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Personal Data

BRIEFING OF NATURAL PERSONS ON PERSONAL DATA PROCESSING ΒΥ EUROPEAN RELIANCE GENERAL INSURANCE CO. S.A.


1. General Information

EUROPEAN RELIANCE GENERAL INSURANCE CO. S.A. (hereinafter "European Reliance") is a comprehensive insurance company which is active in all modern insurance sectors. It provides full insurance coverage to individuals and companies. It is registered in Greece, having its headquarters in Chalandri, 274 Kifisias Avenue, telephone number +30 210 6829601, e-mail info@europisti.gr.The European Reliance Group also includes the subsidiaries "European Reliance Asset Management M.F.M.S.A." and "Alter Ego S.A.".
Within the context of its activities, European Reliance maintains and processes Personal Data, as well as Special Category of Personal Data, in order to support, promote, and enforce its contractual relationship with its customers, to protect transactions, and to inform customers on the provided services. European Reliance acts mainly as a Data Controller or Joint Controller and, where appropriate, as Data Processor, in accordance with the General Regulation (EU) 2016/679.

2. Purpose of Personal Data Processing / Personal Data of Special Category

In order for your insurance policy to be issued, you are required to state the Personal Data / Special Category of Personal Data listed in the corresponding fields of the Insurance Application (hard copy or electronic) or in any other future Application (i.e. modification Application, claim, purchase Application, etc.). Your Personal Data are notified to the Company through its employees, or the cooperating insurance intermediaries.

Such data are maintained and processed by European Reliance, since they are objectively essential for the insurance risks assessment, the premiums calculation, the determination of general and special conditions of the insurance policy and in general for the fulfillment of the purpose and operation of the insurance policy.
Moreover, the processing contributes to the evaluation, audit and settlement of the insurance claims in the event of materialization of the insurance risk or payment of the provided amount (compensation), according to the terms of the insurance policy.

The obligation of filling out Personal Data / Special Category of Personal Data and other information required by European Reliance in the Insurance Application, as well as the all necessary accompanying documents, is based on the Legislation on Private Insurance, indicatively Law 2496/1997 (Insurance Policy), Law 489/1976 (Compulsory insurance against civil liability arising from motor third party liability accidents) and Law 4364/2016 (Solvency II), e.t.c.
For as long as the insurance policy remains in force, European Reliance will process the data essential for its operation, based on the consent granted by you at the stage of filling in the Insurance Application or at any other later stage.
Any inaccurate, untrue, or incomplete information on the data requested in the insurance Application, and in any other document pertaining to the insurance, may establish a right on the part of European Reliance to cancel or terminate your insurance policy at any time.
In the event that Personal Data have not been provided by you through the Insurance Application, or through the accompanying documents but through another way ( i.e. from information granted through the technical and scientific advisors of the Company at the preliminary audit, through the Traffic Accident Investigation Report, the Accident Statement, the Accident Care, etc., in the capacity of a third party victim or motor vehicle accident witness) please be advised that European Reliance maintains a strict Personal Data Protection Policy in processing your personal data, which has been thoroughly communicated to the personnel and sales network and its implementation is regularly checked.

3. Type of Personal Data Processing / Special Category of Personal Data

Upon receipt of the filled-in Insurance Application, European Reliance proceeds, for the aforementioned reasons, to each action or series of actions of personal data processing (whether or not by automated means), such as collection, recording, organization, correction, storage, adaptation, alteration, retrieval, search for information, use, erasure, or destruction.
European Reliance may make use of automated means, e.g. for estimating insurance risks, fair determination of premiums, etc. In any case, Applications for all insurance sectors (both hard copy and online) are evaluated by a competent employee or associate of European Reliance.
Within the context of protecting its legitimate interests, European Reliance often performs quality controls and claims analysis, through automated means, for reasons of fraud prevention. The automated process is always monitored by the competent department of European Reliance.
With regard to Life insurance products, the following separated processes (automated or not) are implemented with the purpose of European Reliance compliance with provisions of the European and Greek legislation:
  • Controls to prevent the use of European Reliance products for purposes of anti - money laundering and/or terrorist financing (Law 3691/2008).
  • Controls and dispatch of information and data for the purpose of European Reliance compliance with the national and international regulatory framework for automatic exchange of financial information on tax matters (Law 4428/2016 and Law 4378/ 2016).
  • Any processing for the processing of European Reliance compliance with FATCA, that concerns only natural persons indicated to be of American citizenship / tax residence (Law 4493/2017).

