Effective Date: March 2025
Welcome to the GenNetwork App, operated by Generali Life Assurance Philippines, Inc. (GLAPI). Your privacy and data security are of utmost importance to us. This Privacy Notice explains how we collect, use, protect, and manage your personal data, in compliance with the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC).
Generali Life Assurance Philippines, Inc. (GLAPI) serves as the Personal Information Controller (PIC) for all personal data collected and processed through the GenNetwork App.
Our Services:
GLAPI provides life insurance, including health benefits as riders to life insurance policies, along with related services designed to protect and secure our customers’ financial and personal well-being. To uphold our commitments, we maintain a broad network of medical providers who support us in delivering quality care and services to our customers.
App Features:
The GenNetwork App enables users, belonging to our medical network, to:
- Easily request or validate a Letter of Authorization (LOA).
- Process claims for services rendered to our clients, including payment requests and tracking.
- Access real-time updates on claim statuses and approvals, and receive automatic notifications relevant to you.
- Verify client eligibility and policy details for seamless service provision.
- Securely communicate with GLAPI for support and clarifications.
- Manage billing, payments, and reimbursement records efficiently.
Users of GenNetwork will not be subject to marketing activities. Accordingly, any data collected or processed through GenNetwork will not be used for marketing purposes related to our products or services.
Additional Data Processed for Claims Verification:
To verify that the services are effectively rendered and process your claims as soon as possible, we may process the full name, policy number, company name, member status, period covered, mobile numbers, and email address of our customers. These details must only be used for service verification and claims processing, and strictly in accordance with data privacy regulations.
Please ensure that consent has been obtained freely and explicitly before using this information for these purposes. You are prohibited from using it for any other professional purposes or retaining it unless necessary for the medical procedure and the patient’s health, and only with explicit consent. All information must be treated as highly confidential, shared only with authorized personnel, and protected with strong security measures. Under no circumstances may you disclose this information to third parties without explicit consent, except when required by law or contractual obligations with GLAPI.
What Personal Data We Collect:
- Identification Details: Full name, and date of birth.
- Contact Information: Email address, and phone number.
- Account Details: Network supplier number, hospital affiliation, and claims records.
- Claims Information: Details related to services rendered, including the type of medical services, dates, and amounts involved, to process claims efficiently and validate coverage.
- Health Information: Letter of authorization for GLAPI clients, which may include diagnoses, treatments, and other medical data necessary for claims or benefits processing.
- Financial Information: Bank details, credit/debit card numbers, and billing information (as applicable). In certain instances, and under the responsibility of the members of our medical network, we may also process through GenNetwork the full name, policy number, company name, member status, period covered, mobile numbers, and email address of our customers.
What is the Manner and Timing of Collection?
- Data Previously Provided: Some data may have already been shared with GLAPI during the accreditation process to be onboarded as a medical provider.
- Data You Provide Directly: Medical providers may input or update personal and sensitive data directly in the app during registration or through its features.
- Data Collected Automatically: Technical data, such as device information collected solely for the creation of a token for each device enabling the receipt of notifications if activated, IP address restrictions to ensure that GenNetwork is accessible only within the Philippines’ territory, and app usage to ensure a seamless connection, with tracking limited to the number of users and any application crashes, if they occur.
GenNetwork does not store or collect IP addresses from user devices. We will never collect your
geolocation data.
How We Use Your Personal Data:
We process your data for the following purposes:
- Service Delivery: To manage the medical services you provide to our customers, process claims, validate letters of authorization, and enable app-based functionalities.
- Communication: Sending updates, claims/payment-related notices, reminders, and follow-ups, as well as responding to inquiries regarding service availability.
- Network Support: To assist with your account management, respond to your queries, and address service-related concerns.
- Compliance and Legal Obligations: To meet regulatory requirements mandated by the Insurance Commission, the Bureau of Internal Revenue, and other authorities. This includes verifying transactions, reporting as required, and ensuring compliance with financial crime regulations such as anti-money laundering, counter-terrorist financing, international sanctions, and anti-bribery laws.
- Security and Data Protection: Ensuring the integrity and security of your data against unauthorized access, loss, or misuse.
- Fraud Prevention and Detection: To prevent, detect, and prosecute fraudulent activities, including exaggerated or falsified claims, unauthorized use of the app, and identity verification.
- User Experience Enhancement: To improve the functionality of the app, personalize your experience, and troubleshoot technical issues.
- Network Insights and Service Improvement: To analyze service usage, understand provider engagement, and enhance our medical network offerings through feedback, voluntary participation in satisfaction surveys, and data analytics.
The processing of personal data for the purposes outlined in points 1, 2, and 3 above is necessary for the provision of insurance services by GLAPI and/or the execution of contracts, including the agreement between GLAPI and the network supplier. If this involves the processing of sensitive personal information, explicit consent must be provided, if not already given.
