PRIVACY POLICY AND PERSONAL DATA PROTECTION
TagInsurance – Mediação de Seguros, Lda.

 

INTRODUCTION
This Privacy Policy and Protection of Personal Data, hereinafter “Privacy Policy”, applies generally to the collection and processing of personal data provided by customers, potential customers, and users – henceforth, only “Data Holder”- of the services provided, either offline or online, by TagInsurance – Mediação de Seguros, Lda., insurance intermediary registered in the insurance agent category, registered with the Insurance and Pension Funds Supervision Authority (ASF) under the number 420562464, legal person number (NIPC) 515908860, with registered office at Avenida Casal Ribeiro, no. 18, 2.º Esq., 1000-092 Lisbon, hereinafter referred to as “TagInsurance”, namely those collected through forms, websites, simulators, proposals, documents or other means (hereinafter, only “Documents”), in paper or electronic form, intended to allow contact with TagInsurance , also applying exercise of rights by the Data Subject in relation to them, under the terms of the applicable legislation, namely, but not limited to Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and the free movement of such data (“GDPR”).

This Privacy Policy has a general and abstract character, so the information that is provided in it can be supplemented or removed, totally or partially, by other policies, notices or more specific information that may have been or may be provided by TagInsurance in the context of certain types of processing of personal data.

RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA
TagInsurance , whose activity is regulated by Law No. 7/2019, of January 16 and other regulations published by the ASF, as well as in terms of the agreements, protocols or agreements established with their partner insurance companies – and those that have received authorization from the competent authority of one of the Member States of the European Union to exercise the insurance activity – hereinafter only “Insurers“, may have the most varied forms and modes of relationship, business models and performance in relation to the Insurance Companies, reflected in the purposes and means of processing the personal data of the Data Subject, being able, for this reason, to act, in what concerns the data protection legislation, as “responsible for the processing”, “subcontractor” or as“ jointly responsible for the processing ”of personal data.

Personal data consists of any information relating to an identified or identifiable natural person (the Data Subject). An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, electronic identifiers or to one or more specific elements of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (hereinafter, only “Personal Data“).

Personal Data may have been provided by the respective holder of the data , to fill the documents , regardless of their support, directly or through others, or may have been generated by TagInsurance , whether under prior contacts, either in celebration, running, renewal or termination, through him, of the insurance contract or operation or that have resulted from them and respect the Data Subject, whether in his capacity as policyholder, insured, beneficiary or his representative, and also to victims or to third parties and their representatives. The provision, to TagInsurance, of the Personal Data collected in the scope of pre-contractual diligences or in the contracting process, in addition to the cases in which it corresponds to the necessary information to fulfil TagInsurance’s legal and contractual obligations, constitutes a necessary requirement for pre-diligence contracts and, well, for the conclusion of the insurance contract and its execution, through it. In the event that they are not provided to TagInsurance, the contract cannot be accepted by the Insurers, with the intervention of TagInsurance. The personal data will be processed by TagInsurance, depending on the case, either as a “controller,” “processor” or as a “head assembly for processing” to those listed below purposes, in strict compliance with the provisions in the legislation in force concerning the protection of personal data.

PROCESSING OF PERSONAL DATA
Personal Data provided in the relationship established with TagInsurance is treated in accordance with the legally applicable precepts, namely:

  1. a) Treated lawfully, fairly and transparently;
  2. b) Collected for specific, explicit and legitimate purposes and will not be further processed in a manner incompatible with those purposes;
  3. c) Adequate, relevant and limited to what is necessary in relation to the purposes for which they are treated;
  4. d) Accurate and, if necessary, updated, and appropriate measures must be taken to ensure that inaccurate or incomplete data is erased or rectified, taking into account the purposes for which they were collected or for which they are further processed;
  5. e) Kept in such a way as to permit the identification of their holders only for the period strictly necessary and within the legally permitted scope for the purposes of collection or further processing.

