ABANCA

Who is the data controller?

The data controller is ABANCA GENERALES DE SEGUROS Y REASEGUROS, S.A., with registered office at Avda. Linares Rivas, 30, 3rd floor, 15005 A Coruña and CIF A-14715270 (“ABANCA Seguros Generales”), which has appointed a Data Protection Officer who can be contacted at the following email address: dpo.abancagenerales@abancaseguros.com.

Where do your data come from?

ABANCA Seguros Generales has obtained your personal data from one of the following sources:

• Provided in the application submitted, for the establishment of the contractual relationship or those generated as a result of its development.
• Companies belonging to the Economic Group of ABANCA Corporación Bancaria, S.A. (hereinafter, “ABANCA Group companies”), whose business sectors include finance, social, insurance, real estate, securities investment, training, marketing, and consulting and advisory services.
• From publicly accessible sources (e.g., promotional census, official journals and bulletins…), common files (e.g., for risk selection and pricing, preparation of technical and statistical-actuarial studies, on asset solvency and credit files, identity and fraud prevention or other sector files, etc.), public registers (e.g., land registry, Commercial Registry, etc.) or other external sources (social networks, companies offering data enrichment services, connectivity, cookies, entities responsible for managing contingencies covered by the insurance contract you have with ABANCA Seguros Generales, etc.), provided that your consent has been obtained or another legal basis is available.

If you provide data of third parties, especially in the case of health data, you guarantee that you have the express consent of the third parties so that ABANCA Seguros Generales can process their data. Likewise, you 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 described here.

What data do we process?

The data we process correspond to the following categories:

i) Identification and contact data; ii) Data related to your voice and image; iii) Signature data (handwritten and digitized) and data relating to identification codes or keys; iv) Data on insurance policies contracted with ABANCA Seguros Generales and claims processed; v) Personal, family, and social circumstances data; vi) Socioeconomic data; vii) Economic and asset solvency data; viii) Financial data; ix) Transactional data; x) Data inferred or deduced from the analysis and processing of the other categories of personal data; xi) Data on persons subject to international sanctions and financial countermeasures; xii) Personal data of third parties covered by this policy (e.g., family members or employees) as well as third parties interested in the processing and management of claims arising from the execution of the insurance (interested parties, injured parties, beneficiaries, etc.), provided that such processing is strictly necessary.

Additionally, you are informed that, if necessary, ABANCA Seguros Generales may process personal data relating to your health, exclusively for the purpose of managing, developing, and executing legally required benefits, for example, the management of a claim.

Finally, we inform you that this section lists all categories of personal data that could potentially be processed depending on the situation of each data subject. However, this does not mean that all data included in each category will always be used in such processing. In fact, and in accordance with the legal principle of data minimization, such personal data will only be used to the extent that, depending on the circumstances of each specific case, they are adequate and relevant to fulfill the purpose assigned in this Privacy Policy to the corresponding processing.

For what purposes do we process personal data and on 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:

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

1.1 Formalization, maintenance, and fulfillment of relationships with ABANCA Seguros Generales

This purpose includes all activities aimed at processing your application, its formalization, insurance and claims management, handling pre-contractual and contractual claims and incidents, quality management, and payment and collection management.

In case of non-payment, ABANCA Seguros Generales may communicate your data to debt recovery service providers, acting on behalf of ABANCA Seguros Generales, to carry out collection actions and, likewise, communicate your data and debt information to credit information systems (e.g., ASNEF or BADEXCUG).

1.2 Calculation of the premium and analysis and assessment of the insured risk in the formalization, maintenance, fulfillment, and renewal of relationships with ABANCA Seguros Generales

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 consistent with the characteristics of the insured and beneficiaries, the environment, and the historical data of ABANCA Generales de Seguros.

In the development of this purpose, in addition to analyzing the information requested during contracting or—upon renewal—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 available 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 the estimation of risk level and premium, as provided by insurance regulations, or for compliance with contracting requirements. For example, ABANCA Generales de Seguros may check the vehicle’s MOT status or information about its characteristics.

2. Processing carried out to comply with legal obligations.

The insurance sector, of which ABANCA Seguros Generales is a part, is highly regulated, which means we must process your data to comply with the legal obligations applicable in each case, such as responding to possible information requests from administrations, public bodies, and courts or tribunals; and consulting lists of persons and entities subject to international sanctions and financial countermeasures (e.g.: Specially Designated Nationals and Blocked Persons List in 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. Processing carried out for the legitimate interest of ABANCA Seguros Generales.

