Notice relating to personal data protection

The purpose of this notice is to explain how and for what purposes GENERALI BELGIUM SA uses personal data concerning natural persons (insurance policyholders, potential customers, insured parties and beneficiaries, intermediaries, etc.). Please read this notice carefully.

  • 1. Who are we?

    GENERALI BELGIUM SA, with registered office at 1050 Brussels, Avenue Louise 149 and registered at the CBE under no. 0403.262.553 (hereafter “GENERALI”) processes your personal data (hereafter “personal data”) on its own behalf, in its capacity as data controller.

    The data controller, in the sense defined in the European General Data Protection Regulation, means the natural or legal person which determines the purposes and means of the processing of personal data.

  • 2. What is personal data?

    We only process personal data strictly necessary for the achievement of the purposes set out below (see point 4). Depending on your particular situation and in particular the type of insurance concerned, GENERALI may process the following data:

  • 3. What personal data do we use?

    We only process personal data strictly necessary for the achievement of the purposes set out below (see point 4). Depending on your particular situation and in particular the type of insurance concerned, GENERALI may process the following data:

    • identification data (for example: last name, first name, address, ID card no. etc.);
    • contact data (for example: address, email address, phone number, etc.);
    • composition of the household (for example: civil status, number of children, etc.);
    • global financial overview (for example: your real estate assets, etc.);
    • profession (for example: post held, training, etc.);
    • lifestyle, consumer behaviour as regards goods and services;
    • leisure and interests;
    • dwelling characteristics;
    • recording of images and sounds.

    GENERALI may also need to process certain sensitive data, subject to special protection, such as:

    • data on your health, particularly with a view to ensuring proper management of insurance contracts related to your health (life insurance, hospitalization, guaranteed income, etc.), management of your medical record and management of a claim involving personal injury;
    • data relating to criminal convictions and offences.

    GENERALI processes these data with special care.

    We may also use data obtained from external sources, particularly in the following cases:

    • employer taking out insurance for members of its staff;
    • professional suppliers of data for data correction (for example, correction of the spelling of your address);
    • professional suppliers of data for issuance of proposals;
    • enrichment of data (in particular concerning the composition of your family);
    • publication or transmission of your data by authorized third parties or professional data suppliers.

    In certain cases, we may use personal data concerning people other than you, and for example:

    • your children, your partner, the beneficiary of a life insurance cover;
    • your staff members;
    • a person involved in the context of a claim (witness, injured third party, etc.).

    If you communicate such data to us, we ask you to inform the people concerned of this fact.

  • 4. How do we use your personal data?

    4.1. What are the purposes pursued by GENERALI?

    GENERALI will use your personal data in a reasonable manner for various purposes. For each purpose, only necessary and relevant data is processed.

    GENERALI will firstly use your personal data to fulfil its contractual obligations to you or to take pre-contractual measures at your request, in particular to:

    • analyse the opportunity to conclude an insurance contract or credit agreement and/or conditions to be imposed on concluding an insurance contract or credit agreement;
    • conclude, manage and fulfil insurance contracts forming part of the range of products and services offered by GENERALI, including managing customer relations and claims;
    • keep a record of (most recent) contacts with you, so that we know their frequency and can keep them at an acceptable level;
    • save your preferences, if and how GENERALI can contact you to provide information, publicity or proposals;
    • carry out a service that you have requested, for example, you sending us data online to subscribe to the newsletter or to request an insurance proposal.

    GENERALI will also process your personal data in order to comply with all the legal, regulatory and administrative obligations to which it is subject, in particular in terms of:

    • prevention of money laundering;
    • preventing the funding of terrorism;
    • implementation of AssurMIFID legislation;
    • combatting tax fraud;
    • tax obligations;
    • management of customer complaints;
    • requests by supervisory authorities.

    When you have given your specific consent to a particular processing, GENERALI will process your personal data for this purpose.

