1. INTRODUCTION
BY ACCESSING OR USING OUR WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY AND CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED HEREIN.
Chedid Insurance Brokerage ("we", "us", or "our") values your privacy and is committed to safeguarding your Personal Data. This Privacy Policy (the "Policy") applies to our website Compare360.com (the "Website") and to the services we provide through it, as further described in our Terms of Use (the "Services").
The Policy outlines our practices regarding the collection, use, disclosure, and protection of the Personal Data of our users ("you") in line with the Lebanese Law No. 81 of 2018 on Electronic Transaction and Personal Data and any amendments or implementing regulation thereof (the "Lebanese Data Protection Law"), in addition to any other applicable data protection legislation (together the "Data Protection Laws"), and the relevant regulations and guidelines issued by the Lebanese Ministry of Economy and Trade ('MoET') and the Insurance Control Commission ('ICC').
To provide you with the Services, we act as the intermediary between you and the third-party insurance providers whose products are displayed and generated on the Website ("Third-Party Insurance Providers"). These providers may have access to your Personal Data and are bound to process it in compliance with this Privacy Policy and strictly for the purpose of delivering their services.
Nevertheless, any Personal Data they collect directly from you is subject to their respective privacy policies. We encourage you to carefully review the respective privacy policies of these Third-Party Insurance Providers to understand how each of them processes your Personal Data and protects your privacy.
2. WHAT IS PERSONAL DATA
"Personal Data" refers to any information relating to an identified or identifiable natural person. A person is identifiable if they can be identified, directly or indirectly, in particular by reference to identifiers such as a name, identification number, contact details, location data, or to factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.
In the context of our Services, this may include information such as age, health-related data, driver or claims history, financial information, employment details, and any other data necessary for assessing eligibility, underwriting, pricing, or issuing insurance products.
3. WHY WE COLLECT YOUR PERSONAL DATA
We collect and process your Personal Data solely for legitimate, specific, and clearly defined purposes in accordance with the Lebanese Data Protection Law. Depending on the nature of the interaction, we determine the purposes and means of processing independently. Where Personal Data is shared with Third-Party Insurance Providers, such providers act as independent controllers in respect of any processing they carry out for their own purposes.
Our primary purpose in collecting your Personal Data is to provide you with accurate, relevant, and customised insurance price comparison services and to facilitate your interaction with the insurance products available on our Website. Accordingly, the Personal Data you provide on our Website is collected, used, and processed for the following purposes:
- Service delivery: generating insurance quotes tailored to your needs and preferences and processing your inquiries or transactions.
- Customer support: responding to your questions, assisting you with the Website, and following up on requests.
- Service Improvement: enhancing Website functionality, performance, security, and user experience.
- Communication: contacting you regarding your requests, updates, or feedback.
- Marketing (with consent): sending offers, promotions, or updates.
- Compliance: meeting legal, regulatory, and reporting obligations.
- Advisory: assisting you in understanding insurance options and related policy terms.
- Joint Controller Arrangements: In exceptional cases, and only where required by applicable law, we may act as a joint controller, in which case we will make available the information required under the Lebanese Data Protection Law regarding the allocation of responsibilities.
When you select a quote and proceed with the purchase of an insurance policy offered by any Third-Party Insurance Provider through the Website, you will be presented with two payment methods:
- Online Payment: If you choose to pay online, you will be redirected to a secure payment gateway operated by our partnered payment service provider (the "Payment Service Provider"), who will process your transaction directly. We do not collect, store, or have access to any card numbers, banking credentials, or other financial details entered on the payment gateway. We may receive only limited transaction-related information (such as confirmation of receipt of payment). For more details, please refer to our Terms of Use.
- Cash on Delivery: Alternatively, if you select the cash-on-delivery option, payment will be collected by our authorised representatives at the time of insurance policy delivery.
Certain transaction-related data may be collected either by our partnered Payment Service Provider or by us, depending on the chosen payment method. Such data is processed strictly for the following purposes:
- To process, verify, and confirm your payment and, where applicable, issue refunds;
- To respond to your inquiries or requests you may have regarding your payment;
- To support you with any payment-related services provided through the Payment Service Provider or our customer support channels.