 

TYPES OF PERSONAL DATA

TagInsurance only collects and processes personal data necessary for the provision of a quality service in order to be able to offer products and services that best fit the needs of its customers and to meet its obligations as “Subcontractor”, when acting in that capacity.

TagInsurance also process the personal data that are necessary for compliance with legal obligations to which it is subject or for the satisfaction of their own legitimate interests.

In the scope of the provision of services, TagInsurance processes the following categories of Personal Data:

  1. a) data identifying, for the borrower, secure people ‘s, victims and beneficiaries, as applicable (such as name, age, marital status, place of birth and nationality, address, citizen card, telephone number, address and email, taxpayer number, profession);
  2. b) Data on the registration of claims in the life branch (such as death certificates, heirs’ qualifications, medical report, funeral agency receipt, accident report, autopsy report and results of blood alcohol tests and toxicology, payment order to be filled by the beneficiary, proof of IBAN);
  3. c) Data on the registration of claims in the health sector (such as the health history of the insured, medical reports, documents to support the resolution of claims);
  4. d) Data on the registration of claims in the field of occupational accidents (such as, date of activation of the insurance and description of the claim, maturity, premiums, extras, bonuses, food allowance, support data for the resolution of claims);
  5. e) Personal accident claim data (such as description of the claim, medical information, documentation to support the claim, legal beneficiaries);
  6. f) Data on the registration of claims in the automotive industry (such as data on claims, identification of injured third parties, identification of witnesses);
  7. g) Data on the registration of claims in other branches (data on claims);
  8. h) Data of identification of the insured object (type of vehicle, registration, make, model, year of manufacture, number of chassis, date of registration, cylinder capacity, number of seats, number of policies, identification of other insured objects, such as jewellery, art pieces, housing, home furnishings or animals);
  9. i) Collecting data (IBAN, bank, swift, signature, name of the account holder, address, policy number);
  10. j) Health and lifestyle data (such as information on lifestyle habits, such as food, sport, alcohol consumption, smoking, biometric indices, disease history);
  11. k) Call recording data (call recording, including voice recording and number recording);
  12. l) Other categories of personal data necessary for the purposes required at all times.

 

PURPOSES, GROUNDS FOR TREATMENT AND DEADLINES FOR THE CONSERVATION OF PERSONAL DATA

Personal Data is treated for the following purposes based in each case on the indicated basis and are kept for the time strictly necessary to the pursuit of those purposes, according to the terms (or criteria used to define them) in the following table:

Goal Legal Basis Conservation Term
Necessary treatment for the execution and management of the insurance and insurance mediation contract or for pre-contractual steps with the intervention of TagInsurance.

Registration and proof of commercial transactions and pre-contractual information.

 

 Presentation, proposition, execution and execution of the insurance contract, pre-contractual steps and support its management, especially in the event of an accident, with the intervention of TagInsurance.

Legitimate interest of the controller or third parties in the identification, risk assessment, information, clarification and advice of solutions and products.

Consent of the Data Holder.

Compliance with legal obligations.

 Until the statutory limitation period for all obligations arising from the insurance contract and the insurance mediation activity related thereto.
Prospecting and commercial action Consent of Data Holder.

Legitimate interests in developing and growing the activity of the controller or third party.

 Until the end of one year on the end of the contractual and legal relationship.
Compliance with legal obligations, namely with the authorities, among others, of supervision, tax and fiscal or judicial. Compliance with legal obligations.

Legitimate interests to control the activity of the controller or by third parties.

For declaration, exercise or defence of rights in judicial proceedings.

 Legal deadline applicable at all times for each legal and legal obligation to be fulfilled, namely 10 years for the fulfilment of tax obligations and 7 years for the fulfilment of obligations in the prevention of money laundering and terrorist financing.

Until the expiry of the statute of limitations or lapse for the exercise of rights.