    Lastly, GENERALI may process your personal data for reasons arising from its legitimate interest. In this case, GENERALI will ensure it keeps a proportionate balance between the interest pursued and respect for your privacy. In this context, GENERALI will be able to process your personal data for, among others, the following purposes:

    • detection and prevention of cases of abuse and fraud;
    • protection of the company’s assets;
    • security of assets and of people, and of GENERALI’s networks and information systems;
    • reporting of any abuse causing or likely to cause serious harm to GENERALI’s financial position, results and/or reputation;
    • monitoring correct execution of operations;
    • supervision and control;
    • establishing, exercising, defending and preserving the rights of GENERALI or of the people it may represent, for example at the time of disputes;
    • gathering evidence;
    • an overview of customers (for example, compiling statistics on our customers so that we know who they are and to get to know them better);
    • qualitative controls (in particular telephone calls) with a view to evaluating and optimizing our services to our customers;
    • monitoring of GENERALI’s activities and administrative knowledge of the different persons with links to the company, that could if necessary enable identification of files, any intermediary and other involved parties;
    • testing, evaluation, simplification, optimization and/or automation of GENERALI’s purely internal processes to make them more efficient (for example, optimization/automation of internal risk assessment and acceptance processes, automation of the procedure for handling your questions and requests, etc.);
    • testing, evaluation, simplification and optimization of online systems to make your user experience better (for example, fixing bugs on our websites and mobile apps, contacting you to resolve technical problems when we find that you started to enter your data to benefit from a service but were not able to continue this process, etc.);
    • optimization and management of GENERALI’s distribution channels (in particular the brokerage network);
    • management and adjustment of authorized products;
    • satisfaction surveys;
    • prospecting; and
    • development of new products and services by GENERALI that will make us even more responsive to your needs and expectations.

    4.2. Does GENERALI use your personal data for automated decision-making?

    In the context of the purposes referred to above (point 4.1.), GENERALI may also use and analyse your personal data as a basis for automated decision-making, in other words not involving human intervention. In such a case, GENERALI will inform you about the logic involved in such decision-making and the significance and envisaged consequences of this processing.
    In this case, GENERALI will ensure that there is always a significant human intervention and/or that the profiling does not produce legal effects concerning you or which, similarly, significantly affect you.

  • 5. Why is it necessary for you to provide your personal data?

    You have the right not to communicate the personal data we request.
    If however you refuse to supply the data requested in the context of issuance of an insurance proposal, conclusion of an insurance contract or submission of an insurance claim, GENERALI may find it impossible to conclude such a contract or to carry out your intervention request.

  • 6. Who has access to your personal data and to whom are they transferred?

    To protect your privacy, the people who are authorized to access your data are determined precisely according to their tasks.

    With a view to achieving the purposes detailed above (see point 4.1.), your data may be communicated:mprise

    • to other intervening insurance companies (or to their representatives in Belgium or their contacts in other countries);
    • to the reinsurance companies concerned;
    • to claims offices:
    • to an expert;
    • to a medical advisor;
    • to a lawyer;
    • to a technical consultant;
    • to your insurance intermediary;
    • to your employer’s insurance intermediary;
    • to a subcontractor (intermediaries with whom we collaborate, private detectives for enquiries into fraud, IT service providers, marketing and communications offices, etc.) to whom GENERALI has entrusted execution of a particular processing;
    • to the Datassur ESV "files" service;
    • to Informex:
    • to other companies forming part of the GENERALI Group.

    We may also be required to communicate certain data to public authorities under legal or regulatory obligations.

  • 7. Where do we transfer your personal data?

    GENERALI may transfer personal data to States, territories or organizations:

    • situated in the European Economic Area (EEA),
    • situated outside the European Economic Area (EEA) and which are not recognized as ensuring an adequate level of protection of personal data by the European Commission. When necessary, transfer of your data will only be made on condition that appropriate and suitable guarantees exist, in compliance with applicable law.
    You have the right to obtain information on this subject and, when necessary, a copy of the guarantees provided by contacting our DPO (see point 10).

  • 8. What are your rights and how can you exercise them?

    With regard to your personal data, GENERALI guarantees you the following different rights:

    Access: You can request access to your personal data. You can also request the following information about your personal data:

    a. for what purposes we process your personal data;
    b. which categories of personal data we process;
    c. to which categories of recipients it is communicated;
    d. the storage period;
    e. the source of the processed data;
    f. the logic involved in the automated processing - including profiling - of certain personal data.

