Eurocaution Data protection

The confidentiality of your information is of the greatest importance to us.

The present Personal Data Protection Policy explains which data we collect concerning you and the way in which we use such data, as well as your rights in this regard and how you may exercise them. We undertake to implement all appropriate means to preserve the confidentiality and integrity of your personal data.

1. Who are we?

EuroCaution Benelux SA is a brokerage company registered with the RCS [Trade and Companies Register] of Luxembourg under the number B169101. It is accredited as a broker with the Commissariat aux Assurances de Luxembourg [Luxembourg Insurance Commission] under the number 2012CM012 and is entered in the “Register of accredited brokerage companies in the Grand-Duchy of Luxembourg” available on the site of the Commissariat aux Assurances at the following address http://www.caa.lu/fr/operateurs/intermediaires/societe-de-courtage . EuroCaution is authorised to operate in Luxembourg and Belgium according to the Freedom to Provide Services provisions.

EuroCaution Benelux SA collects your personal data for its own account, in the capacity of data controller.

You can contact us using the following details:

Post: 7, rue des Mérovingiens L-8070 Bertrange

Tel.: +352 202123241

E-mail: Cliquez ici

Personal data is any information concerning an identified or identifiable natural person (for example a person’s name, photograph, telephone number, contract number, password etc.).

The data controller, in accordance with European regulations on the protection of privacy, is the person who determines the purposes and means of the processing of personal data.

You may submit any request for further information or any requests regarding your personal data by using the contact details given above.

2. What personal data do we collect?

Only personal data strictly necessary for the purposes described below will be processed. In the context of our activities and in accordance with your particular situation and with respect to your life insurance and/or capitalisation contracts, we may process the following data:

• Identifying data (surname, first name, sex, date of birth, nationality etc.);
• Contact details (e-mail address, mobile and/or land-line number, postal address etc.);
• Civil status;
• Financial and asset data (list of movable and immovable assets etc.)
• Professional data (functions exercised)
• Composition of household (for example: civil status, number of children etc.);
• And any other information that you might choose to provide.

We may also have to process certain sensitive data, subject to particular protection, such as:

• Your tax identification number

We process these data with very particular care.

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

• Data obtained by a financial partner (bank, financial manager, family office) which contacts EuroCaution Benelux SA with a view to collaboration on your file, in total transparency with you;
• Updating of your data (for example concerning the composition of your family, your address, your identity card which has expired etc.)

In certain cases, we have to use personal data concerning persons other than you, for example:

• your forbears, children, partner, the beneficiary/beneficiaries of your life assurance;
• your employees, legal/statutory representatives, your shareholders/associates;

If you provide us with such data, you undertake to inform the persons concerned.

3. How do we use your personal data?

3.1 For what purposes and on what legal basis do we use the personal data?

We will first of all use your personal information to execute our contractual obligations towards you, particularly in order to:

– provide you with the services expected in the context of our role as insurance intermediary, such as to:

• determine your requirements and needs (and in the context of an investment product based on the insurance, your complete investor profile) ;
• provide you with advice;
• supply you with the documentation regarding the products for which you asked for our assistance;
• assist you in the conclusion of an insurance contract (preparatory work and actual signing) ;
• assist you in the management and execution of the insurance contracts (purchase, top-up payment, arbitrage, liquidation)

– save your preferences, if and how we can contact you to provide you with information, or proposals;

We may also have to use your personal data in order to comply with our legal obligations, particularly with regard to:

• prevention of money laundering and the financing of terrorism;
• insurance distribution;
• our tax accounting obligations;

On the basis of our legitimate interests, we may process your information in order to:

• manage our clientèle and obtain a global vision of our clients (for example by establishing statistics of our clients in order to understand who they are and to know them better);
• prevent abuse, fraud and infractions ;
• protect the assets of the firm;
• ensure the security of goods and persons, as well as the IT networks and systems of the firm;
• monitor the regular nature of operations;
• ascertain, exercise, defend and preserve the rights of the firm and the persons it represents, for example in the event of disputes;
• establish proofs;

3.2 Do we use your personal data to make automated decisions?

In the context of the purposes referred to above (Point 3.1), we may also use and analyse your personal data in order to make automated decisions, i.e that do not involve human intervention, in the following case(s):

• description of the automated decision taking or profiling + description of the underlying logic and expected consequences of this processing]

4. Why is it necessary to provide us with your personal data?

If you decline to provide us with the data requested in the context of certain services (such as for example assistance in the conclusion of an insurance contract or in the event of the notification of a claim), we might find it impossible to fulfil our role as intermediary or satisfy your requests.