4. TYPES OF PERSONAL DATA WE COLLECT
We may collect different categories of Personal Data through our Website depending on how you interact with our Services and the information you choose to provide. The main categories include:
Personal Information: such as your name, contact information (email address and phone number), date of birth, nationality, salary information, and any other relevant identification details necessary to generate personalised insurance quotations.
Insurance Information: details relating to your insurance needs and preferences, including information about existing insurance policies, driving history, claims history, and other data relevant to generating and/or comparing insurance products.
Health Information: health-related data necessary to assess your eligibility for, or pricing of, health insurance products. Such information is collected only where required, and always on the basis of your explicit consent or any required authorisation from the competent authority (e.g., the Lebanese Ministry of Public Health).
Travel Information: details such as your intended travel destination, travel dates, and duration, when you request travel insurance quotations.
Website Usage Data: technical information automatically collected through your interaction with our Website, including IP address, device information, browser type and version, operating system, pages visited, referral URLs, and the date and time of your visits. This information helps us maintain and improve the security, functionality, and performance of our Website.
Anonymised and Aggregated Statistical Data: We may also collect anonymised and aggregated statistical data, such as demographic breakdowns (e.g. average age or geographical allocation of users), number of visits, and browsing patterns. This information does not identify you personally and is used exclusively for analytics and service-improvement purposes.
Third-Party Insurance Providers may store and process your Personal Data in accordance with the data minimisation and storage limitation principles set out in the Lebanese Data Protection Law. They will retain your Personal Data for as long as necessary for the purposes mentioned above or as required by applicable law, which may extend beyond the end of your relationship with them. Certain information may be retained, for instance, to prevent fraud or future misuse, ensure the integrity of insurance operations, support account recovery, or comply with legal obligations.
All retained Personal Data will continue to be handled in accordance with the terms of this Privacy Policy. If you request that certain Personal Data be removed from our databases, we will take reasonable steps to do so; however, some data may need to be preserved to meet legal, regulatory, or technical requirements.
5. DATA RETENTION
We retain your Personal Data only for as long as necessary to fulfil the purposes described in this Policy or to comply with legal, regulatory, or contractual obligations.
We apply strict data minimisation and retention-limitation principles and periodically review the Personal Data we hold to ensure that it remains relevant and necessary.
When your Personal Data is no longer required for the purposes for which it was collected, we will take appropriate steps to delete, anonymise, or securely archive it, unless a longer retention period is required or permitted by law (for example, to comply with regulatory requirements, resolve disputes, prevent fraud, or enforce our agreements).
Where anonymisation is applied, the data will be processed in a form that no longer allows you to be identified, and may be used for statistical, analytical, or service-improvement purposes.
6. HOW WE COLLECT YOUR PERSONAL DATA
We collect your Personal Data through various means depending on how you interact with our Website and Services. These include:
- Registration, forms, and account creation: when you complete online forms, request insurance quotations, or create an account on our Website.
- Communications and customer support: when you contact us by email, telephone, or through our customer service channels for assistance, inquiries, or follow-ups.
- Automated interactions: when you browse or use the Website, certain technical data may be collected automatically through cookies, log files, and/or similar tracking technologies, as described in our Cookies and Tracking section.
In certain cases, Third-Party Insurance Providers may also collect your Personal Data directly from you -- for example, when they contact you to complete an insurance application, verify information, or issue a policy. In such instances, those Third-Party Insurance Providers act as independent controllers of your Personal Data and are solely responsible for processing it in accordance with their own privacy policies.
We will seek your express consent to collect, use, or disclose your Personal Data whenever required by law. In particular, we will seek your express consent:
- when processing involves Sensitive Personal Data (e.g., health or financial information),
- when contacting you for marketing or promotional communications, or
- when we need to process your Personal Data for a new purpose from the one originally communicated to you.
Consent may be obtained by checking a box, submitting a form, accepting an online agreement, or performing another clear and affirmative action demonstrating your agreement.
7. SHARING OF YOUR PERSONAL DATA
We may share your Personal Data only as necessary to operate, maintain, and improve our Services, and always in accordance with the Lebanese Data Protection Law and other applicable Data Protection Laws. We do not sell or disclose your Personal Data to third parties except as described below.
We may share your Personal Data with:
- Our affiliates, employees, agents and authorised representatives for internal audit, management, billing, administrative, compliance, legal, other legitimate business purposes. We may only use your Personal Data for marketing and promotional purposes with your prior consent.