 

TELEPHONE CALL RECORDING
In the telephone contacts established between the Data Subject and TagInsurance, within the scope of its activity, the latter may proceed, if necessary, to record the calls, with prior information to the Data Subject and with his consent, to manage the relationship pre-contractual and contractual, through TagInsurance, and compliance with legal obligations, namely, as a means of proving information or instructions transmitted, as well as for improving the services offered or contracted, and also for quality control of the same. The call recordings will be kept for the periods indicated in the deliberations of the National Data Protection Commission (CNPD) that define the principles applicable to the treatment of call recording data, namely, Resolution 1039/2017.

HEALTH DATA
In the case of some coverage of risks to be transferred from the sphere of the Data Subject (namely, health insurance, personal accident insurance or others), which fall under the category of special and sensitive data, the presentation, proposition, celebration or execution of the insurance contract, with TagInsurance’s legal and/or contractual intervention , involves or may involve the treatment of data related to the data holder’s health, either within the scope of the pre-contractual relationship, for identification, analysis of the proposed risk and fixing contractual conditions, whether in terms of managing the contractual relationship, using coverage, managing claims and, in renewal and contractual changes. TagInsurance shall process the data in question, either as “controller,” “processor” or “responsible set controller”, for the above purposes with the consent Data Holder or his representative, without prejudice of cases in which the treatment is based on another basis of lawfulness (that is, for the purposes of fulfilling obligations and exercising specific rights of TagInsurance, Insurers, third parties or the Data Subject himself , in terms of labour legislation, social security and social protection insofar as such treatment is permitted by European Union or Member State law or by a collective agreement providing adequate guarantees of the fundamental rights and interests of the Data Subject). In these cases, acceptance by insurers, with the intervention of TagInsurance, the insurance contract in question depends on the ability to process data relating to health data, without which proves unfeasible do the analysis of the proposed risk, celebrate the insurance contract, transfer the risk, place and accept the desired coverage or even keep the contract in force with the Insurers.

 DATA COMMUNICATION
Personal Information may be reported and treated by other entities for which TagInsurance acts, if applicable, as “processor” or “responsible together for treatment,” as to whom TagInsurance has subcontracted its processing and, also, by its insurance co-mediators or People Directly Involved in the Insurance Distribution Activity (PDEADS). Personal Data may also be treated by other insurers or co-mediators as part of the settlement of claims. For the purposes of the described purposes and in compliance with a legal obligation, Personal Data may be transmitted to judicial, administrative, supervisory or regulatory authorities, as well as to entities that legally frame or carry out data collection actions, prevention actions and combating fraud and money laundering, market studies or statistical or technical-actuarial studies.

DATA COLLECTION FROM OTHER SOURCES
TagInsurance may take samples of concerning information to the Data Holder deemed relevant for the assessment of the risk to be insured and fixation, the Insurers with intervention TagInsurance , the contractual conditions of insurance, with sources available to the public, public bodies, industry associations, existing computer platforms or specialized companies, to complement or confirm the information provided by the Data Subject , within the scope of the management of the pre-contractual and contractual insurance relationship, through TagInsurance , including the exercise of the activity insurance mediation under the terms of the specifically applicable legislation, in the framework of the fulfilment of the duties of information, clarification, transmission, advice, assistance and registration that are imposed by said legislation.

RIGHTS OF THE DATA HOLDER
The holder of Personal Data is entitled to request from TagInsurance, and through it, to the Insurers, upon written request addressed to the following address (info@tagusinsurance.com):

  1. a) Access, under the terms and conditions legally provided for, to Personal Data that concern you and that are subject to treatment;
  2. b) The correction or updating of inaccurate or out-of-date Personal Data that respect it;
  3. c) The processing of missing Personal Data when it proves to be incomplete;
  4. d) The erasure, in the cases specifically provided for by law, of Personal Data concerning it;
  5. e) The limitation, verified the conditions foreseen in the law, of the processing of Personal Data with respect to it.

