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1. Who is the data controller?

The data controller is ABANCA GENERALES DE SEGUROS Y REASEGUROS, S.A., with registered office at Avenida Linares Rivas 30 3rd, Postal Code: 15005, A Coruña and Tax ID A-14715270 (hereinafter, “ABANCA Seguros Generales”).

At ABANCA Seguros Generales, we have a Data Protection Officer (hereinafter also “DPO”), whom you may contact, if necessary, to obtain more information about any of the points included in our Privacy Policy and to send your questions, inquiries, or complaints related to the processing of your personal data, via the email address dpo.abancagenerales@abancaseguros.com.

Below, we provide you with detailed information about the processing of your personal data carried out by ABANCA Seguros Generales as the data controller.

2. What is the source of your personal data and what data do we process?

We must distinguish between the sources from which your personal data originate and the categories of personal data we process:

2.1 Sources of your personal data

Your personal data processed by ABANCA Seguros Generales may come from yourself (when you provide or supply them in the context of your relationship with us), be generated by ABANCA Seguros Generales (as a result of managing those relationships), or originate from external sources (that is, from third parties who are not part of your relationship with us and from whom we obtain data about you under the consent you may have given us for this purpose, or under another legally established basis that allows it). Below, we provide detailed information regarding the aforementioned internal and external sources from which your personal data may originate:

  • Data provided by you in the applications you submit to us or in the context of the formalization and development of your contractual or pre-contractual relationships with ABANCA Seguros Generales (e.g., the data necessary to request and contract an insurance policy, as well as other data provided for the processing of claims arising from the insurance contract, complaints, or other incidents). This data may include health data you have provided during the processing of a claim. If you provide us with data of third parties (e.g., insured persons or beneficiaries in insurance contracts), you guarantee that you have the express consent of these third parties for ABANCA Seguros Generales to process their data, including health data if you provide such information. You also guarantee that the third parties whose data you provide have been duly informed of the processing that ABANCA Seguros Generales will carry out with such data, as set out in this Privacy Policy.

  • Data generated about you as a result of the management, development, and maintenance of the contractual or pre-contractual relationships you have with ABANCA Seguros Generales (e.g., data about you generated as a result of the management and development of the products or services you have subscribed to with us).

  • Data obtained from external sources, under your prior consent or another legitimizing basis provided for in the regulations (e.g., because they are necessary for the proper provision of the insurance contract and its contingencies or for the assessment of the policy and claims management in the legitimate interest of ABANCA Seguros Generales, see section 3.3). The following are identified as “external sources” from which your personal data may originate:

    • Entities responsible for managing the contingencies covered in the insurance contract you have with ABANCA Seguros Generales;
    • Companies belonging to the Economic Group of ABANCA Corporación Bancaria, S.A. (“ABANCA”), whose business sectors include finance, social, insurance, real estate, investment, training, marketing, and consulting and advisory services. You can access the complete list of companies that are part of the ABANCA Economic Group at any given time at the hyperlink (https://www.abanca.com/es/legal/empresas-grupo-abanca/);
    • Common files of the insurance sector under the assumptions, conditions, and guarantees that allow their creation and consultation;
    • Publicly accessible sources, such as promotional census, electronic communications service directories, public lists of people associated with professional associations, official journals and bulletins, social media, and open social networks;
    • Files on asset and creditworthiness information (e.g., ASNEF).
    • Files from the Directorate General of Traffic and other public or private files that have information about the characteristics of the vehicle or driver that are relevant for calculating the insurance premium or managing the claim.
    • Reports, intervention records, or similar documents prepared by the State Security Forces and Corps as necessary for claim management.

2.2 Categories of personal data

At ABANCA Seguros Generales, we process different types of personal data to manage the contractual or pre-contractual relationships you have with us at any given time, as well as for the other purposes indicated in section 3. “For what purpose and on what legal basis do we process your personal data?” of this Privacy Policy.

To provide you with clear and detailed information in this regard, we have grouped the personal data we process into the following categories:

  • Identification and contact data: name, surname, identity document (DNI, passport, or NIE), postal and email address, and landline or mobile phone number.

  • Data related to your voice and image (e.g., recordings of telephone calls you have with us or videos recorded during online contracting procedures for new products and/or services).

  • Signature data (handwritten and digitized) and data related to codes or identification keys for access and operation in remote channels you use in your relationship with ABANCA Seguros Generales. If you use the digitized signature system to give your consent in the context of applications you submit to ABANCA Seguros Generales or contracts you have formalized or formalize with us, we will process the data associated with that signature. The data associated with the digitized signature are categories of data that include the calligraphic features of the signature, such as the pressure and speed with which it is made, as well as the inclination of the stroke; therefore, they may be used exclusively for the formulation, exercise, or defense of claims or in a judicial or administrative process in case of repudiation of the operation signed by means of the digitized signature system, in order to verify, through the corresponding comparison, that the signature is yours and to be able to prove the consent given and the reality and validity of the operation reflected in the electronic document to which the signature is attached. In this regard, the aforementioned data associated with the signature will be duly encrypted through a third-party trusted service provider, who will be the custodian of the private key to access them; thus, ABANCA Seguros Generales will not have access to such data except in the exclusive case that it requests the third-party provider to decrypt them by formal request and before a notary public, and only in the cases and for the purposes of verification and accreditation mentioned above.

  • Data on insurance policies contracted with ABANCA Seguros Generales: duration, type of insurance, claims history, etc.

  • Health data of insured persons and third parties when necessary for the processing and management of claims.

  • Personal, family, and social circumstances data: marital status, driving license, penalties and claims, age, family situation, date and place of birth, nationality, gender, vehicle and its characteristics; as well as personal data of third parties covered by the policy.

  • Economic and asset solvency data: data on the non-payment of a debt contracted with a private company, data on debts contracted with public bodies, and similar.

  • Financial data: ABANCA bank account number.

  • Transactional data: information related to the products and services requested or contracted (insurance characteristics, their coverage, and payment methods, for example).

  • Data inferred or deduced from the analysis and processing of the other categories of personal data: This category includes, on the one hand, the grouping of clients into categories and segments based on objective criteria such as age, preferences, or propensity to contract products and services. In no case will we infer any data that reveals your ethnic or racial origin, political opinions, religious or philosophical beliefs, or trade union membership, nor genetic data, data relating to your health or your sex life or sexual orientation, nor biometric data aimed at uniquely identifying you (“Special categories of data”).