    Rectification: You can ask GENERALI to rectify any personal data that is incorrect or incomplete.

    Erasure ("right to be forgotten"): In certain cases, you can ask GENERALI to erase your personal data:

    a. when the personal data are no longer necessary in relation to the purposes for which it was collected or processed;
    b. lwhen the processing is based exclusively on your consent and you decide to withdraw this consent;
    c. when you object to automated decision-making and there remains no overriding legitimate grounds justifying the processing;
    d. when you object to processing for direct marketing purposes;
    e. lwhen your personal data have been unlawfully processed;
    f. when your personal data must be erased for compliance with a legal obligation in European Union or Member State law to which GENERALI is subject;
    g. when the personal data have been collected, on the basis of your consent or that of your parents, at a time when you were a minor;

    GENERALI may however continue to store your data when this retention is necessary for the following reasons, among others:

    a. compliance with a legal obligation;
    b. for the establishment, exercise or defence of legal claims.

    Restriction: You can ask GENERALI to restrict the way in which we process your personal data in any of the following situations:

    a. you contest the accuracy of your personal data (the restriction will apply for a period enabling GENERALI to verify the accuracy of the data);
    b. the processing is unlawful and you oppose its erasure and require restriction of its use instead;
    c. GENERALI no longer needs the personal data for the purposes of the processing but the data is still necessary to you for the establishment, exercise or defence of legal claims;
    d. you have objected to processing pursuant to the right to refuse automated decision-making (the restriction will apply for a period enabling verification on whether the legitimate grounds of GENERALI override your grounds).

    In this case, with the exception of storage, your data cannot be processed without your consent, or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or of a Member State.

    Portability: When the processing is based on your consent or on fulfilment of a contract and is carried out using automated processes, you can ask GENERALI to transmit the data you have provided to us to another data controller when this is technically feasible.

    Objection: You have the right to object at any time, on grounds relating to your particular situation, to:

    a. uprocessing of your personal data (including profiling) based on the legitimate interest of GENERALI. Your request will not be taken into consideration however if our legitimate interest overrides your own or if the processing of your data remains necessary for the establishment, exercise or defence of legal claims;
    b. processing of your personal data for prospecting purposes (including profiling).

    Withdrawal of consent: When processing is based on your consent, you can withdraw this consent at any time. You can also object to the processing of data concerning your health at any time. In this case, GENERALI may find it impossible to fulfil the relevant purpose and/or to carry out your intervention request. Such withdrawal will not call into question the lawfulness of the processing of your personal data carried out during the previous period.

    To exercise these different rights, you simply need to address your dated and signed request together with a photocopy of the front of your identity card by post or email to our DPO (see point 10).

  • 9. What to do if you suspect a personal data breach?

    If you suspect unauthorized publication or transmission of personal data, don’t hesitate to contact our Data Protection Officer (DPO) as promptly as possible by sending us this document by post or email:

    By e-mail: databreach@generali.be
    For the attention of the Data Protection Officer
    Avenue Louise 149,
    1050 Brussels
  • 10. To whom can you send your questions or requests?

    For any questions or requests relating to the processing of your personal data, please contact our Data Protection Officer (DPO) by letter or email at the following address:

    By email: dpo@generali.be
    For the attention of the Data Protection Officer
    Avenue Louise 149,
    1050 Brussels
  • 11. How can you make a complaint or a claim?

    If you think that processing of your personal data constitutes a breach of the data protection legislation, you can lodge a complaint with the Data Protection Authority whose contact details are as follows:

    Data Protection Authority
    Rue de la Presse 35
    1000 Brussels
    Tel: +32 2 274 48 00
    E-mail: commission@privacycommission.be
  • 12. For how long do we store your personal data?

    We store your personal data for as long as is necessary for fulfilment of the purposes described above (see point 4.1.). This means, for example, that we retain your data during performance of the insurance contract but also during the applicable legal limitation period.

    When there is no longer any purpose justifying storage of your personal data, we retain it only if legally required to do so.

  • 13. How can you keep up-to-date on any modifications made to this Notice?

    GENERALI may make modifications to this notice. We will inform you about any modification to the notice via our website.

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