- Third-party service providers who support our operations, whether in-house or outsourced, such as IT hosting providers, analytics platforms, communication tools, payment processors, or customer support systems. These providers act as data processors and are contractually bound to:
- process Personal Data solely on our documented instructions;
- implement appropriate confidentiality and security measures; and
- refrain from using your Personal Data for their own purposes.
- Third-Party Insurance Providers when necessary to generate insurance quotations, underwrite or issue policies, verify information, process payments, or otherwise deliver and administer the insurance products you select. Depending on the processing activity, these parties act as independent controllers of your Personal Data.
- Payment Service Providers and financial institutions to process payments, issue refunds, verify transactions, and support fraud-prevention activities.
- Public authorities and regulators, including MoET and ICC, where disclosure is required by law, regulation, or in response to valid legal or regulatory requests.
We maintain an updated internal register of all third-party service providers who process Personal Data on our behalf.
8. INTERNATIONAL TRANSFERS
Any transfer of Personal Data to a recipient located outside Lebanon will be carried out in accordance with applicable Data Protection Laws, using appropriate contractual, organisational, and technical safeguards or any other transfer mechanism recognised under applicable Data Protection Laws to ensure an equivalent level of protection.
9. YOUR RIGHTS
You have several rights relating to your Personal Data. The scope of these rights may vary depending on the legal basis for processing and the applicable Data Protection Laws. We will honour all requests in accordance with our legal obligations.
Right to Know Legal Basis
You may request information regarding:
- the legal basis on which we rely to process your Personal Data (e.g., consent, legal obligation, legitimate interest); and
- which processing activities are based on each legal basis.
Right to Know Retention Periods
You may request information about:
- how long we retain your Personal Data;
- circumstances requiring retention beyond the standard retention period (e.g., legal or regulatory requirements).
Right to Access, Correction and Deletion
You may request:
- access to the Personal Data we hold about you;
- correction of inaccurate or incomplete Personal Data;
- deletion of your Personal Data where no legal, regulatory, or operational requirement obliges us to retain it.
We will review and process your request within a reasonable timeframe, subject to applicable legal, regulatory, or technical obligations requiring us to retain certain information.
Right to Restrict Processing
In certain circumstances, you may request that we restrict the processing of your Personal Data, including where:
- you contest the accuracy of the Personal Data (pending verification);
- we no longer need the data but you require it for the establishment, exercise, or defence of legal claims; or
- you have objected to processing pending the verification of our legitimate grounds for continuing the processing.
Where processing is restricted, your Personal Data will be stored but not otherwise processed unless required by law.
Right to Object to Processing
You may object, for legitimate reasons, to the collection or use of your Personal Data, including for direct marketing purposes, unless we are required to process your data by law or where you have previously consented to such processing. Exercising this right may limit your ability to use certain features of the Website and/or the Services.
Right to Know Recipients of Data
You may request information regarding:
- the categories of third parties who have received your Personal Data; and
- the purposes of such disclosures.
Right to Withdraw Consent
You may withdraw your consent to the collection or use of your Personal Data where processing is based solely on your consent. Withdrawal does not affect the lawfulness of processing carried out prior to such withdrawal, or where we are required to retain your data for legal or regulatory purposes.
Please note that withdrawing your consent may affect your ability to access certain features of the Website and/or the Services.
Right to Opt-Out of Marketing Communications
You may opt out of receiving marketing or promotional communications at any time by following the unsubscribe instructions included in our emails.
Right to be Notified of Breaches
Where a Personal Data breach is likely to result in a risk to your rights or freedoms, you have the right to receive notification without undue delay. We will inform you of:
- the nature of the breach;
- the potential consequences;
- the measures we have taken; and
- any recommended steps you should take to protect yourself.
Right to Lodge a Complaint
If you believe that your Personal Data has been processed in violation of this Policy or applicable Data Protection Laws, you may contact us to raise your concerns. We will review and respond to your complaint within a reasonable timeframe.
You may also have the right to lodge a complaint with the competent Lebanese authority, where applicable.
Use of Automated Tool
We may use automated tools to assist in generating insurance quotations or matching you with suitable insurance providers. Such automated processing is used solely to support our services and does not involve fully automated decision-making that produces legal or similarly significant effects without human involvement.