  • Geographical location and device location data: based on the legitimate interest of ABANCA Seguros Generales in preventing fraud in the contracting and use of our products and services.

  • Data of persons subject to international sanctions and financial countermeasures: data of persons as indicated in laws, regulations, guidelines, resolutions, programs, or restrictive measures on international economic-financial sanctions imposed by the United Nations, the European Union, the Kingdom of Spain, the United Kingdom, and/or the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).

3. For what purpose do we process personal data and under what legal basis?

Below, we inform you about the different processing of your personal data for which ABANCA Seguros Generales is responsible, specifying the respective legal bases that legitimize them and the purposes of each. Additionally, and as indicated in the previous sub-section 2.2. (“Categories of data”), the specific categories of data used in each processing are detailed.

3.1. Processing necessary for the execution of your contractual or pre-contractual relationships with ABANCA Seguros Generales

This sub-section refers to the processing we carry out of your personal data for the execution of the contractual or pre-contractual relationships you establish with ABANCA Seguros Generales and, therefore, to provide you with the services and products that are the subject of those relationships.

The legal basis for this processing is, therefore, the necessity to execute or fulfill those contractual or pre-contractual relationships with ABANCA Seguros Generales of which you are a party.

Below are the processing activities referred to, indicating their respective purposes, as well as the categories of personal data used in each:

3.1.1. Formalization, maintenance, and fulfillment of relationships with ABANCA Seguros Generales

The purpose of this processing is the correct formalization, maintenance, and fulfillment of the contractual or pre-contractual relationships you establish with us.

The following are the data processing operations we may carry out within the framework of the aforementioned processing, which include obtaining the data necessary to manage the requests you make to us, evaluating the feasibility of contracting the corresponding products and services, and the correct formalization, maintenance, and fulfillment of the resulting contracts:

  • Receive the information or contracting requests you have made regarding our products and services, analyze and evaluate them, respond to you, and clarify any doubts that may arise.

  • Contact you, by electronic or non-electronic means, in the event of any incident that may have prevented the completion of the contracting of a product or service and allow you to resume its contracting.

  • Proceed, if applicable, to the activation of the requested operation by signing the corresponding contract.

  • Maintain, develop, and control your business relationships with ABANCA Seguros Generales.

  • Send you non-commercial communications strictly related to the products and services you have contracted with ABANCA Seguros Generales.

  • With prior information (either in the contractual or pre-contractual documentation or at the beginning of the call itself), record the telephone conversations you have with us, in order to, if necessary, comply with legal obligations, carry out quality controls, and use them as evidence in the context of a judicial or extrajudicial claim.

  • If applicable, analyze and manage situations of non-payment that may occur in the context of the products and services you have contracted with ABANCA Seguros Generales, which may involve the communication of your data to debt recovery service providers, acting on behalf of and for ABANCA Seguros Generales, to carry out collection actions.

  • Manage and respond to any claims you may submit.

  • Manage the application of bonuses, discounts, or any other promotional conditions, as well as the delivery of prizes and/or promotional gifts that may be associated with or applicable to the contractual relationship you have established with ABANCA Seguros Generales.

  • For reasons arising from the inclusion of a product or service in a reinsurance or coinsurance or due to the management of the policy itself, it will be necessary to communicate to third-party insurance entities the information about the contracting of any product or service, regardless of its commercial name, as well as the identification data of the contracting parties and the product or service (name and surname or company name; type and number of identification document; date of birth; country of nationality, if the country of issue of the identification document is not available; country of issue of the identification document, if the country of nationality is not available; declared country of residence; type of numbering of the contracted product or service; start and end date of the relationship between the account or deposit and the intervening person) and of the other holders and, where appropriate, representatives or authorized persons.

  • Determine the assistance or benefit to be provided to the insured and/or beneficiaries under the coverages included in the contract, as well as proceed with payment to service providers or reimbursement to the insured or beneficiary of expenses.

For the formalization, maintenance, and fulfillment of the contractual or pre-contractual relationships you establish with ABANCA Seguros Generales and, therefore, to provide you with the services and products that are the subject of those relationships, we may process the personal data corresponding to the following categories detailed in sub-section 2.2. (“Categories of data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same sub-section 2.2.): i) Identification and contact data; ii) Data related to your voice; iii) Personal, family, and social circumstances data; iv) Sociodemographic data; v) Economic and asset solvency data; vi) Financial data; vii) Transactional data; viii) Signature data (handwritten and digitized) and data related to codes or identification keys; where applicable, ix) Health data for the operations indicated in the last point and under the provisions of the insurance sector regulations; x) Data inferred or deduced from the analysis and processing of the other categories of personal data.

3.1.2. Analysis and assessment of the insured risk in the formalization, maintenance, fulfillment, and renewal of relationships with ABANCA Seguros Generales

The purpose of this processing is to analyze the risk associated with the insurance and, through the application of actuarial and statistical techniques, calculate premium rates.

When you request an insurance product from us, as well as in the case of contracting and even during its validity and renewal, we will carry out an analysis and assessment using actuarial and statistical techniques, thus obtaining a premium rate that is consistent with the characteristics of the insured and beneficiaries, the environment, and the historical data of ABANCA Seguros Generales.

Regarding the way these techniques are applied and their impact, you should bear in mind that, depending on the product requested or actually contracted, automatic decisions may be made regarding approval, denial, or reassessment of the product; or decisions regarding approval, denial, or reassessment of the product that are not completely automatic, as there is a subsequent review of the assessment result by a specific approval committee (so the result of the actuarial techniques is, in such case, merely indicative). In the event that the approval, denial, or reassessment decision is completely automatic, we inform you that you will have certain rights, in particular, the right to obtain human intervention by ABANCA Seguros Generales in the analysis of the decision, to express your point of view, and to challenge the decision made.

In the development of this purpose, in addition to analyzing the information requested during contracting or—upon renewals—derived from the maintenance of the contractual relationship, ABANCA Seguros Generales may consult:

  • Data relating to your non-fulfillment of monetary, financial, or credit obligations that may appear in credit information systems (e.g., ASNEF or BADEXCUG).
  • Information contained in common information systems of the insurance sector, in accordance with their access or consultation rules or other information available in third-party files, provided it is necessary for estimating the level of risk and the premium, as provided in insurance regulations, or for compliance with contracting requirements. For example, ABANCA Seguros Generales may check the status of the vehicle’s technical inspection (ITV) or information about its characteristics.

