Personal data processing notice

1. Introduction - Purpose of this notice

This processing notice concerns the insurance products and/or services offered by Europ Assistance (Suisse) Assurances SA and Europ Assistance (Suisse) SA (together "Europ Assistance", "we", "us").

To be able to offer and carry out our various services, we need to process the personal data of customers (and potential customers), beneficiaries and our partners ("you", "your"). Processing personal data means collecting, storing, recording, protecting, modifying, disclosing and finally erasing data in accordance with the law.

This processing notice sets out our approach to protecting your personal data and explains which data we may collect and how we may use them (within our organisation and with partners), within which legal framework.
We suggest you take the time to read this processing notice carefully. It may be updated directly on the website. We thank you for your confidence in us and remain at your disposal for any questions you may have at: eachdpc@europ-assistance.ch.

2. Who processes your personal data?

To be able to offer you insurance products and services, Europ Assistance has two operational companies in Switzerland, which may act as data controller or data processor according to the circumstances.

2.1 Legal information

Europ Assistance (Suisse) Assurances SA is a limited liability company registered in the the Canton of Vaud trade register under company identification number CHE-101.333.746. Its address is Avenue Perdtemps 23, 1260 Nyon. It is an insurance company subject to supervision by FINMA (Swiss Financial Market Supervisory Authority).

Europ Assistance (Suisse) SA is a limited liability company registered in the Canton of Vaud trade register under company identification number CHE-108.684.098. Its address is Avenue Perdtemps 23, 1260 Nyon, Switzerland.

2.2 Data controller’s identity

The identity of the data controller is specified in your contractual documentation. With the online-services.europ-assistance.ch/en website and the insurance products and services distributed on it, the data controller is Europ Assistance (Suisse) Assurances SA.

3. How do we use your personal data?

We may use your personal data for the following purposes:

3.1 Processing for the provision of our insurance products and/or services

Proposing an insurance policy, assessing the risks to be insured and calculating premiums;
Underwriting, managing and performing your insurance policy;
Providing services;
Processing loss reports and assistance cases;
Organising satisfaction surveys with the beneficiaries of insurance products and services;
Managing any claims, pre-litigation and litigation.

3.2 Processing in connection with the use of our websites

Processing your requests (in particular for information, complaints and partnerships) sent to our contact details and on contact forms.

3.3 Processing required to comply with legal and regulatory obligations

Complying with rules concerning insurance supervision;
Complying with rules on combating money laundering and the financing of terrorism, asset freezing measures and financial sanctions, including processing alerts and suspicions;
Whistleblower group procedures;
Complying with tax rules;
More generally, complying with criminal and administrative police rules;
Detecting and preventing abuse and fraud, particularly insurance fraud;
Complying with data protection rules.

3.4 Processing necessary for the smooth performance of our operations

Evaluating, improving and designing our insurance products and services and calculating our rates;
Improving our administrative management (processes, products, services);
Ensuring the security and operation of our IT systems and protecting our staff and assets;
Carrying out actuarial and commercial studies;
Marketing operations and communications.

3.5 Other purposes

If we need to process your personal data for any purpose other than those mentioned above, we will use them in accordance with the applicable legal provisions and the original purposes. In other cases, you will be informed in advance.

4. What are the legal bases for our processing of personal data?

Most of the personal data processing described above is necessary for the pre-contractual phase and the proper performance of our contractual obligations towards you (whether or not we have entered into a contract directly with you).

We may also process your personal data:

For our legitimate interests, e.g. to carry out marketing operations or improve our administrative management;
When it is necessary to comply with our legal obligations, e.g. to combat the financing of terrorism;
In certain exceptional cases where your vital interest or that of another individual is involved, e.g. in the case of medical assistance abroad.

If it is necessary to process your data for another purpose, we may ask for your consent.

5. What personal data do we use?

We may process the types of personal data described below. Only personal data relevant to the purposes for which they are to be used are processed. When we ask you for personal data, you have the right not to honour our request. However, this refusal may prevent our contractual obligations to you from arising or being properly fulfilled.

5.1 Types of data

Europ Assistance will process in particular:

Identification documents and information (like your name and date of birth);
Contact information (like your address, telephone number and email);
Data on your relatives and/or immediate family (such as their name and date of birth);
Information about your pets;
Informationabout your vehicle (such as the number plate);
Data on insured devices (such as the IMEI number for mobile phones);
Data concerning the use of digital tools (cyber assistance product);
Information about your home;
Information on your movements and geolocation;
Image and sound recording;
Health-related data;
Information concerning ongoing criminal proceedings (such as motoring offences);
Banking and payment data;
Data on your use of our websites (through cookies). Our cookies policy is available below.

Phone calls may be recorded. The recordings are preceded by an informational voice message.

5.2 Health-related data

Data concerning your health are sensitive personal data and we apply a higher level of protection to them. In particular, we ensure they are only used when strictly necessary and that access to them is kept to a minimum.