5. Where to and how do we transfer your personal data?

5.1 Who has access to your personal data and to whom are they transferred?

In order to protect your privacy, the persons who are authorised to have access to your data are determined in specific accordance with their tasks.

In no case will we sell your personal data to third parties. For the purposes detailed above (cf. Point 3.1), we will nonetheless have to communicate certain information to third parties:

• to insurance companies from which you wish to receive a proposal or with which you wish to conclude a contract;
• for the proper execution of our missions as an intermediary, your data may be transmitted to and/or processed by our IT subcontractors;
• in order to comply with our legal obligations, your data may be transmitted to the authorities and to our regulator;
• in the event of disputes, your data may be transmitted to our lawyers and used to defend our case in court;

Where do we transfer your personal data to? In no case will be transfer your personal data outside the European Economic Area (“EEA”).]

6. For how long will your personal data be stored?

We will store your data for as long as:

• it is necessary for fulfilling the purposes detailed above, or;
• there is a legal obligation to continue such storage (for example, storage of accounting documents)
• the applicable limitation periods have not expired, to ensure that we have the necessary information available to us to protect us in any court case.

7. What are your rights and how may you exercise them?

As the person concerned, you have various rights. You will find below a brief description of these rights and how you may exercise them.

Right to information

You may ask us any question concerning the recording and processing of your data.

Right of access

You may at any time have confirmation as to whether or not personal data concerning you are processed and, where necessary, have access to the said data and have a free copy thereof.

Right of correction

You can at any time, by sending us a written request, have incorrect personal data concerning you corrected. Similarly, you may ask for incomplete data to be completed.

Right of deletion

You can at any time, by sending us a written request, have your personal data deleted, on condition that one of the following reasons is applicable:

• the data are no longer necessary for the purposes for which they were collected and processed;
• you have withdrawn the consent on which the processing was based;
• you object to processing and there is no compelling legitimate reason for the said processing;
• the data have been processed unlawfully;
• the data must be deleted to comply with a legal obligation.

Right to the limitation of processing

When the limitation of processing is accorded, the personal data may no longer be processed except with the consent of the person concerned, or in order to ascertain, exercise or defend rights in court, or to protect the rights of another natural person or legal entity, or for important public-interest reasons.

You may request the limitation of processing for one of the following reasons:

• you dispute the correctness of the personal data;
• in the case of unlawful processing;
• we no longer need your personal data for processing purposes but you still need them for the ascertainment, exercise or defence of rights before the courts;
• you have objected to processing (the processing will be limited during the period necessary to verify if legitimate reasons of ours exist which might have priority over yours).

Right to object

You have, for reasons concerning your particular situation, the right at any time to object, by sending us a written request, to the processing of your personal data based on the execution of a mission of public interest or necessary for the legitimate interests that we follow.

We will no longer process these personal data unless it is shown that there are legitimate and compelling reasons for the processing which prevail over your interests and your rights and liberties, or for the ascertainment, exercise or defence of rights before the courts.

Where your personal data are processed for marketing purposes, you have the right to object to such processing at all times.

Right to portability

You have the right, by sending us a written request, to receive the personal data you have supplied to us in a structured, commonly used and machine-readable format, and to transmit these data to another data controller without any obstacle on our part, when:

• the processing is based on your consent or on a contract; and
• the processing is carried out with the help of automated processes.

Right to withdraw consent

When the processing is based on your consent, you have the right to withdraw this at any time by sending us a written request. The withdrawal of your consent will not affect the legitimacy of the processing based on your consent and carried out before the withdrawal thereof.

Right to make a claim

We endeavour as best we can to comply with our legal obligations with regard to data protection and to follow up any claim submitted to us in this respect as quickly as possible. If you should not be satisfied with the response received, you can submit a claim to the Data Protection Authority.