REGULATION REGARDING THE PROTECTION OF NATURAL PERSONS WITH REGARD TO THE PROCESSING OF PERSONAL DATA AND ON THE FREE MOVEMENT OF SUCH DATA.
We inform you of the provisions in force since 25 May 2018 concerning the European Regulation of 27 April 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (‘GDPR’).
This regulation lays down the principles and rules that should protect individuals with respect to their personal data, their fundamental freedoms and rights, regardless of their nationality or residence.
Firstance Luxembourg S.A. and each company that is part of the Firstance Group, uses and is responsible for the processing of the personal data of its customers (herein after denominated also the “data subject”) in the framework of contracts or insurance contracts with them. The data collected by Firstance Luxembourg S.A. and the Group’s companies are used in the context of customer acceptance, administrative management of insurance contracts, various regulatory reports provided to the Control Authorities, tax reports, reports within the Firstance Luxembourg S.A. Group, internal payments and controls, in particular compliance, anti-money laundering and the financing of terrorism, as well as in the implementation of existing economic sanctions. This personal data may also be shared with third parties as defined in the following sections. In the event that a customer does not provide Gatsby & White S.A., or any other Group company with which he enters into a business relationship, the necessary personal data, or does not give us permission to use this data, our brokerage companies may not be able to accept or continue the execution of our insurance brokerage mandate.
In addition, this personal data processing policy is the policy applicable within the Group controlled by Firstance Luxembourg S.A. Therefore, by Firstance Luxembourg S.A. below, any company controlled directly or indirectly by Firstance Luxembourg S.A. must be understood. The list of these companies is available in Appendix 1 of the terms and conditions of the brokerage mandate is constantly updated. In the case of co-brokerage, this text applies in conjunction with each company concerned. Therefore:
1. HOW DO WE COLLECT YOUR DATA? |
Through the information you provide to us during our meetings or through other intermediaries (natural or legal); When you contact us by phone, fax, email or other forms of electronic communication. In this context, we may record such communications;
When completing contract forms (commands, proposals, etc.);
Other companies of the Firstance Luxembourg S.A.Group;
From your agents, insurance intermediaries, advisers or promoters;
From public data sources or from third parties, especially when we are forced to verify some of your personal data;
2. The categories of personal data we collect? |
1 This list is regularly updated and does not constitute a substantial change in our personal data processing policy.
3. THE BASIS FOR DATA PROCESSING (OTHER THAN YOUR CONSENT), HOW DO WE USE THIS DATA AND WITH WHOM WE SHARE IT? |
Treatment required to execute one or more contracts with you (Art. 6.1.b GDPR)
We process your data because it is necessary in the execution of the mandate that is granted to us and in order to analyze the contact entry with you.
In this context, we use your personal data to:
Prepare our mandate for insurance intermediation;
Prepare, manage and advise you on your insurance proposal;
Manage complaints or suggestions to our company or insurance company;
For any task you entrust us with personal data;
Therefore, we may share your personal data with the following individuals:
We also process your personal data to satisfy our legitimate interests or, sometimes, when necessary, to satisfy the legitimate interest of another person.
In this context, we use your personal data for the following purposes:
As a result, we may share your personal data with the following individuals:
Processing is necessary to comply with a legal obligation (Art. 6.1.c GDPR)
We process your personal data to comply with our legal obligations:
In this context, we share your personal data with the following individuals or entities:
4. MARKETING |
With your authorization, we may use your data to promote our activities and products. This can take the form of newsletters, event invitations or any other initiative at this address.
We will communicate with you in a number of ways such as mail, phone, email, SMS or other digital media. If you have authorized us to use your personal data for marketing purposes (see the contractual documents of the mandate you signed with us) and would like to withdraw this authorization, we would appreciate it if you would let us know by email or mail to:
Firstance Luxembourg S.A.
FAO: Dpt. Legal & Compliance
6 Av. Jean-Pierre Pescatore
L-2324 Luxembourg
By email: privacy.lux@firstance.com
5. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES OF THE EUROPEAN UNION |
The exchange or transfer of personal data in accordance with this information note may only take place outside the European Union in favour of the recipients mentioned above. In this context, your personal data will only be transferred in the following cases:
For more information about transfers by us of your personal data outside the European Union, please contact us with the above information.
6. THE RIGHTS OF THE DATA SUBJECT |
In addition, here we would like to inform you of your new rights to protect personal data as follows:
The data subject has the right to obtain confirmation from Firstance Luxembourg S.A.. that personal data about him, who has access to this information as well as the following explanations are being processed:
6.2 Right to the rectification of data
The data subject has the right to obtain from Firstance Luxembourg S.A. the rectification, as soon as possible, of the erroneous data concerning him, as well as the right to complete the missing data.
6.3 Right of erasure of data
The data subject has the right to obtain from Firstance Luxembourg S.A. the erasure of the data concerning him as soon as possible.
6.4 Right to restriction of processing
The data subject has the right to obtain from Firstance Luxembourg S.A. the limitation of the processing of personal data:
6.5 Right to notification
Firstance Luxembourg S.A. must inform each recipient to which personal data has been disclosed of any deletion, rectification or restriction of personal data, unless such disclosure is impossible or requires disproportionate means.
6.6 Right to data portability
The data subject has the right to receive the personal data provided to Firstance Luxembourg S.A., in a structured format, and has the right to transmit that data to another processing manager where technically possible.
6.6 Right to object and automated individual decision-making
The data subject has the right to object at any time to some automatic processing of personal data concerning him. The data subject has the right not to be the subject of a decision based solely on automated processing that produces legal effects that significantly affect him. You can contact the Firstance Luxembourg S.A. data controller at: privacy.lux@firstance.com
As far as our company Firstance Luxembourg S.A. in Luxembourg is concerned, you can direct your complaints to the Luxembourg supervisory authority at the following address:
Commission nationale pour la protection des données
15, Boulevard du Jazz – LU-4370 Belvaux
Telephone: (+352) 26 10 60 26 I Fax : (+352) 26 10 60 2
www.cnpd.lu
On the other hand, if a Group Company is interested and has his headquarters in Liechtenstein, you may direct your complaints to the following supervisory authority:
Datenschutzstelle Fürstentum Liechtenstein
Städtle 38 Postfach 684 – LI-9490 Vaduz
Telephone: (+423) 236 60 90 I info.dss@llv.li
www.datenschutzstelle.li
Finally, if a Group Company is interested and has his headquarters in Belgium, you may direct your complaints to the following supervisory authority:
L’Autorité de protection des données
Rue de la presse 35 – BE-1000 Bruxelles
Telephone: +32.2.2744800 I Fax: +32.2.2744835
contact@apd-gba.be
www.autoriteprotectiondonnees.be
Firstance Luxembourg S.A. retains the personal data of its data subjects for 10 years after the end of the contract. Recorded phone conversations are held for a year. Firstance Luxembourg S.A. does not use the automatic processing of personal data for automated decision-making purposes neither for marketing purposes.
Firstance Luxembourg S.A. may update its Privacy Regulations for the processing of personal data and the free movement of personal data from time to time. When we significantly change the policy, a notice will be posted on our website with the privacy update. When you receive a question or request for personal information, we have a dedicated team looking to answer the problem or question you are looking for. If your question is more substantial in nature, you may be asked for more information. All these background contacts receive a response. If you are not satisfied with the response received, you can refer your complaint to the national data authority.
If there are major changes that are incompatible with the purpose for which the data was collected, we will seek your renewed consent.
The Privacy Policy of Firstance Luxembourg S.A. was updated on July 3, 2020.