Appropriate measures are implemented to ensure accuracy and fairness.
10. DATA SECURITY
The security of your Personal Data is of critical importance to us. We employ industry-standard technical and organisational security measures to protect your information against unauthorised access, disclosure, alteration, or destruction. These measures include, at a minimum:
- Encryption of Personal Data during transmission and, where applicable, at rest;
- Access controls, including role-based authorisation and multi-factor authentication;
- Secure server and network infrastructure;
- Security testing, vulnerability assessments, and system updates;
- Staff training on confidentiality, data-handling obligations, and security awareness.
When we share, transfer, or process your Personal Data, we do so strictly in accordance with applicable Data Protection Laws. For this purpose, we have put in place contractual, technical, and other organisational safeguards to ensure that any third party acting on our behalf provides an equivalent level of security and processes your Personal Data solely in accordance with our instructions.
We do not disclose or transfer your Personal Data to any third party except as described in this Privacy Policy.
You also play an important role in maintaining the security of your Personal Data. For instance, never give out your account credentials or passwords for the Services to third parties.
We will maintain the confidentiality of any contact information you provide to us when you sign up for our Services, marketing communications, or contact us with questions or for further information and we will use it only for the purposes for which we have collected it (subject to the exclusions and disclosures we have listed in this Privacy Policy), unless you agree that we may disclose it to other third parties.
11. DATA BREACH NOTIFICATION
In the event of a Personal Data breach that is likely to pose a risk to your rights or freedoms, we will notify you in accordance with applicable law, providing information reasonably necessary about the nature of the breach, potential risks and recommended protective steps. Following any breach, we will take reasonable measures to:
- contain and isolate the incident;
- assess its scope and impact;
- restore the integrity of our systems; and
- implement corrective measures to prevent similar incidents in the future.
12. COOKIES AND TRACKING TECHNOLOGIES
We use cookies and similar tracking technologies to enhance your browsing experience, store your preferences, understand how you interact with our Website, and improve the performance and functionality of our Services. Cookies may be used for purposes such as:
- enabling essential Website features;
- remembering your preferences for future visits;
- analysing Website traffic and usage trends;
- delivering relevant advertisements or content. You may modify your browser settings to block or delete cookies. However, disabling certain cookies may affect the functionality or performance of the Website. When you visit our Website, cookies may be placed on your browser. These may include session cookies, persistent cookies, and analytics or advertising cookies, depending on your interaction with the Website. Non-essential cookies (including analytics and advertising cookies) will only be used after obtaining your consent, in accordance with the Lebanese Data Protection Law.
13. LINKS TO THIRD-PARTY WEBSITES
Our Website may contain links to, or display content provided by, third-party websites or advertisers (such as ad networks, advertising agencies, or audience segmentation providers). These third parties may collect information about your browsing activities through cookies, web beacons, and other technologies in an effort to deliver targeted advertising or personalised content.
You acknowledge that we do not have access to, or control over, the information these third parties may collect. However, we encourage you to visit their individual privacy policy guidelines to understand the nature of their data usage in order to protect yourself from any unintended events.
We disclaim responsibility for the privacy practices, content, or security standards of any third-party website linked to our Website.
14. CHILDREN'S PRIVACY
Our services are not intended for individuals who do not have the legal capacity to use the Services under Lebanese applicable laws and regulations. We do not knowingly collect Personal Data from children or from individuals who are otherwise legally incapable of providing valid consent. If we become aware that Personal Data has been collected from such individuals, we will take prompt steps to delete the data and, where appropriate, disable the related account or request parental/legal guardian authorisation.
15. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, operational needs, legal requirements, or regulatory guidance.
When updates occur:
- the revised version will be posted on our Website;
- the "effective date" at the top of the Policy will be updated; and
- where required by law, we will notify you of material changes or seek your renewed consent.
16. CONTACT US
In compliance with the Lebanese Data Protection Law, we have appointed a Data Protection Contact Person. If you have any questions, requests, or concerns related to this Privacy Policy or your Personal Data, you may contact our Data Protection Contact Person at: complaints@compare360.com. We will review and respond to your inquiry within a reasonable timeframe and in accordance with applicable Data Protection Laws. By using our Website, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy.