Declaration on the Protection of Personal Data

Introduction

Integrale Luxembourg SA (hereinafter "Integrale Luxembourg"), undertakes to protect and process your personal data with care, transparency and compliance with the relevant legislation.

The purpose of this Declaration on the Protection of Personal Data ("Declaration") is to fully inform you on the subject. It explains how we collect, use and store your personal data. This Declaration does not modify the contractual conditions between you and Integrale Luxembourg.

You will also find information by consulting the website of the National Commission for the Protection of Data ("CNDP"): https://cnpd.public.lu/fr.html

Until 24/05/2018, the legislation in force regarding privacy is the law of 02/09/2002 relating to the protection of privacy with regard to the processing of personal data. From 25/05/2018, the new Regulation (EU) 2016/679 of the European Parliament and of the Council of 27/04/2016 relating to the protection of natural persons with regard to the processing of personal data and the free flow of this data ("GDPR") will apply. This Declaration was devised based on the new legislation.

 

What is the scope of this Declaration?

Definitions according to the European Regulation 2016/679 (GDPR)

Personal data: any information relating to an identified or identifiable natural person (hereinafter referred to as "Person concerned"); is deemed to be an "identifiable natural person" a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements particular to their physical, physiological, genetic, psychic, economic, cultural or social identity.

Processing: any operation or set of operations whether or not performed using automated processes and applied to personal data or data sets, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Responsible for the processing: Integrale Luxembourg SA, with its registered office at 1610 Luxembourg, 4-6 Avenue de la Gare, is responsible for the processing of your personal data at its disposal. This means that we determine the purposes and means of the processing of this data and that we are your contact person and that of the supervisory authorities for any question relating to the use of this data.

Data Protection Officer
We have appointed a Data Protection Officer within our company. He will be your point of contact for data protection:

 

France Noiret

Data Protection Officer

Integrale Luxembourg SA

4-6 Avenue de la gare

1610 Luxembourg

dpo@integrale.lu

 

Who is concerned?

Our Declaration concerns all natural persons, whether they are policyholders, prospects, insured persons, beneficiaries, directors, executives, agents or beneficial owners whose personal data is processed. In contrast, the processing of personal data concerning legal persons is not affected by this Declaration.

 

What data is covered by this Declaration?

The data covered by this Declaration is the personal data that allows us to identify you (last name, first name(s), etc.). During our exchanges, we may have to collect various personal data about you depending on the type of product purchased.

 

2.3.1 Data collected in the context of an insurance

 

If your email address and your telephone number have been provided to us, they may be used by Integrale Luxembourg in a balanced manner between its legitimate interest and respect for your rights and freedoms, in order to communicate with you as part of the management of your insurance contract, to keep you informed about the legislation or the technical aspects relating to your contract.

We may also use data obtained from external sources, for example when employers take out insurance for their staff.

In some cases, personal data concerns one or more of your relationships (e.g. your children, your partner, the life insurance beneficiary, your employees, etc.). If you convey the personal data of other persons, you may also be bound by the legal provisions on the protection of privacy.

 

2.3.2 Data collected when you are a beneficiary in the event of the death of the policyholder

We may also use data obtained from external sources.

 

When and how is your personal data collected?

Some of your data may for example be collected by Integrale Luxembourg:

 

When we collect your data, you have the right not to respond to our request. This refusal could however prevent the formation of contractual relations, modify the nature of these relations or influence their management.

 

For what purposes does Integrale Luxembourg process your data?

Introduction

Integrale Luxembourg undertakes to collect your data for specific, explicit and legitimate purposes. Your data will not be processed at a later date in a manner incompatible with these purposes. If these purposes are modified in the future, you will be informed in advance.

 

We use your personal data:

 

Compliance with legal obligations

Integrale Luxembourg may and, in certain cases, must obtain and process certain data, in particular in order to comply with all the legal and regulatory obligations to which it is subject. These obligations may imply that Integrale Luxembourg collaborates with the competent authorities and/or with third parties and, where appropriate, provides them with some of your data. These obligations mainly fall within the following legal and regulatory areas:

 

The list of legal and regulatory areas under which Integrale Luxembourg is required to process your data is non-exhaustive and is subject to change.

 

(Pre)contractual relations

Before the conclusion of contracts and during the execution of the contract, Integrale Luxembourg may and, in some cases, must obtain and process certain data, in particular in order to:

When Integrale Luxembourg is not able to process the data necessary for the aforementioned purposes, it will not be able to provide the precontractual information, nor execute the contract. The contract cannot be concluded or will be suspended or even stopped.  

 

Legitimate interest

In addition to the objectives listed above, Integrale Luxembourg has a number of legitimate interests which justify its processing of personal data. Integrale Luxembourg ensures, in any event, that the impact of this processing on the respect of your private life is as limited as possible and in all cases, that the balance between the legitimate interests of Integrale Luxembourg and the possible impact on the respect of your private life is not impaired. If, however, you object to this processing, you may, in some cases, exercise your right to object (see point 7.6).