For the analysis and assessment of the insured risk in the formalization, maintenance, and fulfillment of relationships with ABANCA Seguros Generales, we may process personal data corresponding to the following categories detailed in sub-section 2.2. (“Categories of data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same sub-section 2.2.): i) Identification and contact data; ii) Signature data (handwritten and, where applicable, digitized); iii) Data on contracted insurance and claims occurred; where applicable, iv) Health data; vi) Personal data of third parties covered by the policy; vii) Personal, family, and social circumstances data; viii) Sociodemographic data; ix) Economic and asset solvency data; x) Financial data; xi) Transactional data; xii) Data inferred or deduced from the analysis and processing of the other categories of personal data.

3.1.3. Obtaining contact data to manage non-payment situations

In the context of executing the contractual relationships you have with ABANCA Seguros Generales, in order to claim the amount(s) owed in the event of non-payment, it is necessary to have up-to-date contact data to enable the development of extrajudicial collection actions.

The purpose of this processing is to update your contact information if we are unable to contact you through the information you provided when formalizing the contractual relationships with ABANCA Seguros Generales. This update of your contact data will be carried out only and exclusively in the event of a non-payment situation.

Thus, we inform you that the new contact data may be obtained from the following sources:

  • Companies of the ABANCA Economic Group;
  • Publicly accessible sources (e.g., official journals and bulletins, public lists of people associated with professional associations, or open social networks);
  • Debt recovery agencies;
  • Third parties who are accidentally contacted because they are the current holders of the contact address that previously belonged to you.

The information is always obtained with the guarantee that the data collected comply with the principle of quality and accuracy, in addition to having been obtained lawfully. For obtaining additional contact data to manage non-payment situations, we may process personal data corresponding to the following categories detailed in sub-section 2.2. (“Categories of personal data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same sub-section 2.2.): Identification and contact data.

3.2. Processing carried out to comply with legal obligations

The insurance sector, of which ABANCA Seguros Generales is a part, is highly regulated, and this means that we must process your data to comply with the legal obligations applicable to us in each case.

The legal basis for this processing is, therefore, the necessity to comply with the legal obligations to which ABANCA Seguros Generales is subject in the course of its activity.

Below are the personal data processing operations we may carry out in the context of the aforementioned processing and depending on the legal framework applicable to ABANCA Seguros Generales in each case:

3.2.1. Responding to possible requests for information made by administrations, public bodies, and courts and tribunals

In compliance with the applicable regulations in force and in the context of proceedings in which administrations and public bodies, as well as courts and tribunals, are competent, we are obliged to communicate to these entities the data generated at ABANCA Seguros Generales as a result of the relationship(s) established with you.

To comply with the obligation to respond to possible requests for information made by the aforementioned competent administrations, public bodies, and courts and tribunals, we may process data corresponding to the following categories detailed in sub-section 2.2. (“Categories of data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same sub-section): i) Identification and contact data; ii) Data related to your voice; iii) Signature data (handwritten and, where applicable, digitized) and data related to codes or identification keys; iv) Data on contracted insurance; v) Special categories of data (e.g., health data necessary for the processing and management of claims occurred); vi) Personal data of third parties covered by the policy; vii) Personal, family, and social circumstances data; vii) Sociodemographic data; xx) Economic and asset solvency data; xi) Financial data; xii) Transactional data; xiii) Data inferred or deduced from the analysis and processing of the other categories of personal data.

3.2.2. Other legal obligations

Consulting lists of persons and entities subject to international sanctions and financial countermeasures (e.g., the list of specially designated nationals and blocked persons at the U.S. Department of the Treasury “SDN List” -http://sdnsearch.ofac.treas.gov-), either directly or through consultation tools and databases provided by third parties.

Finally, we may process your health data for damage assessment and claims settlement.

3.3. Processing based on the legitimate interest of ABANCA Seguros Generales

This section refers to the processing of your personal data based on the satisfaction of legitimate interests pursued by ABANCA Seguros Generales, provided that your own interests or fundamental rights and freedoms do not prevail over those legitimate interests. In no case will health data or other special categories of data be processed on the basis of legitimate interest.

For this reason, prior to carrying out the processing described in this sub-section 3.3., we have carried out a balancing test between your rights and the legitimate interest of ABANCA Seguros Generales, concluding that the latter prevails. You can consult the balancing analysis we have carried out by contacting our DPO at the following email address: dpo.abancagenerales@abancaseguros.com.

3.3.1. Preventing Fraud

It is also in the legitimate interest of ABANCA Seguros Generales to prevent situations of fraud in the contracting and use of our products or services (e.g., identity theft, password theft, or claim management) that could result in harm to you, to third parties, and/or to ABANCA Seguros Generales. Therefore, and for the purpose of fraud prevention, we may carry out the following processing operations on your personal data:

  • Consulting ABANCA Economic Group companies or the ABANCA Seguros Generales corporate group regarding anomalous activities.
  • Analysis of identification, authentication, contracting, and management processes of our products or services with the aim of detecting operations that do not correspond to the client’s usual way of operating.
  • Analysis of the claim in order to verify its causes, consequences, and coverage.

To prevent fraud in our product and service contracting processes, as well as in the provision of such products and/or the use of contracted services, we may process personal data corresponding to the following categories detailed in subsection 2.2 (“Categories of Data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same subsection 2.2.): i) Identification and contact data; ii) Sociodemographic data; iii) Financial data; iv) Health data necessary for the processing and management of occurred claims; v) Personal data of third parties covered by the policy; vi) Personal, family, and social circumstances data; x) Economic and asset solvency data; xi) Transactional data; xii) Data inferred or deduced from the analysis and processing of the rest of the categories of personal data; xiii) digitized; xiv) Geographical location data.

3.3.2. Creation of commercial profiles, to offer you advertising information tailored to these profiles, about products and services similar to those contracted

At ABANCA Seguros Generales, we use your personal data obtained from our internal sources (that is, data we have because you provided it or it was generated within ABANCA Seguros Generales due to the management of products and services you have contracted with us) for the purpose of creating your commercial profile, and using that profile to offer you advertising information tailored to it about products and services similar to those you have contracted with us. For this purpose, we will only use data obtained from external sources if you have given us your consent for this, as provided in subsection 3.4.6. of this Privacy Policy, or if we have another legally established legal basis that allows its processing.