We process your personal data based on the satisfaction of the legitimate interests pursued by ABANCA Seguros Generales, and to the extent that your own interests or fundamental rights and freedoms do not override those legitimate interests, for the following purposes: i) Detect and prevent fraud in contracting and in the provision or execution of our products and services (e.g., during claims management) that could result in harm to you, third parties, and/or ABANCA Seguros Generales; ii) create, using only data from our internal sources, commercial profiles (which allows us to analyze and predict your personal preferences, economic situation, interests, geographic location, and behavior) to offer you advertising information tailored to these profiles, about our products and services similar to those you have contracted; iv) offer you advertising information about products and services similar to those contracted; v) send surveys to assess your satisfaction level and the quality of the product or service you have contracted or our service; vi) data analysis to improve internal processes and/or our products and services.

At any time, you may exercise your right to object to the sending of commercial communications, surveys, and/or the creation of the profile mentioned in section iii), by contacting the Customer Service at dpo.abancagenerales@abancaseguros.com. Likewise, at this address you may request additional information about the analysis carried out to evaluate the development of all purposes based on legitimate interest.

4. Processing carried out with your consent.

Only if we have requested and obtained your prior consent for this purpose, may we carry out the following processing of your personal data:

4.1. Offer you advertising information tailored to your profile about products and services of other companies in the ABANCA Economic Group 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—SMS, push messages, or other messaging services such as WhatsApp—, email, social networks, or our remote banking services), information tailored to your commercial and credit risk profiles (i.e., adapted to your interests, needs, preferences, savings capacity, and creditworthiness) about products and services of other companies in the ABANCA Economic Group, as well as third-party partners of ABANCA Seguros Generales.

4.2. Transfer your data to other companies in the ABANCA Economic Group to facilitate their contracting processes with you. We will share your personal data with other companies in the ABANCA Economic Group in order to facilitate and expedite the analysis (including credit risk analysis in the case of financing operations) and the possible formalization of a contract or pre-contract you have requested from the relevant ABANCA Economic Group company recipient of the data; or to facilitate and expedite the management and execution of a contract or pre-contract you already have with the relevant ABANCA Economic Group company recipient of the data.

4.3. Transfer your data to partners of ABANCA Seguros Generales to facilitate their contracting processes with you. We will share your personal data with partners of ABANCA Seguros Generales in order to facilitate and expedite the analysis (including the risk to be insured in the case of insurance operations or credit risk in the case of financing operations) and the possible formalization of a contract or pre-contract you have requested from the relevant partner recipient of the data; or to facilitate and expedite the management and execution of a contract or pre-contract you already have with the relevant partner recipient of the data.

4.4. Transfer your data to other companies in the ABANCA Economic Group so that they can offer you advertising information tailored to your profile about their products and services. We will share your personal data with other companies in the ABANCA Economic Group so that these companies can create or update your commercial profile and your credit risk profile and, using these profiles, prepare, to offer you, advertising information tailored to them (i.e., adapted to your interests, needs, preferences, savings capacity, and creditworthiness) 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).

4.5. Transfer your data to partners of ABANCA Seguros Generales so that they can offer you advertising information tailored to your profile about their products and services. We will share your personal data with partners of ABANCA Seguros Generales 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, prepare, to offer you, information tailored to them (i.e., adapted to your interests, needs, preferences…) 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).

4.6. Voluntary improvements in the insurance premium calculation process and creation of your commercial profile for commercial purposes using external sources. We will enrich the information about you that we already have through our internal sources (i.e., the information you have provided or generated at ABANCA Seguros Generales as a result of managing the products and services you have contracted with ABANCA Seguros Generales), with other data about you provided by various external sources, such as public registers (e.g., Land Registry, Commercial Registry, and Cadastre); publicly accessible sources (e.g., public lists of people associated with professional associations, official journals and bulletins—for example, to check for previous fines and adjust the policy to the driver's characteristics—, social media and open social networks); ABANCA Economic Group companies you have authorized to transfer your personal data to us (e.g., scoring); geomarketing tools and databases; browsing data on third-party websites or applications, if you have accepted the use of cookies and other similar technologies on the relevant browsing devices. All this with the aim of having relevant information when calculating the premium amount and creating a more complete and in-depth commercial profile for you for commercial purposes than those created with internal sources, which will allow us to more accurately personalize the offers we send you regarding our products and services.

4.7. Maintain the processing of your personal data once our relationship has ended for the management of a new request. We will retain your personal data once our relationship with you has ended, and for a maximum period of 5 years, to manage new requests for products or services you may submit to us.

4.8. Maintain the processing of your personal data once our relationship has ended to continue sending you advertising information tailored to your profile about products and services of ABANCA Seguros Generales. We will retain your personal data once our relationship with you has ended, and for a maximum period of 5 years, to continue sending 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 remote banking services), advertising information tailored to your commercial and risk profiles (i.e., adapted to your interests, needs, preferences…) about ABANCA’s own products and services.