4. Time periods for Retaining Personal Data / Personal Data of Special Category

European Reliance will maintain (in hardcopy and/or electronic form) and process your personal as long as the policy is effective. In the event that this is terminated for any reason, European Reliance will retain your data for as long as it is required under current legislation or up to the time-limit of any relevant claims with maximum time period twenty (20) years. In case of non-conclusion of an insurance policy, European Reliance may maintain the personal data you stated at the precontractual stage for time period up to five (5) years after their submission, depending on the existing policy in force for destruction of data. The above are valid, provided that no legal dispute is pending for longer than twenty years and up to the closure of case with irrevocable judicial decision.

5. Rights of Natural Persons

In accordance with General Regulation (EU) 2016/679, you have the following rights:
  • The right of access, namely the right to obtain a confirmation from European Reliance as to whether or not your data are processed and, if yes, for what purpose, for how long, and who the recipients are.
  • The right to correct any deficiencies or inaccuracies in your data.
  • The right to delete ("right to be forgotten") your data from European Reliance files, provided that their processing is no longer necessary, as provided for in paragraph 4, above.
  • The right to restrict processing, in the event of proven inaccuracy of personal data, etc.
  • The right of portability, that is the right to receive your data from European Reliance in a structured and commonly used format, if this is technically feasible, so that you may forward them to another data controller.
  • You may, at any moment, oppose the processing of Personal Data / Special Category of Personal Data, for the purposes of the insurance policy, by withdrawing your consent. However, this will lead to the termination of the insurance policy for a significant reason and to non-coverage in the event the risk actually occurs, as no insurance policy may operate without processing of the above data of the insured person.
If the revocation of the consent takes place in a precontractual stage, then European Reliance has the right to deny the conclusion of the policy.

The above rights are exercised at no cost to you by sending a relevant letter or via e-mail to the Data Protection Officer (see paragraph 10 below). In case you request additional actions and copies, European Reliance may impose the payment of a reasonable charge for administrative costs.
In case you exercise any of your aforementioned rights, European Reliance will take every possible measure to respond to your request at the latest within thirty (30) days of receipt, informing you either regarding its fulfillment, or regarding objective and legal reasons which prevent its fulfillment.

Upon your notification by European Reliance, this deadline may be extended by a further period of two months, if necessary, taking into account the complexity of the request and the number of requests.

6. Children’s Personal Data Processing

For minors under 15 (or the age provided by the Law) that participate in the insurance policy with the capacity of the insured person or beneficiary, the processing of their personal data is lawful only if and to the extent that the person having the parental care of the minor grants the consent or approves the personal data processing. When the minor reaches the age of 15 (or the age provided by the Law), the minor must give the consent in person for the processing of personal data by European Reliance.

7. Forwarding Data to Third Parties

Your data may be forwarded to any operational unit of European Reliance for the proper and smooth operation of the insurance policy.
Your data may be forwarded to third parties (legal entities or natural persons) with which European Reliance maintains contracts for your proper compensation, according to the terms of your insurance policy, as well as for the assessment of claims.

