Basic information on personal data protection
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?
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 belonging to the Economic Group of ABANCA Corporación Bancaria, S.A.; vi) common files of the insurance sector (e.g., risk selection and rating files and files for the preparation of technical and statistical-actuarial studies); vii) publicly accessible sources (e.g., public registers, 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 such third parties to communicate their data to ABANCA Seguros Generales. 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 their data.
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) data on claims that have occurred; vi) personal data of third parties covered by the policy; vii) data on personal, family, and social circumstances; viii) sociodemographic data; ix) data inferred or deduced from the analysis and processing of the other categories of personal data; x) biometric data; xi) geographic location data; xii) data on persons subject to international sanctions and financial countermeasures.
3. For what purposes 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 that legitimize them and the purposes of each:
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 process your data (and, where applicable, those relating to 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, where appropriate, 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, where applicable, are associated with or applicable to the contractual relationship established with ABANCA Seguros Generales).
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 appropriate, 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.: list of specially designated nationals and blocked persons in the United States 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 of 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.
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, to third parties, and/or to 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, for example, the ASNEF file; iv) to offer you advertising information about products and services similar to those contracted; v) to conduct satisfaction surveys of 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 factors and behavioral patterns in order to prepare 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 preparation of the profile mentioned in section ii), by contacting the email address dpo.abancagenerales@abancaseguros.com.
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:
- To offer you advertising information tailored to your profile about products and services of companies belonging to the Economic Group of ABANCA Corporación Bancaria, S.A. 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 insurance risk profiles (i.e., adapted to your interests, needs, and preferences) about products and services of other companies in the Economic Group of ABANCA Corporación Bancaria, S.A. (hereinafter, “Economic Group of ABANCA”), as well as third-party partners of ABANCA Seguros Generales (companies with which ABANCA Seguros Generales maintains commercial collaboration agreements).
- To transfer your data to companies in the Economic Group of ABANCA to facilitate their contracting processes with you. We will share your personal data with companies in the Economic Group of ABANCA in order to facilitate and expedite the analysis and possible formalization of a contract or pre-contract that you have requested from the corresponding company in the Economic Group of ABANCA 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 company in the Economic Group of ABANCA recipient of the data.
- To transfer your data to companies in the Economic Group of ABANCA 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 in the Economic Group of ABANCA so that such companies can create or update your commercial profile and your insurance risk profile or, where applicable, your credit risk profile, and, using such profiles, can prepare, to 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).
- Preparation of your commercial profile and your insurance risk profile for the purpose of contracting insurance and 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 provided by you 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., the Property Register, the Commercial Register, the INE, and the Cadastre); publicly accessible sources (e.g., public lists of people associated with professional associations, official journals and bulletins, social media, and open social networks); companies in the Economic Group of ABANCA that you have authorized to transfer your personal data to us for the preparation 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 of the insurance sector (e.g., risk selection and rating files and files for the preparation of technical and statistical-actuarial studies) and credit files (e.g., ASNEF). All this with the purpose of preparing a more complete and in-depth commercial profile and insurance risk profile for you than those prepared 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.
- 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 that you may submit to us.
- 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.
- 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 in the Economic Group of ABANCA 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 in the Economic Group of ABANCA and third-party partners of ABANCA Seguros Generales (companies with which ABANCA Seguros Generales maintains commercial collaboration agreements).
For the record of the corresponding consents you may have granted 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 of 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 the contingencies and services covered in the insurance contract you have with ABANCA Seguros Generales; viii) to companies in the ABANCA Economic Group and partner companies; ix) to insurance intermediaries; x) to service providers; xi) to national and European Union supervisory authorities (such as, for example, the Directorate General of Insurance and Pension Funds); xii) competent authorities in the field of anti-money laundering and terrorist financing; xiii) to the Spanish Union of Insurance and Reinsurance Companies (UNESPA); ix) to common solvency files relating to the fulfillment and non-fulfillment of monetary obligations (e.g., ASNEF); x) to the State Tax Administration Agency; xi) to Judges and Courts; and xii) to entities of the ABANCA Seguros Generales group and providers in order to comply with regulations on international sanctions and consultation of lists of persons and entities subject to international sanctions and financial countermeasures.
On certain occasions, 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 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 abanca.com/regimen-datos-decesos-primaunica, or via the email address dpo.abancagenerales@abancaseguros.com.
6. 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 abanca.com/regimen-datos-decesos-primaunica. 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.