Below, we explain how we create and use your commercial profile for the indicated purpose:

The processing of your personal data for the creation of your commercial profile aims to understand your needs, interests, and preferences and to personalize the product and service offers we make so that you only receive offers that match those needs, interests, and preferences.

The interest pursued by ABANCA Seguros Generales is to be more efficient and effective when targeting our client group with advertising, or in other words, to maximize the performance of our commercial campaigns.

This processing consists of using your personal data to analyze and predict your personal preferences, economic situation, interests, and behavior through techniques based on basic profiling rules (that is, simple segmentations such as, for example, clients within a certain age range or residing in a specific region), and advanced techniques based on supervised and unsupervised Machine Learning algorithms, which allow the construction of propensity models and the execution of advanced segmentations.

To create this commercial profile, we will process personal data corresponding to the following categories detailed in subsection 2.2 (“Categories of Data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same subsection 2.2): i) Identification and contact data; ii) Personal, family, and social circumstances data; iii) Economic and asset solvency data; iv) Financial data; and v) Transactional data. As indicated above, such data will not include those obtained from external sources, except in the exclusive case that we have your consent for this, as provided in subsection 3.4.6. of this Privacy Policy, or if we have another legally established legal basis that allows its processing.

The data used may correspond to the two years immediately prior to the creation and/or review of the commercial profile.

At any time, you may object to the processing of your data for the creation of your commercial profile by emailing: dpo.abancagenerales@abancaseguros.com.

The final consequence of creating your commercial profile is that, as a client, you will only receive advertising information about our products and services that is appropriate to your needs, interests, and preferences. That is, this profile is used exclusively for the indicated purpose and, therefore, cannot be used as grounds for denying any product and/or service.

3.3.3. Offering you advertising information about products and services similar to those contracted

By virtue of the legitimate interest of ABANCA Seguros Generales in promoting its products and services, we may process your personal data in order to send you advertising information referring to products and services similar to those you have contracted with ABANCA Seguros Generales.

Prior to processing your data for such direct marketing purposes, in addition to consulting our internal records to ensure that you have not objected to such processing, we will consult the Robinson List, to ensure that you are not included in any advertising exclusion database.

This advertising information may be generic or personalized, that is, tailored to your commercial profile as described in the previous subsection 3.3.2 (profiling with internal sources) or, if you give your consent for this, as described in the following subsection 3.4.6 (profiling with external sources).

Whenever you wish, you may object to the sending of such advertising information by emailing: dpo.abancagenerales@abancaseguros.com.

Unless you indicate otherwise, this information may be sent to you through the following channels:

  • Postal mail;
  • Email and social networks;
  • Any type of message to your mobile phone;
  • The apps that ABANCA Seguros Generales may offer and of which you are a user;
  • Phone calls.

To send you advertising information regarding products and services similar to those you have contracted with ABANCA Seguros Generales, we may process personal data corresponding to the following categories detailed in subsection 2.2. (“Categories of Data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in the same subsection 2.2.): Identification and contact data.

3.3.4. Conducting satisfaction surveys of our contracted products and services

By virtue of the legitimate interest of ABANCA Seguros Generales in evaluating the level of satisfaction and quality of the contracted product or service, we may process your personal data in order to conduct satisfaction surveys referring to products and services you have contracted with ABANCA Seguros Generales.

Unless you indicate otherwise, these surveys may be sent through the following channels:

  • Postal mail;
  • Email and social networks;
  • Any type of message to your mobile phone;
  • The apps that ABANCA Seguros Generales may offer and of which you are a user;
  • Phone calls.

To evaluate the level of satisfaction and quality of the product or service contracted with ABANCA Seguros Generales, we may process personal data corresponding to the following categories detailed in subsection 2.2. (“Categories of Data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in the same subsection 2.2.): i) Identification and contact data; and ii) Data on contracted insurance and products.

3.3.5. Conducting statistical and historical studies

The continuous analysis of our internal processes is necessary to achieve various purposes related to improving the quality of our business performance, such as:

  1. The development and optimization of analytical, business, and risk models.
  2. Achieving greater effectiveness and efficiency in our internal processes and improving our products and services.
  3. Generating information relevant to business decision-making and its monitoring.
  4. Generating economic indicators and obtaining aggregated economic information about our business.
  5. Ensuring the security of our systems and protecting the confidentiality, integrity, and availability of the information processed by the entity and our processes.
  6. Improving our products and services.

However, whenever possible, ABANCA Seguros Generales will apply:

  1. Anonymization techniques through which the initial information would become anonymous information that could not be associated with a specific person.
  2. Pseudonymization techniques through which your identification or contact data would be replaced by internal identifiers.

Additionally, in any case, the information processed by ABANCA Seguros Generales will be the minimum essential for the development of the intended purpose.

In the course of this analysis, we may process personal data corresponding to the following categories detailed in subsection 2.2. (“Categories of Personal Data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same subsection 2.2.): i) Identification and contact data; Data relating to your voice (in the case of telephone surveys); ii) Personal, family, and social circumstances data; iii) Sociodemographic data; iv) Economic and asset solvency data; v) Transactional data; vi) Financial data; vii) Data on insurance marketed by ABANCA Seguros Generales that you have contracted; viii) Data obtained through the participation form in the survey in which you voluntarily participate; ix) Data inferred or deduced from the analysis and processing of the rest of the categories of personal data.

3.3.8. Data analysis for the improvement of internal processes

The continuous analysis of our internal processes is necessary to achieve various purposes related to improving the quality of our business performance, such as:

  • The development and optimization of analytical, business, and risk models.
  • Achieving greater effectiveness and efficiency in our internal processes.
  • Generating economic indicators and obtaining aggregated economic information about our business.
  • Ensuring the security of our systems and protecting the confidentiality, integrity, and availability of the information processed by the Entity and our processes.
  • Improving our products and services.

However, whenever possible, ABANCA Seguros Generales will apply:

  • Anonymization techniques through which the initial information would become anonymous information that could not be associated with a specific person.
  • Pseudonymization techniques through which your identification or contact data would be replaced by internal identifiers.

Additionally, in any case, the information processed by ABANCA Seguros Generales will be the minimum essential for the development of the intended purpose.

In the course of this analysis, we may process personal data corresponding to the following categories detailed in subsection 2.2. (“Categories of Personal Data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same subsection 2.2.): Identification and contact data; Data relating to your voice (in the case of telephone surveys); Personal, family, and social circumstances data; Commercial activity data; Sociodemographic data; Economic and asset solvency data; Transactional data; Financial data; Data obtained through the participation form in the survey in which you voluntarily participate; and Data inferred or deduced from the analysis and processing of the rest of the categories of personal data.

3.4. Processing based on your consent

In this subsection, we refer to those processing activities of your personal data that we will carry out exclusively if we have requested and obtained your prior consent for this purpose.

The legal basis for the different processing activities described below therefore lies in the consent that you may have given us for each of them.

We remind you that such consent is revocable, that is, you may withdraw it whenever you wish and, in that case, ABANCA Seguros Generales will cease the corresponding processing. However, the withdrawal of consent will not have retroactive effects, so it will not affect the lawfulness of the processing previously carried out. To consult, revoke, or withdraw the consent you may have given us, you may contact us at: dpo.abancagenerales@abancaseguros.com.

The processing of your personal data that we may carry out if we have requested and obtained your prior consent for it are detailed below:

3.4.1. Offering you advertising information tailored to your profile about products and services of ABANCA Economic Group companies and partners

We will process your personal data to offer you, through any means (postal mail, telephone, any type of message to your mobile phone (such as SMS or push messages), email, social networks, or our apps), information tailored to your commercial profile (that is, adapted to your interests, needs, and preferences, as explained in subsection 3.3.2 of this Privacy Policy) about products and services of ABANCA Economic Group companies, as well as third-party partners of ABANCA Seguros Generales.

The business sectors of the ABANCA Economic Group companies include finance, social, insurance, real estate, investment, training, marketing, and consulting and advisory services. You can access the complete list of companies that are part of the ABANCA Economic Group at any time at https://www.abanca.com/es/legal/empresas-grupo-abanca/ .

The third-party partners of ABANCA Seguros Generales are companies with which ABANCA Seguros Generales maintains commercial collaboration agreements and that offer financial, insurance, leisure, food, appliances, furniture, vehicles, footwear, textile, optical, or personal consumption products and services.

To offer you advertising information about products and services of the ABANCA Economic Group companies and third-party partners as indicated in this section, we may process personal data corresponding to the following categories detailed in subsection 2.2. (“Categories of Data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same subsection 2.2.): i) Identification and contact data; ii) Data inferred or deduced from the analysis and processing of the rest of the categories of personal data (mainly, the commercial profile created with the basic and advanced profiling techniques described in subsection 3.3.2. of this Privacy Policy).

3.4.2. Sharing your data with ABANCA Economic Group companies to facilitate their contracting processes with you

We will share your personal data with the ABANCA Economic Group companies referred to in the previous subsection 3.4.1 in order to facilitate and expedite the analysis (including the risk to be insured in the case of insurance operations or the credit risk in the case of financing operations) and the possible formalization of a contract or pre-contract that you have requested from the corresponding ABANCA Economic Group company recipient of the data; or to facilitate and expedite the management and execution of a contract or pre-contract that you already have with the corresponding ABANCA Economic Group company recipient of the data.

The personal data that ABANCA Seguros Generales may share with other ABANCA Economic Group companies as provided in this subsection 3.4.2 are those corresponding to the following categories detailed in subsection 2.2 (“Categories of Data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same subsection 2.2.): i) Identification and contact data; ii) Economic and asset solvency data; iii) Financial data; iv) Transactional data; v) Data inferred or deduced from the analysis and processing of the rest of the categories of personal data (mainly, the commercial profile created with the basic and advanced profiling techniques described in subsection 3.3.2. of this Privacy Policy).

3.4.3. Sharing your data with ABANCA Seguros Generales partners to facilitate their contracting processes with you

We will share your personal data with ABANCA Seguros Generales partners referred to in the previous subsection 3.4.1 in order to facilitate and expedite the analysis (including the risk to be insured in the case of insurance operations or the credit risk in the case of financing operations) and the possible formalization of a contract or pre-contract that you have requested from the corresponding ABANCA Seguros Generales partner recipient of the data; or to facilitate and expedite the management and execution of a contract or pre-contract that you already have with the corresponding ABANCA Seguros Generales partner recipient of the data. The personal data that ABANCA Seguros Generales may share with its partners as provided in this subsection 3.4.3 are those corresponding to the following categories detailed in subsection 2.2 (“Categories of Data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same section): i) Identification and contact data; Economic and asset solvency data; ii) Financial data; Transactional data; iii) Data inferred or deduced from the analysis and processing of the rest of the categories of personal data (mainly, the commercial profile created with the basic and advanced profiling techniques described in subsection 3.3.2. of this Privacy Policy).

3.4.4. Sharing your data with ABANCA Economic Group companies so they can offer you advertising information tailored to your profile about their products and services

We will share your personal data with the ABANCA Economic Group companies referred to in the previous subsection 3.4.1 so that these companies can create or update your commercial profile and your risk profile in insurance matters or, where appropriate, your credit risk profile, and, using these profiles, can prepare and offer you information tailored to them (that is, adapted to your interests, needs, preferences, savings capacity, and credit capacity) about the products and services they market at any given time; information that, consequently, these companies will send you directly and through any means (including email, SMS messages, and other equivalent electronic communication means).

To create or update your commercial profile, the ABANCA Economic Group companies may use basic and advanced profiling techniques as described in subsection 3.3.2. of this Privacy Policy. Additionally, and also for the purpose of creating or updating your commercial profile, such companies may consult legitimate files of the sector or sectors in which they operate (e.g., common risk selection and pricing files in the insurance sector). The personal data that ABANCA Seguros Generales may share with the ABANCA Economic Group companies as provided in this subsection 3.4.4 are those corresponding to the following categories detailed in subsection 2.2 (“Categories of Data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same subsection 2.2): i) Identification and contact data; ii) Economic and asset solvency data; iii) Financial data; Transactional data; iv) Data inferred or deduced from the analysis and processing of the rest of the categories of personal data (mainly, the commercial profile created with the basic and advanced profiling techniques described in subsection 3.3.2. of this Privacy Policy).

3.4.5. Sharing your data with ABANCA Seguros Generales partners so they can offer you advertising information tailored to your profile about their products and services

We will share your personal data with ABANCA Seguros Generales partners referred to in the previous subsection 3.4.1 so that they can create or update your commercial profile and your risk profile in insurance matters or, where appropriate, your credit risk profile, and, using these profiles, can prepare and offer you information tailored to them (that is, adapted to your interests, needs, preferences, savings capacity, and credit capacity) about the products and services they market at any given time; information that, consequently, these partners will send you directly and through any means (including email, SMS messages, and other equivalent electronic communication means).

To create or update your commercial profile, ABANCA Seguros Generales partners may use basic and advanced profiling techniques as described in subsection 3.3.2. of this Privacy Policy. Additionally, and also for the purpose of creating or updating your commercial profile, such partners may consult legitimate files of the sector or sectors in which they operate (e.g., common risk selection and pricing files in the insurance sector).

The personal data that ABANCA Seguros Generales may share with its partners as provided in this subsection 3.4.5 are those corresponding to the following categories detailed in subsection 2.2 (“Categories of Data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same subsection 2.2.): i) Identification and contact data; ii) Economic and asset solvency data; iii) Financial data; iv) Transactional data; v) Data inferred or deduced from the analysis and processing of the rest of the categories of personal data (mainly, the commercial profile created with the basic and advanced profiling techniques described in subsection 3.3.2. of this Privacy Policy).

3.4.6. Voluntary improvements in the insurance premium calculation process and creation of your commercial profile using external sources

We will enrich the information we already have about you from our internal sources (that is, information you have provided or generated at ABANCA Seguros Generales as a result of managing the products and services you have contracted with us) with other data about you provided by various external sources, such as public records (e.g., the Land Registry, the Commercial Registry, the National Institute of Statistics, and the Cadastre); publicly accessible sources (e.g., public lists of people associated with professional associations, official journals and bulletins, and for the purpose of verifying the existence of previous fines and adjusting to the characteristics of the driver, social media and open social networks); companies within the ABANCA Economic Group to which you have authorized to transfer your personal data to us (e.g., scoring) for this purpose; geomarketing tools and databases; browsing data on third-party websites and applications, if you have accepted the use of cookies and similar technologies on the relevant browsing devices; as well as common insurance sector files (e.g., risk selection and rating files and files for the preparation of technical and statistical-actuarial studies). All this is to have relevant information to calculate the premium amount and create a more complete and in-depth commercial profile than the one created with the internal sources mentioned in subsection 3.3.2. of this Privacy Policy, which will allow us to more accurately personalize the offers we send you regarding our products and services.

Indeed, with information about you enriched with external sources, and by applying the profiling techniques described in subsection 3.3.2. of this Privacy Policy to such information, we will be able to adapt or select with greater precision the offers of products and services from ABANCA Seguros Generales that best suit your characteristics and, therefore, your interests, insurance needs, preferences, savings capacity, and creditworthiness; and, if we have obtained your consent as referred to in subsection 3.4.1, select the offers of products and services from other companies in the ABANCA Economic Group and/or partners that best suit your characteristics and, therefore, your interests, financial or insurance needs, preferences, savings capacity, and creditworthiness.

To create your commercial profile using information about you enriched with external sources, we may process personal data corresponding to the following categories detailed in subsection 2.2 (“Categories of data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same subsection 2.2.): i) Identification and contact data; ii) Personal, family, and social circumstances data; iii) Sociodemographic data; iv) Economic and asset solvency data; v) Financial data; vi) Transactional data; and vii) Browsing and online behavior data.

The data used may correspond to the last two years.

3.4.7. Retaining the processing of your personal data after our relationship ends to manage a new request

We will retain your personal data after our relationship with you ends, and for a maximum period of 5 years, to manage new requests for products or services that you may submit to us.

For this purpose, we may process personal data corresponding to the following categories detailed in subsection 2.2. (“Categories of data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same section): i) Identification and contact data; ii) Personal, family, and social circumstances data; iii) Sociodemographic data; iv) Economic and asset solvency data; and v) Financial data.

3.4.8. Retaining the processing of your personal data after our relationship ends to continue sending you advertising information tailored to your profile about products and services of ABANCA Seguros Generales

We will retain your personal data after our relationship with you ends, and for a maximum period of 5 years, to continue sending you, by any means (postal mail, telephone, any type of message to your mobile phone – such as SMS or push messages –, email, social networks, or our apps), advertising information tailored to your commercial profile (that is, adapted to your interests, needs, and preferences, as explained in subsection 3.3.2 of this Privacy Policy) about products and services of ABANCA Seguros Generales.

For these purposes, we may process personal data corresponding to the following categories detailed in subsection 2.2. (“Categories of data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same section): i) Identification and contact data; ii) Data inferred or deduced from the analysis and processing of the rest of the categories of personal data.

3.4.9. Retaining the processing of your personal data after our relationship ends to continue sending you advertising information tailored to your profile about products and services of companies in the ABANCA Economic Group and partners

We will retain your personal data after our relationship with you ends, and for a maximum period of 5 years, to continue sending you, by any means (postal mail, telephone, any type of message to your mobile phone (such as SMS or push messages), email, social networks, or our apps), information tailored to your commercial profile (that is, adapted to your interests, needs, and preferences, as explained in subsection 3.3.2 of this Privacy Policy) about products and services of companies in the ABANCA Economic Group and third-party partners of ABANCA Seguros Generales referred to in the previous subsection 3.4.1 of this Privacy Policy.

For these purposes, we may process personal data corresponding to the following categories detailed in section 2.2. (“Categories of data”) of this Privacy Policy (without prejudice to the application of the principle of minimization of personal data as indicated in that same section): i) Identification and contact data; ii) Data inferred or deduced from the analysis and processing of the rest of the categories of personal data.

4. Who do we share your data with?

4.1 General information

We will only share your personal data with third parties when you have given us your consent to do so or there is another legal basis that supports such data communication. Thus, the data processing carried out by ABANCA Seguros Generales described in this Privacy Policy may involve your data being communicated to the following recipients:

  • To Financial Entities to proceed with the appropriate collections and payments.

