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, active in all modern sectors of insurance, providing full insurance coverage to individuals and companies. It is registered in Greece and its headquarters are in Chalandri, 274 Kifisias Avenue, telephone number +302106829601, e-mail info@europisti.gr. European Reliance Group of Companies owns the subsidiaries “European Reliance Asset Management M.F.M.S.A.” and “Alter Ego S.A.”. 
Within the context of its activities, European Reliance retains and processes Personal Data and Special Categories of Personal Data, in order to support, promote and enforce the contractual relationship with its customers, to protect transactions and inform customers on the provided services.  European Reliance acts mainly as a Data Controller or Joint Controller and, where appropriate, as Data Processor, according to the General Regulation (EU) 2016/679.
 

2. Purpose of Processing of Personal Data 

Within the framework of your insurance coverage, it is required that you declare your Personal Data / Special Categories of Personal Data included in the fields of your Insurance Application Form (in hard copy or electronic form), in all of your future Application Forms (i.e. Amendment Form, Compensation, Purchase, etc.), as well as application forms related to your insurance coverage or briefing on the insurance products of European Reliance. The data is disclosed to European Reliance by you or your insurance intermediaries or the delegated third parties and must be true, accurate and clear.
The data is retained and processed by European Reliance, as it is objectively essential for:
a) the estimate of the underwriting risk, b) the calculation of premiums, c) the determination of general and special conditions of the insurance policy and d) the fulfillment of the objective and function of the insurance policy. 
Moreover, this processing contributes to the estimate, audit and settlement of the insurance claim in the events of occurrence of the underwriting risk or payment of the sum insured (compensation) as provided in the terms of the insurance policy. 
Regarding the Life Insurance Products, we perform individual procedures for the purpose of compliance of European Reliance with the provisions of the European and Greek legislation.
 
Audits for the prevention of the use of products of European Reliance for purposes of money laundering and/or terrorist financing, (L. 4557/2018).
Audits and dispatch of data for the purpose of compliance of European Reliance with the national and international regulatory framework on the automatic exchange of financial information in tax matters (L. 4428/2016 and L. 4378/2016).
Any relevant processing for the purpose of compliance of European Reliance with FATCA which refers to natural persons with American citizenship / residence for tax purposes (L. 4493/2017).
 
For the fulfillment of the purposes mentioned above, European Reliance requires and collects the data of the insured and third parties involved in case of occurrence of the underwriting risk (i.e. injured third parties, witnesses etc.) from third parties that cooperate or not with the Company, such as: insurance intermediaries, loss adjusters, car stations, road companies, other insurance companies, clinics, diagnostic centers, the Division of Information Technology of the Hellenic Association of Insurance Companies, etc.
 
In any case, we would like to inform you that European Reliance retains a strict Personal Data Protection Policy for the processing of your personal data, which is disclosed to the personnel and insurance agents and its implementation is audited regularly.
 

3. Legal Basis of the Processing 

The processing of Personal Data / Special Categories of Personal Data, other data and information, collected by European Reliance, within the framework of its operations and for the above purposes, is based on: 
a) the execution of the contract (insurance policy) and the actions required in the pre-contractual stage (i.e. filling in the form, submitting the offer, etc.) 
b) your consent (i.e. in case of processing of special categories of personal data, promotional acts, etc.) 
c) the compliance of the Company with its legal obligations as enforced by the applicable legislative and regulatory framework (i.e. regarding the private insurance legislation, the management of complains etc.) and 
d) service of its legal interests (i.e. the establishment and exercise of its legal rights, the prevention of insurance fraud, the management of the business functions, the operation of the IT systems, the internal audit procedures, etc.).
 

4. Type of data processing

Upon the receipt of the filled-in application forms, accompanying documents and any other information received by European Reliance within the framework of its operations, the Company proceeds, for the aforementioned purposes, to a series of acts for the processing of personal data (with or without the use of automated measures), such as, the collection, registration, organization, correction, storage, adjustment, variance, retrieval, search for information, use, erasure, or destruction.  
European Reliance may make use of the automated measures at the stage of filling in the insurance form, i.e. for the estimate of the underwriting risks, fair determination of premiums, etc.  
Moreover, within the framework of protecting its legitimate interests, European Reliance often performs quality audits and analysis of losses, through automated means for the prevention of fraud. 
 In cases of automated processing, the results arising are always audited by the competent employees or insurance agents of European Reliance and therefore no decision is taken exclusively based on the automated procedure.
 
 

5. Time period for the Retention of Personal Data

European Reliance will retain (in hard copy and/or electronic form) and process your personal data for the entire period of your contract. If the insurance policy is terminated for any reason, European Reliance will retain the data for as long as it is required under the current legislation or up to the time of expiration of any relevant claim with maximum time period twenty (20) years. 
 In case of non-conclusion of an insurance policy, European Reliance may retain the personal data declared in the pre-contractual stage for a time period up to five (5) years after its submission, depending on the existing destruction policy in force. All of the above are valid provided that no legal dispute is pending for a time period longer than the aforementioned and up to its finalization of the policy with an irrevocable judicial decision.
 