5.3 Source

The personal data collected may mainly come from:

The person directly concerned, verbally or in writing;
Third parties with whom the data subject has a contractual relationship (e.g. employers, banks, insurers, reinsurers or health organisations);
Persons involved in a loss or other event requiring our intervention (such as health professionals, other insurers, relatives of the person concerned);
The policyholder or one of the other beneficiaries when insurance products and services benefit several people.

When personal data is transmitted by a person other than the person concerned, Europ Assistance expects the data subject to have been informed of the transmission and to have given their consent, if necessary.

6. With whom do we share your personal data?

6.1 Potential recipients of personal data

Personal data may be communicated:

Within Europ Assistance (Suisse) Assurances SA and Europ Assistance (Suisse) SA;
To other companies in the Generali/Europ Assistance group (i.e. direct and indirect subsidiaries of Assicurazioni Generali S.p.A.), within and outside Switzerland;
To our service providers and other partners (such as auditors, reinsurers or co-insurers, claims managers, intermediaries, distributors). We draw your attention to the fact that the provision of our assistance products and services requires the intervention of third-party service providers and thus the transmission of personal or even medical data to them (e.g. when managing medical emergencies abroad or in the event of a car breakdown);
To your family and friends, in the event of a loss or other event requiring our intervention, though we take care to communicate only what is strictly necessary;
To third parties with whom you have a contractual relationship (such as your employer, your bank, insurers, reinsurers or healthcare organisations), in accordance with your contractual relationship with them;
To official, state and supra-state bodies.

6.2 Transfers of personal data abroad

We may transfer your personal data outside Switzerland in accordance with current legislation.

This will be the case in particular for:

IT infrastructure management from France (equivalent countries);
Specialised IT tools and applications, such as for accounting and finance or losses with associated data storage ("cloud") in France, Germany and Ireland (or equivalent countries);
Group procedures for managing quality, financial crime and whistleblowers mainly located in France and Italy (equivalent countries);
The provision of services and management of claims in fulfilment of our contractual obligations. This may be the case if you request our services from abroad and/or if it is necessary to use service providers located abroad.

In such cases, where strictly necessary, we may transfer personal data to countries, territories or organisations outside the EEA that are not recognised as providing an adequate level of protection by the Swiss Federal Data Protection Commissioner and/or the European Commission. In this event, we will take steps to ensure a higher level of protection, including contractual protection, and you have the right to ask us for information about the measures taken.

Lastly, in accordance with market practice, the use of IT tools and applications means that certain development and support operations may be carried out from countries outside the EEA. In these cases, the appropriate contractual protection is implemented.

7. How long do we keep your personal data?

We will keep your personal data for as long as necessary for the purposes mentioned above or for as long as is required by law.

8. Your rights concerning your personal data

You may exercise the following rights concerning your personal data:

Access: you may request access to your personal data;
Rectification: you may ask us to correct your personal data if they are incorrect or incomplete;
Deletion: you may ask us to delete your personal data, in particular:
When your personal data are no longer needed for the purpose for which they were collected or processed;
When the processing of your personal data is based solely on your consent and you decide to withdraw it;
If you object to the processing of your personal data and there are no other overriding legitimate grounds justifying their processing, or you object to direct marketing processing.
Restriction: you can ask Europ Assistance to restrict the way in which your personal data are processed for one of the following reasons:
You dispute the accuracy of your personal data for a period allowing Europ Assistance to verify this data;
The processing is unlawful and you object to the deletion of your personal data and request that their use be restricted instead;
Europ Assistance no longer needs your personal data for processing purposes, but you need them for the establishment, exercise or defence of legally founded claims.

Portability: you may ask Europ Assistance to transfer the personal data you have provided to us to another organisation, and/or ask to receive your personal data in a structured, commonly used and machine-readable format.

8.2 Automated decisions

In the context of the signature or performance of a contract, automated individual decisions (without human intervention) may be taken in your regard (e.g. for the calculation of prices). In particular, you can take out an insurance policy using the application forms on our website. You have the option of requesting the intervention of one of our staff.

9 Contacts for exercising your rights

9.1 Europ Assistance

You can send requests, including for the exercise of your rights, to: eachdpc@europ-assistance.ch.
In addition, Europ Assistance has appointed Europ Assistance Holding SAS, a simplified joint stock company registered in France (RCS 632 016 382) as its representative within the European Union for the purposes of article 27 of the GDPR. A data protection officer within the meaning of Article 37 of the GDPR has also been appointed and can be contacted at EAGlobalDPO@europ-assistance.com.
The request to exercise rights is free of charge, unless the request is manifestly unfounded or unreasonable.

9.2 Federal Data Protection and Information Commissioner

If you consider that we are not respecting your personal data protection rights, you may lodge a complaint with the competent data protection authorities. In Switzerland, this role is carried out by the Federal Data Protection and Information Commissioner: https://www.edoeb.admin.ch.