Forwarding your data depending your insurance program
Also, both in the context of your insurance policy proper operation and for the purpose of fulfilling their legal obligations, European Reliance may, in case needed, depending on your insurance program, forward your data to legal entities and/or natural persons, as indicatively:
  • Your Insurance IntermediaryInsurance Companies (for the needs of the Amicable Settlement-SAP),
  • In Reinsurance Companies in European and Non- European Countries,
  • In Nursing Facilities, Diagnostic- Coordination Centers, Doctors, etc.
  • Claims Investigators, Experts, Attorneys, etc.
  • In road assistance, courier, archive and file management, telephone services companies, etc.
  • In the Informatics Division of the Hellenic Association of Insurance Companies, the Information Center and the International Insurance Bureau
  • In Car Stations
  • In co-operating Banking Institutions (etc. in the event of issuing credit cards for servicing the insurance product, paying compensations, etc.).
However, legal entities and/or natural persons will process your personal data for the exclusive purpose of providing services to European Reliance and not for their own benefit, acting as data processors and having been bound in writing to confidentiality, protection of personal data, and Information Security.
Your data may also be forwarded to Public and Judicial Authorities, Public Organizations and Supervisors on the basis of specific legal provisions with which European Reliance must comply.
Your data may be forwarded, made accessible, and be processed also by other European Reliance subsidiaries.
At each and every data transmission, European Reliance takes all measures to ensure that the data forwarded are always the minimum necessary and that the conditions for lawful and legitimate processing are always met.

8. Processing of Personal Data for Marketing or Research Purposes

European Reliance may process the personal data submitted by you (phone number, e-mail etc.), by asking you each and every time to provide clearly separate and special consent regarding the following purposes:
  • To receive, according to your choice, updates on new product or service offers throughout your policy period and for up to 36 months after its expiry.
  • To receive updates products or services of European Reliance or its subsidiaries.
  • To conduct customer satisfaction surveys regarding the products and services provided by European Reliance, as well as insurance mediators you may be cooperating with.
Moreover, for the fulfillment of the purpose above, the Company may transfer personal data to cooperating research and promotional companies.

You may modify and/or withdraw your consent for the collection and use of Personal Data for the above purpose at any time, in writing or via the Customer Service Department (Tel.+30 210-8119670, email helpcustomer@europisti.gr).

9. European Reliance Data Security

The security of your personal data is extremely important to us and for this reason we take and implement all appropriate organizational and technical measures to ensure that the data we collect are adequately protected and processed in accordance with the requirements of the applicable legislation.
European Reliance applies an Information Security Management System in accordance with the international standard ISO/IEC 27001:2013 and since 01/11/2017 has been certified by the Certification Body TUV HELLAS (TUV NORD) S.A. According to this System, in addition to technical security measures, European Reliance has also adopted corresponding Information Security Policies and Procedures for the protection of your personal data.
The adopted Information Security Policy consists of a set of rules that determine the way in which European Reliance manages and protects its Information Assets. These rules determine the role played by anyone within European Reliance involved with data, their competences, responsibilities, and duties.
The Primary Purposes of the Information Security Policy include, among others:
  • Protecting European Reliance data.
  • Ensuring European Reliance customers’ confidence.
  • Ensuring compliance with the Greek legal and institutional framework (Greek legislation).
  • Specifying the Organization’s security level and requirements.
  • Establishing mechanisms supporting the identification and prevention of threats to European Reliance information, as well as the organization’s efficient response should such threats become a reality.
  • Specifying Company member roles and responsibilities, in order to achieve the protection of information and information assets.
  • Raising awareness about the risks the Company information and IT systems are exposed to.
The Information Security Policy full text can be found at www.europaikipisti.gr and more specifically here.

10. How to Submit a Complaint / Protest

For any matter pertinent to the processing of Personal Data, you may contact the European Reliance Data Protection Officer (DPO) (tel. +30 210 8119670, email dpo@europisti.gr).
Also, you maintain the right to contact the Personal Data Protection Authority, which receives relevant complaints submitted either in written form at its Protocol Department (1-3 Kifisias Avenue, Postal Code 115 23, Athens, Tel. +30 210-6475600 / Fax +30 210-6475628) or electronically at contact @dpa.gr. Furthermore, you always maintain the right to appeal to the Greek Courts.
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