 

6. Rights of Natural Persons

According to the General Regulation (EU) 2016/679, the natural persons retain the following rights: 
 
The right of access, namely the right to receive a confirmation from European Reliance as to whether your data is processed and, if so, for which purpose, time duration, and recipients.
The right to rectify any deficiencies or inaccuracies in your data.
The right to erase your data ("right to be forgotten") from the Registry of European Reliance, provided that the 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, when this is technically possible, so that you may forward it to another data controller.
You may, at any moment, oppose the processing of your 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 of occurrence of risk, as no insurance policy may apply without the processing of the above data of the insured. If the withdrawal of the consent takes place in a pre-contractual stage, then European Reliance has the right to deny the conclusion of the policy.
 
The above rights are exercised free of charge, by sending a relevant letter or e-mail to the Data Protection Officer (see paragraph 10 of the present document).  In case of request of additional actions and copies, European Reliance may impose the payment of a reasonable fee for administrative expenses. 
If 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 since its receipt, informing you on its fulfillment, or for objective and legal purposes which prevent its fulfillment. Upon your notification by European Reliance, this deadline may extend for a time period of two months, if necessary, taking into account the complexity and the number of requests.
 

7. Processing the Personal Data of Children

For minors under 15 years old (or the age provided by the Law) that are included in the insurance policy with the capacity of the insured or the beneficiary, the processing of the personal data is lawful, only if and to the extent that the consent is provided or approved by the person with the parental responsibility of the minor.
When the minor reaches the age of 15 years old, (or the age provided by the Law), the minor must give in person the consent for the processing of the personal data by European Reliance.
 

8. Transmission of Data to Third Parties

Your data may be transmitted to any business 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 retains policies for your compensation, according to the terms of the insurance policy, as well as for the estimate of the claim.
 
Transmission of data depending on your insurance scheme
 
Within the context of your insurance policy and for the purpose of fulfilling its legal obligations, European Reliance may, in cases needed, depending on the insurance scheme, transmit data to legal and/or natural persons, as indicatively:
 
your Insurance Intermediary
Insurance Companies (for the needs of the Amicable Settlement-SAP)
Reinsurance Companies within and outside the European Union 
Nursing Facilities, Diagnostic- Coordination Centers, Doctors, etc.
Claims Investigators, Loss Adjusters, International Loss Adjusters, Attorneys, etc.
Road assistance companies, courier companies, archive and file management companies, telephone service providers, etc.
The Division of Information Technology of the Hellenic Association of Insurance Companies, the Information Center and the International Insurance Bureau and International Mediation Bureaus.
Car Stations
Co-operating Banking Institutions etc. (for cases of issuance of credit cards for an insurance product, paying claims, etc.).
Public and Judicial Authorities, Public Organizations and Supervisory Authorities, based on special legislative provisions with which European Reliance must comply.
Subsidiaries of European Reliance.
 
However, the legal and / or natural persons shall process your personal data exclusively for the purpose of the provision of 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 security of information.
 
In every transmission, European Reliance shall take all necessary measures, so that the data transmitted will always be the minimum required and shall ensure that all requirements for legal and appropriate processing are met.
 

9. Processing of Personal Data for commercial or research purposes

European Reliance may process the personal data submitted by you, (i.e. your phone number, e-mail, etc.), only upon your discrete consent, for the following purposes:
 
To receive, according to the method of your preference, updates on new offers for products or services throughout your policy period and for 36 months after the expiration of the policy.
To receive updates for the promotion of products or services of European Reliance or its subsidiaries.
To perform surveys on customer satisfaction regarding products and services of European Reliance and regarding your insurance intermediary.
For the achievement of this purpose, your data may be transferred to cooperating market research and promotion companies. 
 
For this purpose, you may modify and/or revoke your consent on the collection and use of your Personal Data at any time, in writing or via the Customer Service Department (tel.: +30 210-8119670, email: helpcustomer@europisti.gr).
 
 

10. 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 is adequately protected and processed in accordance with the requirements of the applicable legislation.
European Reliance applies an Information Security Management System according to the international standard ISO/IEC 27001:2013 and since 01/11/2017 it holds a certificate by the Certification Body TUV HELLAS (TUV NORD) S.A.
 
According to this System, European Reliance, apart from measures for technical security, has adopted 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 with which European Reliance administers and protects its Information Assets.  These rules determine the role of any person of European Reliance involved, the competencies, responsibilities and duties.
The Primary Purposes of the Information Security Policy include, among others:
The protection of the information of European Reliance.
The assurance of the trust of the customers of European Reliance.
The assurance of compliance with the Greek Legislative and Institutional Framework (Greek legislation).
The appointment of the security level and requirements of the Organization.
The establishment of mechanisms that support the identification and prevention of threats to the information of European Reliance and the effective response of the Organization, if such threats occur.
The determination of the roles and responsibilities of the members of the Organization for the protection of information and information assets.
Raising awareness on the risks of the information and IT systems of the Organization.
The complete text of the Information Security Policy can be found here.
 

11. How to Submit a Complaint / Protest

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