ABANCA

1. Who is responsible for processing your data?

ABANCA GENERALES DE SEGUROS Y REASEGUROS, S.A., with NIF A-14715270 (hereinafter, “ABANCA Seguros Generales”).

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

2.1 Sources of your data:

Your personal data processed by ABANCA Seguros Generales may come from yourself, be generated by ABANCA Seguros Generales, or originate from external sources: i) data provided by you; ii) data provided by ABANCA Corporación Bancaria, S.A.; iii) 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; iv) entities responsible for managing contingencies covered in the insurance contract you have with ABANCA Seguros Generales; v) companies within the ABANCA Corporación Bancaria, S.A. Economic Group; vi) common files in the insurance sector (e.g., risk selection and pricing files and files for the preparation of technical and statistical-actuarial studies); vii) publicly accessible sources (e.g., public registries, promotional census, official journals and bulletins, or open social networks); and viii) files containing information on asset solvency and credit (e.g., ASNEF).

If you provide data of third parties, especially health data, you guarantee that you have the express consent of those third parties to communicate their data to ABANCA Seguros Generales. 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 their data.

2.2. Categories of personal data:

The data we process correspond to the following categories, in relation to the Policyholder and, where applicable, the Insured: i) identification and contact data; ii) data related to voice and image; iii) signature data (handwritten and, where applicable, digitized) and data relating to identification codes or keys; iv) data on contracted insurance policies; v) special categories of data (e.g., health data of the insured necessary for the formalization and management of the insurance, as well as for the processing and management of claims); vi) data on claims; vii) personal data of third parties covered by the policy (e.g., members of the family unit); viii) data on personal, family, and social circumstances; ix) sociodemographic data; x) economic and asset solvency data; xi) data inferred or deduced from the analysis and processing of the other categories of personal data; xii) biometric data; xiii) geographic location data; xiv) data on persons subject to international sanctions and financial countermeasures.

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

Below, we inform you about the different processing activities of your personal data for which ABANCA Seguros Generales is responsible, specifying the respective legal bases and purposes for each:

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

In order to execute the contractual or pre-contractual relationships you establish with ABANCA Seguros Generales and, therefore, to provide you with the products and services that are the subject of those relationships, we will carry out the following processing: i) we will process your data (and, where applicable, those of the insured) for the formalization, maintenance, and fulfillment of your contractual or pre-contractual relationships with ABANCA Seguros Generales (this includes receiving information or contracting requests you have made regarding our insurance products or services; carrying out risk analysis and assessment using actuarial and statistical techniques to, if applicable, proceed with the requested operation by signing the corresponding contract; maintaining, developing, and controlling your insurance relationships with ABANCA Seguros Generales; sending you non-commercial communications strictly related to the products and services you have contracted; with prior notice, recording telephone conversations you have with us; analyzing and managing situations of non-payment that may arise; or managing 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 established with ABANCA Seguros Generales); ii) the processing of the insured's health data necessary for the execution of the contract, both prior to the establishment of the contractual relationship and during its development and execution, is based on the express consent you provide by signing and accepting this document and the authorization request offered by ABANCA Seguros Generales.

3.2 Processing carried out to comply with legal obligations.

To comply with the legal obligations applicable to us in each case, we may process your data for the following purposes: i) to respond, if applicable, to information requests made by public administrations and bodies and competent courts and tribunals; ii) to consult lists of persons and entities subject to international sanctions and financial countermeasures (e.g., the Specially Designated Nationals and Blocked Persons List of 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; and iii) to consult and enrich common files in the insurance sector for the preparation of technical and statistical-actuarial studies. This data may be shared with the Insurance Compensation Consortium and with private entities for reasons of reinsurance, coinsurance, or policy management.

3.3 Processing carried out for the legitimate interest of ABANCA Seguros Generales.

We process your personal data, except those classified as sensitive (health, etc.), 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 prevail over those legitimate interests, for the following purposes: i) to prevent fraud in contracting and during the provision or execution of our products and services that could result in harm to you, third parties, and/or ABANCA Seguros Generales; ii) to 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) and risk profiles in insurance for commercial purposes (which allows us to assess, based on your particular situation, the potential insurable risks you may incur) in order to offer you advertising information tailored to these profiles, about our products and services similar to those you have contracted; iii) to consult data relating to your non-compliance with monetary, financial, or credit obligations that appear in common credit information systems, such as the ASNEF file; iv) to offer you advertising information about products and services similar to those contracted; v) to conduct satisfaction surveys regarding our contracted products and services; and vi) to anonymize your personal data for the preparation of statistical and historical studies that allow us to recognize and analyze common behavioral factors and patterns in order to develop studies on the evolution of the product portfolio and the identification of possible predictive models or retrospective studies that contribute to more efficient business management. At any time, you may exercise your right to object to the sending of such advertising information, as well as to the processing of your data for the creation of the profile mentioned in section ii), by contacting dpo.abancagenerales@abancaseguros.com.