  • To the common files of the insurance sector that may be applicable and public records (e.g., risk selection and rating files and files for the preparation of technical and statistical-actuarial studies).

  • To Public Bodies, such as the Institute of Accounting and Auditing of Accounts or the Insurance Compensation Consortium, in cases where current regulations, or an agreement signed by ABANCA Seguros Generales with the corresponding body, so determine.

  • To private reinsurance or coinsurance entities, responsible for managing the coverages included in the coinsurance and reinsurance policy regarding the risks assumed by them.

  • To entities responsible for managing the contingencies and services included in the insurance contract you have with ABANCA Seguros Generales.

  • To insurance intermediaries.

  • To national and European Union supervisory authorities.

  • To companies in the ABANCA Seguros Generales corporate group for internal administrative purposes, detection of anomalous activities (fraud prevention), and compliance with legal obligations and internal regulations regarding international sanctions and consultation of lists of persons and entities subject to international sanctions and financial countermeasures.

  • To companies in the ABANCA Economic Group and partner companies, with your prior consent and for the purposes of streamlining your contracting processes and carrying out advertising actions tailored to your profile, or for the provision of any of the services associated with the contracted insurance, for example:

  • To ABANCA Corporación Bancaria, S.A and ABANCA Servicios Financieros, E.F.C, S.A so that they can manage the financing operations that, where appropriate, you have requested from them and that will be covered by the insurance you contract with ABANCA Seguros Generales;
  • To ABANCA Corporación Bancaria, S.A. to allow the direct debit of the insurance payment and, where appropriate, process its financing and/or deferred payment.

You can access the complete list of companies that are part of the ABANCA Economic Group at any time at: https://www.abanca.com/es/legal/empresas-grupo-abanca/

  • Service providers. The purpose of these communications will be the management by these third parties, called data processors, of the provision of certain services on behalf of ABANCA Seguros Generales. They will process your personal data on our behalf and always following our instructions. Under no circumstances may they process your personal data for their own purposes. At ABANCA Seguros Generales, we follow strict criteria for selecting service providers and sign the corresponding data processing agreement with each of them, which sets out the conditions of confidentiality, security, and data processing in accordance with the regulations in force at any given time. These third parties may include different sectors of activity such as: Training services; Trusted third-party services; Survey services; Call center services; Insurance back-office services; Administrative support services; Postal, distribution, and courier services; Printing and envelope stuffing services; Archiving, custody, storage, and digitization services; Document removal and destruction services; Audit and consulting services; Legal services; Physical security services; Logical security services; IT services; Telecommunications services; and Communication and activity support services.

  • To the Directorate General of Insurance and Pension Funds and European supervisory bodies, in compliance with the functions attributed to them by regulations as national and/or European supervisory authorities; this communication of your data will be for the purpose of supervising the activity of insurance companies and pension fund managers.

  • To entities that manage credit information systems or also known as files on non-compliance with monetary obligations (e.g., BADEXCUG or ASNEF). The purpose of these communications is to report debts that meet the requirements established by law, after prior communication indicating the rights you have.

  • To the AEAT and other competent tax administrations, in compliance with applicable tax regulations.

  • To State Security Forces and Corps in the context of investigation procedures—judicial and/or administrative—in which they are competent or in compliance with applicable regulations.

  • To Judges and Courts, in the context of judicial proceedings in which they are respectively competent or in compliance with applicable regulations.

  • To the Customer Ombudsman: D.A. Defensor, S.L., in order to address and resolve, in the second instance, complaints and claims that have previously been resolved by the ABANCA Seguros Generales Customer Service in the first instance arising from insurance contracts in accordance with the provisions of the ABANCA Seguros Generales Customer Defense Regulations.

4.2 Common insurance sector systems - SIHSA and SIATPRI

4.2.1 Introduction

Pursuant to the provisions of personal data protection regulations, we inform you about the processing of your personal data in the following Information Systems (hereinafter, collectively, the “Systems”):

  • Historical Automobile Insurance Information System (hereinafter, “SIHSA”).
  • Total Loss, Theft, and Fire Automobile Information System (hereinafter, “SIAPTRI”).

We also inform you that the processing of personal data included in the Systems is carried out in accordance with the provisions of the Code of Conduct Regulating the Processing of Personal Data in the Common Information Systems of the Insurance Sector, promoted by UNESPA (hereinafter, the “Code of ConductView PDF file”). This code was approved by the UNESPA Executive Committee at its meeting on December 5, 2019, and registered in the General Registry of the Spanish Data Protection Agency on June 29, 2022.

4.2.2 Joint controllers

The personal data included in the Systems will be processed, under joint responsibility, by all Insurance Entities adhering to the Systems. You can consult the complete list of these entities, along with the contact details of their respective Data Protection Officers, by clicking hereYou will be redirected to another website.

Likewise, we inform you that Tecnologías de la Información y Redes para las Entidades Aseguradoras, S.A. (hereinafter, “TIREA”), acts as the data processor.

4.2.3 Purposes

  • SIHSA: (i) to issue, in favor of the owner of the insured vehicle and the policyholder of said vehicle, their claims history or, where appropriate, a certificate of absence of claims; (ii) to allow the adhering insurance entities to make inquiries, at the request of policyholders, when they request the subscription of a new policy, in order to carry out a technical and objective risk assessment, as well as the correct application of premium rates.
  • SIAPTRI: (i) to facilitate the automated identification of possible situations of anomaly and risk of fraud by the policyholder, the vehicle owner, or the beneficiary of the compensation, so that the adhering insurance entities can adequately assess policy subscription requests and, where appropriate, risk rating; (ii) to properly process claims where a possible risk of fraud is detected; (iii) to cooperate with the State Security Forces and Corps in the investigation of possible crimes of theft and fraud related to insured vehicles; and (iv) to collaborate with the State Security Forces and Corps, Centro Zaragoza, the Directorate General of Traffic, and the affected insurance entity in the identification and location of stolen and compensated vehicles.

4.2.4 Legal basis

The legal basis that justifies and allows the processing of personal data included in the Systems is compliance with legal obligations for the detection, prevention, and prosecution of insurance fraud, established in Article 100 of Law 20/2015, of July 14, on the regulation, supervision, and solvency of insurance and reinsurance entities.