 

Upon written request, addressed to the following address (info@tagusinsurance.com), the Data Subject is also entitled to:

  1. a) Withdraw the consent given, when the data processing is based only on consent;
  2. b) Oppose the processing for reasons related to their particular situation, when the data processing is based on the legitimate interest of the “controller” or third parties;
  3. c) Receive from the “controller”, “subcontractor” or “joint controller”, in digital format in common use and automatic reading, the personal data that concern him and that have been provided by him, processed by automated means based on:
  4. i) to consent given by the Data Holder; or
  5. ii) in a contract entered into, being able to request, in writing, the respective transmission directly to another responsible person, whenever this is technically possible.

 

The Holder of Personal Data may also request, upon written request, addressed to the following address (info@tagusinsurance.com), more detailed information, namely on the purposes, legality grounds and conservation deadlines, as well as presenting you complaints about the way your Personal Data are treated, without prejudice to being able to do so, also with the National Data Protection Commission (CNPD – National Data Protection Commission, telephone: (+351) 213 928 400 ; e-mail: geral@cnpd.pt ; website: www.cnpd.pt).

SECURITY OF PERSONAL DATA
TagInsurance adopted appropriate techniques and organizational measures to protect personal data against loss, destruction or damage, accidental or unlawful and, also to ensure that the data provided are protected against unauthorized access or use by unauthorized third parties. TagInsurance guarantees the privacy and security of data transmission of its customers and visitors to your website and other computer platforms, if the same disposal.

In situations where TagInsurance subcontracts to other entities the provision of services involving the transfer of personal data, these entities will be obliged to adopt the necessary technical and organizational measures in order to protect personal data against destruction, loss, alteration, disclosure, unauthorized access or any other type of unlawful treatment.

AUTOMATED DECISIONS
Within the scope of subscription and renewal processes for insurance contracts or operations, Insurers may resort to decision-making solutions by automated means that are necessary for the execution of the respective insurance contract or operation, with the intervention of TagInsurance with recourse to the information, regarding the policyholder or insured, obtained in the framework of the management of the contractual or pre-contractual relationship from which decision-making regarding the contractual conditions applicable in the subscription or renewal may result. The holder of Personal Data may also request, upon written request, addressed to the following address (info@tagusinsurance.com), more detailed information on the logic underlying the processes in question, in the context of contract subscription and renewal, through TagInsurance, namely, on the information account, for exclusively automated decision-making and the way in which it integrates the decision-making process of the Insurers. In all cases in which the Insurers make decisions based exclusively on automated data processing, the respective processes will include, at least, mechanisms that give the Data Subject the possibility of:

  1. a) Express their point of view;
  2. b) Contest the decision; and
  3. c) Request and obtain from the Insurers, directly or through TagInsurance, human intervention in the decision-making review process.

 

COOKIES
TagInsurance may use cookies on its website, if it has to improve the user experience and allowing perform certain operations safely.

Cookies are small pieces of text that are stored on your computer through the browser, retaining only information related to your preferences. The use of this technology is a common practice of different sites.

Cookies are used to ensure the efficient functioning of the website, to store information, such as the user’s personal preferences when visiting the page and to improve our service. You can turn off cookies, in your browser options, or by making changes to your antivirus program tools. However, this may change the way you interact with this or other pages, which may affect or prevent you from logging into programs or pages on our and / or other networks.

CHANGES TO THE PRIVACY POLICY
The present Privacy Policy may be subject to periodic alteration, through publication on the TagInsurance website or by disclosure by any means of which it is in writing, including electronic or postal mail, without the prior and express consent of the Data Subject. Any changes of a significant nature will be communicated with the degree of publicity corresponding to their relevance, either by highlighting in the online publication, or, if the relevance justifies it, by means of individual communication to the Data Holders.

Updated on December 22, 2020