For example, we process your data for the following purposes:

 

Consent

Integrale Luxembourg may use your email address to send you commercial information and advertising about our new products by means of commercial communications. In this case, Integrale Luxembourg first requests your consent explicitly. Integrale Luxembourg's approach will be limited to the products offered by it.

Under no circumstances will Integrale Luxembourg use your personal data belonging to particular categories within the meaning of the GDPR (data relating to your health, revealing your racial or ethnic origin, your sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, data relating to criminal convictions and offences).  

You can unsubscribe from any services you have registered for.

 

How do we protect your data?

Integrale Luxembourg uses appropriate security measures to help protect your information and safeguard it from unauthorised access. Information storage is performed on secure servers. It regularly evaluates its security policies and procedures to ensure that our systems are secure and protected, and that only authorised individuals who need to use it in the context of processing access it.

Integrale Luxembourg protects personal data under its control in accordance with the strict standards defined by its policies and procedures. Technical and organisational protection measures such as anti-virus, firewalls, access controls, rigorous selection of personnel and suppliers are put in place to prevent and detect losses or inappropriate disclosures of your personal data.

 

Who has access to your data and to whom is it transmitted?

Basic principle

Integrale Luxembourg staff members who are authorised to access your data are determined precisely according to their tasks.  

This data may if necessary be communicated to other insurance companies as part of the co-insurance, to reinsurance companies, a lawyer, a notary, specialised partners or a subcontractor.

Regarding the subcontractors of Integrale Luxembourg, we call in partners for certain tasks in order to offer you the best service within the framework of your insurance contract.

These subcontractors are contractually bound to Integrale Luxembourg and must follow our instructions and respect the principles set out in our Declaration. In particular, we ensure that our subcontractors:

We also transmit your data to third parties if we are obliged to do so by virtue of a contractual or legal obligation or if a legitimate interest which you have not opposed justifies it. In these cases, we ensure that:

 

Transfer for commercial use

We do not transmit your data to third parties for commercial use.

 

What are your rights?

Right of access

You have a right of access to the data concerning you. You can ask us:

 

Right of rectification

If you find that, despite our best efforts, your data is inaccurate or incomplete, you may ask us to correct or supplement it.

Integrale Luxembourg shall notify each recipient to whom the personal data has been communicated of any rectification of personal data, unless such communication proves impossible or requires disproportionate effort.

 

Right to erasure ("right to be forgotten")

In certain specific cases, the legislation allows you to have your personal data deleted. This is particularly the case if:

Your right to be forgotten is not absolute, however. We are entitled to continue to keep your data when this retention is necessary, among others:

Integrale Luxembourg shall notify each recipient to whom the personal data has been communicated of any erasure of personal data, unless such communication proves impossible or requires disproportionate effort.

 

Right to restriction of processing

In certain specific cases, you may request the restriction of the processing of your personal data.  This is particularly the case when:

Restriction of processing will be discontinued in the following circumstances:

Integrale Luxembourg shall notify each recipient to whom the personal data has been communicated of any erasure of personal data, unless such communication proves impossible or requires disproportionate effort.

 

Right to portability

In some cases, you have the right to obtain the personal data that you have provided to us:

 

This is the case when:

 

Right to object

Even if the processing of your personal data is based on a legitimate or general interest on our own initiative, you have the right to oppose it at any time.

However, your request will be disregarded if our legitimate interest is superior to yours or if the processing of your data remains necessary for the recognition, exercise or defence of legal rights.

 

How to exercise your rights and who to contact?

To exercise your rights, simply send your signed and dated request accompanied by a photocopy of both sides of your identity card by mail or email to our data protection officer whose contact details are as follows:

France Noiret

Data Protection Officer

Integrale Luxembourg SA

4-6 Avenue de la gare

1610 Luxembourg

dpo@integrale.lu

 

If you believe that the processing of your personal data constitutes a violation of the privacy legislation, you also have the right to lodge a complaint with the CNDP whose contact details are as follows:

 

National Commission for Data Protection

Avenue du Rock’n’Roll, 1

4361 Esch-sur-Alzette

Tel: (+352) 26 10 60 1

 

How long do we keep your data?

Your personal data will be kept for as long as necessary for the purposes indicated during their collection. When there is a contractual relationship with Integrale Luxembourg, your data will be kept for the duration of this contractual relationship, the period of legal prescription and any other retention period that would be required by the regulations.

You can receive a copy of the Declaration by contacting your usual contact point or sending the request by e-mail : dpo@integrale.lu.

 

Our cookies policy

If you visit our website, you can choose whether or not you accept cookies and, if applicable, other technological means that collect data and information about your browsing habits. For more information, please consult our page "Use of cookies" on our website www.integrale.lu (via the link "Use of cookies" at the bottom of the page).

 

How to stay informed about changes made to this Declaration?

In an ever-changing world, our Declaration could be subject to change. We invite you to consult the latest online version of this Declaration and we will inform you of any changes to the Declaration via the Integrale Luxembourg website www.integrale.lu, and, where appropriate, through the other usual channels of communication.

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