In the case of SIHSA, the processing would be legitimized by compliance with the legal obligation to provide the owner or policyholder with the claims history of the vehicle, imposed on insurance entities by Article 2.7 of the Consolidated Text of the Law on Civil Liability and Insurance in the Circulation of Motor Vehicles.

4.2.5 Category of personal data

SIHSA: insured vehicle (including license plate), policyholder data, contract data (including policy number), and claim data. SIAPTRI: data of the policy covering the claim, policyholder data, insured vehicle data, owner and/or beneficiary of the compensation data, description and situation of the claim data, and compensation data.

4.2.6 Recipients

The personal data contained in the Systems may be communicated to the Insurance Entities adhering to them as long as you have a contractual relationship with them or you have requested the conclusion of an insurance contract from them. You can access the list of adhering entities at www.unespa.es and www.tirea.es.

Additionally, the data stored in SIAPTRI may be communicated to the Vehicle Repair Research Institute, S.A. (Centro Zaragoza), the Security Forces and Corps, the Secretary of State for Security, and the Directorate General of Traffic, in accordance with the provisions of the Code of Conduct.

4.2.7 Retention period

The personal data incorporated into SIHSA will be kept as long as necessary to fulfill the purposes that justify their processing. Specifically, the data will remain in the Systems until five years have passed since the cancellation of the policy or since the occurrence of the claims.

On the other hand, the data contained in SIAPTRI will be kept for a period of five years from the date of the claim. That is, in no case will these systems contain data relating to claims and the policies associated with them that are more than five years old.

After these periods, the data will be kept, duly blocked, during the limitation period for actions arising from the contracts (5 years). Subsequently, the data will be completely deleted.

4.2.8 Rights

You may exercise your rights of access, rectification, erasure, or restriction of processing by writing to TIREA at the postal address Ctra. Las Rozas – El Escorial Km. 0.3, C.P. 28231, Las Rozas (Madrid) or at the email address centro.operaciones@tirea.es, indicating your name and surname and sufficiently identifying yourself.

Likewise, we inform you that, since the processing of the data is based on compliance with a legal obligation, it will not be possible to exercise the rights of objection and portability in relation to the Information Systems.

4.2.9 Complaint

We inform you that, if you consider that there has been a breach of data protection regulations or the Code of Conduct or if you are not satisfied with the response received after exercising a right, you may file a complaint with the Supervisory Body of the Code of Conduct that regulates the processing of data included in the System.

To do so, you must send your letter to the address indicated above or via the email address centro.operaciones@tirea.es. In the letter, you must indicate that the purpose is to file a complaint with the Supervisory Body of the Code of Conduct, state the reasons why you object to the entity's decision, and provide any documents supporting your claim. In this regard, you may use the forms that UNESPA and TIREA make available on their websites www.unespa.es and www.tirea.es, respectively.

Finally, we inform you that you have the right to file a complaint with the Spanish Data Protection Agency through its website www.aepd.es.

5. Is any international transfer planned?

Certain companies that provide services to ABANCA Seguros Generales are located outside the European Union, which implies the carrying out of International Data Transfers. In this regard, ABANCA Seguros Generales guarantees the application of technical, organizational, and legal security measures that are appropriate to the level of risk of the processing, regardless of where it takes place.

Any communication of data to third parties located in countries outside the European Economic Area (EEA) will be subject to an adequate level of protection that guarantees the security and legitimacy of the processing of your personal data, in accordance with the applicable regulations.

For more information about international data transfers and the guarantee mechanisms applied, you can contact the Data Protection Officer of ABANCA Seguros Generales at the following email address: dpo.abancagenerales@abancaseguros.com.

6. How long do we keep your data?

Your personal data will be kept for the duration of the contractual or pre-contractual relationship with ABANCA Seguros Generales and, if you have given your consent for this purpose, will be kept after the contractual or pre-contractual relationship for a maximum period of 5 years.

Once the contractual or pre-contractual relationship has ended (or, where appropriate, after the 5-year period), the data will be blocked in accordance with the applicable regulations, which means the identification and reservation of the data, adopting technical and organizational measures, to prevent their processing, except for the formulation, exercise, or defense of claims or for their provision to Judges and Courts, the Public Prosecutor's Office, or the competent Public Administrations, for the purpose of attending to or demanding possible liabilities arising from the processing and only during the legal limitation periods for such liabilities.

After these periods, your personal data will be deleted.

7. What are your rights?

Data protection regulations grant you a series of rights in relation to the processing of your personal data:

  • Right of access. You can find out what type of data we are processing and the characteristics of the processing we are carrying out.

  • Right of rectification. You can request the modification of your data when it is inaccurate or incomplete.

  • Right to portability. You can obtain a copy in an interoperable format of the data being processed.

  • Right to restriction of processing. You can request the restriction of the processing of your personal data when any of the conditions set out in the law are met:
    • When you challenge the accuracy of your personal data, during the period in which ABANCA Seguros Generales verifies their accuracy;
    • When the processing is unlawful but you oppose the erasure of your data;
    • When ABANCA Seguros Generales does not need to process your data but you need them for the establishment, exercise, or defense of claims; and
    • When you have objected to the processing of your data carried out for the performance of a task in the public interest or for the satisfaction of a legitimate interest while it is verified whether the legitimate grounds for the processing prevail over yours.

  • Right of erasure. You can request the deletion of your data when the processing is no longer necessary.

  • Right to object. You can request that we do not process your personal data (e.g., to stop sending commercial communications about the entity's products) and not to be subject to decisions based solely on automated processing. You can also request the cessation of processing based on the legitimate interest of ABANCA Seguros Generales, in which case we will stop processing your data, unless we demonstrate compelling legitimate grounds for the processing that may prevail over your rights, or for the establishment, exercise, or defense of claims.

  • Right to withdraw consent given at any time.

  • Right to lodge a complaint with the supervisory authority (in Spain, the Spanish Data Protection Agency: https://www.aepd.es/).

To exercise any of these rights, you must contact our Customer Service through the email address dpo.abancagenerales@abancaseguros.com.

We will process your request as soon as possible and, in any case, within the legal period of one month from receipt of your request. This period may be extended by another two months if necessary, taking into account the complexity and number of requests. In this case, you will be informed of the extension within the first month from receipt of the request, indicating the reasons for the delay.