described in Item 1 above. You must provide us with reasonably sufficient information to locate the alleged infringing material. For example, “The content at the following URL infringes on my copyright: https://www.anothercontent.com/content.Provide the electronic or physical signature of the owner of the copyright or a person authorized to act on the owner’s behalf.Include a statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law.Include a statement by you that the information contained in your Notice is accurate and that you attest under the penalty of perjury that you are the copyright owner or that you are authorized to act on the owner’s behalf.Include your name, mailing address, telephone number and email address. You may submit your Notification of Alleged Copyright Infringement to our Head Office by fax, mail, or E-Mail as set forth below:
Phone: +254 20 2895000
Fax: +254 20 2715328
E-Mail: privacy@aar.co.ke
Please note that you may be liable for damages, including court costs and legal fees, if you materially misrepresent that content on our website and/or application is copyright infringing.Upon receiving a proper Notification of Alleged Copyright Infringement as described in this Section A, we will expeditiously remove or disable access to the allegedly infringing material and promptly notify the alleged infringer of your claim. We also will advise the alleged infringer of the Counter Notification procedure described below in Section B by which the alleged infringer may respond to your claim and request that we restore this material. If we receive a Notification of Alleged Copyright Infringement that does not contain all of the information described above, but provides a way for us to contact you, we will promptly follow up with you to request that you provide any information not previously provided.
For any questions or concerns regarding your data privacy, including data access requests, complaints, or inquiries about our data protection practices:
- You can contact our customer service team at 254 703 063 000 and info@aar.co.ke
- You can also contact our Data Protection Officer at privacy@aar.co.ke
Service Update on Technology Partner
Service Update on our Claims Management Process
At AAR Insurance Kenya (AIK), we are committed to continuously improving your experience and optimizing our operations to serve you better. As part of our digital transformation journey, we are pleased to announce a significant enhancement to our claims processing services.
Dear Esteemed Client,
We are currently in the process of a digital transformation aimed at improving our services and optimizing operations. As part of our ongoing commitment to delivering exceptional service, we are implementing a strategic decision to optimize member experience and fully manage our claims processing digitally. As AAR Insurance - Kenya (AIK) we are pleased to announce an expansion of our collaboration with M-TIBA (Carepay Limited), our health technology partner. This strategic partnership will streamline our customer service and claims management processes, to enhance efficiency and accuracy. By leveraging M-TIBA's expertise, we will dedicate our resources even more effectively to meet your insurance needs with the highest standards of excellence.
Notable benefits arising from the digitization process include:
- Optimized Customer Experience: Members can now access their Outpatient and Inpatient benefits real time, and have continued customer service support 24/7 on their mobile phone.
- Enhanced Efficiency: The specialised expertise of our chosen technology partner M-TIBA will lead to faster turnaround times in service delivery.
- Improved Customer Service: Our customer service teams are dedicated to addressing your individual needs and concerns, for a more personalised experience.
- Technological Advancement: Use of cutting-edge technology to enhance the overall efficiency of claims management.
- Upgrade from photo card to virtual M-TIBA: With this upgrade, the Inpatient only cover customers can view their benefits balance by dialling *253# and selecting 2. MY M-TIBA
We wish to notify you that your personal data with us shall be shared with M-TIBA in order to administer your policy and receive services efficiently.
AAR Insurance- Kenya (AIK) is committed to upholding the highest standards of data security and privacy, to ensure the complete confidentiality and integrity of your information. Please visit our website for more details about our data privacy – https://aar-insurance.com/policy-center/ and the link with more details on accessing benefits and onboarding – https://mtiba.com/aar-health-insurance-through-m-tiba/
For any queries, please reach us through our customer service team on info@aar.co.ke.
We sincerely appreciate your continued trust in AAR Insurance, and look forward to continue serving you with great efficiency and effectiveness.
Dear Esteemed Client,
At AAR Insurance Kenya (AIK), we are committed to continuously improving your experience and optimizing our operations to serve you better. As part of our digital transformation journey, we are pleased to announce a significant enhancement to our claims processing services.
We are transitioning the processing and payment of SMART claims to our health technology partner, M-TIBA (Carepay Limited). This move is designed to streamline operations, improve service efficiency, and enhance your overall claims experience.
The AAR and M-TIBA Partnership
- M-Tiba (Carepay Limited) is a health technology company specializing in claims processing and management.
- AAR Insurance Kenya (AIK) has entered into a strategic collaboration with MTIBA for provision of claims management services. This partnership is driven by our commitment to providing exceptional member experience. By leveraging on M-TIBA’s advanced digital claims processing capabilities, we aim to provide faster, more efficient, and seamlessly integrated claims processing services.
- This partnership has been reviewed and approved by the Insurance Regulatory Authority.
What The Change Means for You
- No changes on insurer or cover benefits: AAR will remain your health insurance provider. Your policy and cover benefits will continue to run for the policy cover period.
- No changes in the claims submission process: The claims submission process will remain the same. You can continue submitting your claims through the channels and procedures that have been communicated to you.
- No changes in healthcare providers: You will still have access to the same healthcare providers, allowing you to receive services as you have been, with no disruption to your existing care arrangements.
- Data Sharing between AIK and M-TIBA: To facilitate, streamline, and enhance claims processing, relevant data will be shared between AAR Insurance and MTIBA Limited, subject to applicable laws and regulations.
- Data Privacy and security: We prioritize the protection of your personal information. All data shared with M-TIBA will be managed with the utmost care and in full compliance with applicable data protection laws and regulations. Both AAR Insurance Kenya and MTIBA have implemented robust security measures, including encryption, access controls, and regular audits, to safeguard your data from unauthorized access, loss, or misuse. Additionally, your information will only be shared to the extent necessary for the efficient processing of claims, and we will always ensure your privacy and confidentiality are maintained. Please visit our website for more details about our data privacy: https://aar-insurance.com/policy-center/
- Claims Payment:
What Should You Do if You Have a Question or Concern Regarding Your Policy or a Claim?
If you have any questions or concerns about your policy or the changes to the claims processing, our customer service team is here to assist you. You can reach us through the following channels:
- Email: info@aar.co.ke
- Phone: 0703063000 / 0730063000
- Website: https://aar-insurance.com/
Our team is dedicated to addressing your inquiries promptly and ensuring that you fully understand any updates or adjustments to your coverage. Your satisfaction and peace of mind are our top priorities.
We sincerely appreciate your continued trust in AAR Insurance, and look forward to continue serving you.