3.4 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:

3.4.1 To offer you advertising information tailored to your profile about products and services of companies within the ABANCA Corporación Bancaria, S.A. 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 or push messages—, email, social networks, and WhatsApp messages or through the App), information tailored to your commercial and risk profiles in insurance (i.e., adapted to your interests, needs, and preferences) about products and services of other companies within the ABANCA Corporación Bancaria, S.A. Economic Group (hereinafter, “ABANCA Economic Group”), as well as third-party partners of ABANCA Seguros Generales (companies with which ABANCA Seguros Generales maintains commercial collaboration agreements).

3.4.2 To transfer your data to companies within the ABANCA Economic Group to facilitate their contracting processes with you.

We will share your personal data with companies within the ABANCA Economic Group in order to facilitate and expedite the analysis and possible formalization of a contract or pre-contract you have requested from the relevant company within the ABANCA Economic Group 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 company within the ABANCA Economic Group recipient of the data.

3.4.3 To transfer your data to companies within 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 companies within the ABANCA Economic Group so that these companies can create or update your commercial profile and your insurance risk profile or, where applicable, your credit risk profile, and, using these profiles, prepare and offer you advertising information tailored to them (i.e., 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).

3.4.4 Creation of your commercial profile and your insurance risk profile for the purpose of contracting insurance and for commercial purposes using external sources.

We may enrich the information we already have about you from our internal sources (i.e., information provided by you or generated by ABANCA Seguros Generales in connection with the management of the products and services you have contracted with ABANCA Seguros Generales), with other data about you provided by various external sources, such as public registries (e.g., the Property Registry, the Commercial Registry, the INE, and the Cadastre); publicly accessible sources (e.g., public lists of persons associated with professional associations, official journals and bulletins, media, and open social networks); companies within the ABANCA Economic Group that you have authorized to transfer your personal data to us for the creation by us of your commercial profile and your insurance risk profile; 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; as well as common files in the insurance sector (e.g., risk selection and pricing files and files for the preparation of technical and statistical-actuarial studies) and credit files (e.g., ASNEF). All this for the purpose of creating a more complete and in-depth commercial profile and insurance risk profile for you than those created with internal sources, as well as to complete the contracting of your insurance with a more accurate risk profile, which will allow us to more precisely personalize the offers we send you regarding our products and services, including the preparation of a personalized rate or price based on your profile.

3.4.5 To 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.

3.4.6 To 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 through the app), advertising information tailored to your commercial and insurance risk profiles (i.e., adapted to your interests, needs, and preferences) about products and services of ABANCA Seguros Generales.

3.4.7 To 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 companies within 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 app), information tailored to your commercial and insurance risk profiles (i.e., adapted to your interests, needs, and preferences) about products and services of companies within the ABANCA Economic Group and third-party partners of ABANCA Seguros Generales (companies with which ABANCA Seguros Generales 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 section provided for this purpose in this document.

4. With whom do we share your data?

The 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) to common files in the insurance sector for the preparation of technical and statistical-actuarial studies; ii) to entities managing common credit information systems; iii) to the Institute of Accounting and Auditing; iv) to the Insurance Compensation Consortium; v) to private entities for reasons of reinsurance, coinsurance, or policy management; vi) to entities responsible for managing contingencies and services covered in the insurance contract you have with ABANCA Seguros Generales; vii) to companies within the ABANCA Economic Group and partner companies; viii) to insurance intermediaries; ix) to service providers; x) to national and European Union supervisory authorities (such as, for example, the Directorate General of Insurance and Pension Funds); xi) competent authorities in the field of anti-money laundering and terrorist financing; xii) to the Spanish Union of Insurance and Reinsurance Companies (UNESPA); xiii) to common solvency files relating to the fulfillment and non-fulfillment of monetary obligations (e.g., ASNEF); xiv) to the State Tax Administration Agency; xv) to Judges and Courts; and xvi) to entities within the ABANCA Seguros Generales group and providers in order to comply with regulations on international sanctions and to consult lists of persons and entities subject to international sanctions and financial countermeasures.

In certain cases, data is transferred to entities outside the European Economic Area (EEA). You can consult additional information about these International Data Transfers by visiting the website indicated below, in the section “Where can you consult detailed Data Protection information?”

5. What are your rights?

You may exercise your rights of access, rectification, erasure, restriction, objection, and portability of your personal data, as well as the right 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 Data Protection information found in the privacy policy of ABANCA Seguros Generales, accessible at https://www.abanca.com/regimen-datos-decesos-primaperiodica, or via email at dpo.abancagenerales@abancaseguros.com.

6. Where can you consult detailed Data Protection information?

You can consult additional and detailed Data Protection information in the Privacy Policy of ABANCA Seguros Generales, accessible at https://www.abanca.com/regimen-datos-decesos-primaperiodica. The Privacy Policy also details, for each processing activity 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 based on the corresponding legal basis.