4.9. Maintain the processing of your personal data once our relationship has ended to continue sending you advertising information tailored to your profile about products and services of other companies in the ABANCA Economic Group and partners. We will retain your personal data once our relationship with you has ended, and for a maximum period of 5 years, to continue sending 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 remote banking services), information tailored to your commercial and credit risk profiles (i.e., adapted to your interests, needs, preferences…) about products and services of other companies in the ABANCA Economic Group and third-party partners of ABANCA (companies with which ABANCA maintains commercial collaboration agreements).

To record the corresponding consents you may have given us, to which ABANCA Seguros Generales will adhere until they are revoked, such consents are indicated in the box provided for this purpose in the Particular Conditions of the Policy. Likewise, at any time, you may request additional information at dpo.abancagenerales@abancaseguros.com.

With whom do we share your personal data?

Processing, to fulfill the purposes detailed above according to the specified legal basis for each purpose, may involve your personal data being communicated to third parties, such as: i) Financial entities; ii) Common files of the insurance sector and public registers; iii) Public bodies, such as the Institute of Accounting and Auditing or the Insurance Compensation Consortium; iv) Private reinsurance or coinsurance entities; v) Entities responsible for managing contingencies and services; vi) Insurance intermediaries and co-insurers; vii) National and European Union supervisory authorities; viii) Companies of the ABANCA Seguros Generales business group for internal administrative purposes, detection of anomalous activities (fraud prevention), and compliance with legal obligations and internal regulations on international sanctions and consultation of lists of persons and entities subject to international sanctions and financial countermeasures; ix) ABANCA Economic Group companies 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; x) Service providers and external professionals (lawyers, solicitors, auditors, notaries and public officials, private detectives or investigators…); xi) Directorate General of Insurance and Pension Funds and European supervisory bodies; xii) Entities managing credit information systems or also known as files on non-fulfillment of 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 notification indicating your rights; xiii) AEAT and other competent tax administrations, in compliance with applicable tax regulations; xiv) State Security Forces and Corps; xv) Judges and Courts, within the scope of judicial proceedings for which they are respectively competent or in compliance with applicable regulations; xvi) Customer Ombudsman. In particular, ABANCA Seguros Generales will communicate the historical data of policies and claims to the Historical Insurance Information System for Motor Vehicles, for which it is jointly responsible for processing. Its purpose is to provide, at the time of contract subscription, rigorous and verified information on claims data by sharing information obtained through policies and claims from the last five years, as stated in the Law on Civil Liability and Insurance in the Circulation of Motor Vehicles.

ABANCA Seguros Generales will also communicate the historical data on the number of claims related to your insurance or claims in which you have been involved to the Total Loss, Theft, and Fire Information System, for which it is jointly responsible for processing. Its purpose is to facilitate the automated identification of possible anomalous situations and risk of fraud, cooperate with the Security Forces and Corps by facilitating the investigation of possible crimes of theft and fraud, among others, related to insured motor vehicles; and cooperate with CENTRO ZARAGOZA, the Security Forces and Corps, the Directorate General of Traffic, and the affected insurance company in the identification and location of stolen and compensated vehicles.

To exercise data protection rights regarding these last two communications, you can contact TIREA, Ctra. Las Rozas a El Escorial Km 0.3 Las Rozas 28231 MADRID. You can find the rest of the data protection information on the UNESPA (www.unespa.es) and TIREA (www.tirea.es) websites.

We also inform you that certain companies providing services to ABANCA Seguros Generales are located outside the European Union, which involves International Data Transfers. In this regard, ABANCA guarantees the application of technical, organizational, and legal security measures appropriate to the level of risk of the processing, regardless of the territory where it takes place.

What are your rights?

You may exercise your rights of access, rectification, erasure, restriction, objection, and portability of your personal data, as well as not to be subject to decisions based solely on automated processing. You may also withdraw your consent at any time by contacting the DPO of ABANCA Seguros Generales through the channels referred to in the additional and detailed information on Data Protection found in the privacy policy of ABANCA Seguros Generales available at www.abanca.com/es/legal/politica-privacidad-abanca-seguros/coche/informacion-adicional/ or via the email address dpo.abancagenerales@abancaseguros.com

Where can you consult detailed Data Protection information?

You can consult additional and detailed information on Data Protection in the Privacy Policy of ABANCA Seguros Generales available at www.abanca.com/es/legal/politica-privacidad-abanca-seguros/coche/informacion-adicional/. The Privacy Policy also details, for each processing carried out by ABANCA Seguros Generales, the specific categories of data used in each of these processing activities, and includes an explanation of the logic applied to profiling that may be carried out on your personal data depending on the corresponding legal basis.