The processing of personal data for the purposes outlined in points 4 and 5 above is required to comply with the legal obligations to which GLAPI is subject.
The processing of personal data for the other purposes mentioned above is based on GLAPI’s legitimate interests, including the identification and prevention of potential insurance fraud, the protection of the insured community, and the enhancement of the efficiency of our relationships. In cases of proven fraud, GLAPI may initiate criminal proceedings and take relevant measures to safeguard its interests and those of its customers. Where processing is based on your consent (e.g., sharing feedback or participating in network satisfaction surveys as mentioned in point 8), explicit consent will be requested. You may withdraw your consent at any time.
We ensure that decisions involving your personal data, particularly those with significant impact, will always involve human intervention. GLAPI does not rely on automated decision-making systems. All decisions are reviewed and made by a GLAPI employee, ensuring fairness and consideration of your rights.
With whom is your Personal Data Shared?
We may share your personal data with:
- Third-Party Service Providers: These include companies that support our operations, such as IT services, app hosting, payment processing, and gathering customer feedback through satisfaction surveys. They also assist in preventing financial crimes (including combating insurance fraud) and ensuring compliance with applicable laws and regulations (e.g., AML/CTF and international sanctions). Additionally, we may use providers to securely maintain our files, ensure information availability, and uphold the integrity and confidentiality of your data.
- Regulatory Authorities: Such as the Insurance Commission, Bureau of Internal Revenue (BIR), or other government agencies, as required by law.
- Banks and Financial Institutions: For managing payments.
- Legal Obligations: We may disclose your data to comply with legal requirements, court orders, or regulatory audits.
We do not and will never sell your personal data to third parties.
Where is data stored?
Personal data will be stored and processed securely within the Philippines. It will be retained in GLAPI’s secure systems and servers, hosted on a secure external cloud server, with access strictly limited to GLAPI. We ensure full compliance with both local and international security standards.
In addition, data will not be transferred to any foreign entity or country without explicit consent and in full accordance with applicable laws.
How long will data be retained?
We will retain personal data:
- For as long as necessary to fulfill the purposes outlined in this Privacy Notice.
- In compliance with legal requirements, such as retention periods mandated by the Insurance Commission, Bureau of Internal Revenue, or other regulatory bodies, and to ensure the fulfillment of our contractual obligations.
If no longer required, data will be securely deleted, anonymized, or destroyed in accordance with our data retention policy.
What are your rights as a data subject?
At GLAPI, we are committed to upholding your rights as a data subject and ensuring that your personal data is processed transparently, securely, and in full compliance with the law. Under the DPA, you have the following rights:
- Right to Be Informed: Know why and how your data is being processed.
- Right to Access: Request a copy of your personal data.
- Right to Object: Refuse the processing of your data for non-essential purposes.
- Right to Erasure: Request deletion of your data if it is no longer necessary.
- Right to Rectification: Correct any inaccurate or outdated data.
- Right to Data Portability: Obtain a copy of your data in an electronic format.
- Right to File a Complaint: Lodge a complaint with the National Privacy Commission if you believe your rights have been violated.
- Right to Damages: Seek compensation for any damages caused by unlawful processing of your personal data.
To exercise your rights, you may contact us at the details below.
What measures does GLAPI take to protect personal data?
We employ robust security measures to protect your personal data, including:
- Encryption of sensitive data during transmission and storage.
- Regular security audits and vulnerability assessments.
- Role-based access controls to restrict unauthorized access.
- Secure disposal of records and devices containing personal data.
While no system is entirely foolproof, we take all reasonable measures to protect your data.
How does GLAPI use cookies and analytics?
The GenNetwork App uses cookies and similar technologies to:
- Enhance your experience.
- Monitor app performance and usage trends.
You can manage cookie preferences through your device settings.
Third-Party Links
The app may contain links to third-party websites or services. This Privacy Notice applies only to the GenNetwork App. We are not responsible for the privacy practices of third parties.
Contact Us
If you have questions, concerns, or wish to exercise your rights under the DPA, please contact us:
Data Protection Officer (DPO)
Generali Life Assurance Philippines, Inc.
10th Floor, Petron Mega Plaza Building, 358 Sen. Gil Puyat Avenue, Makati City
Email: privacy@generali.com.ph
You may also contact the National Privacy Commission:
Website: https://www.privacy.gov.ph
Updates to this Privacy Notice
We may update this Privacy Notice as needed. Any significant changes will be communicated via the app or other appropriate channels.
By using the GenNetwork App, you acknowledge that you have read, understood, and agreed to the terms outlined in this Privacy Notice.
Thank you for trusting GLAPI!
