ABANCA

1. Who is responsible for data processing?

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: The personal data processed by ABANCA Seguros Generales may come from you, 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. during the insurance contracting processes you carry out through its distribution network; iii) data generated about you derived from the management, development, and maintenance of the contractual or pre-contractual relationships you have with ABANCA Seguros Generales; iv) entities responsible for managing the 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 rating files and files for the preparation of technical and statistical-actuarial studies); vii) publicly accessible sources (e.g., 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 in the case of health data, you guarantee that you have the express and explicit 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 such data, processing which is included here in this Basic Information on Personal Data Protection.

2.2. Categories of personal data: The data we process fall into the following categories: i) identification and contact data; ii) data related to your voice; 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 insured persons necessary for the formalization and management of health 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) personal, family, and social circumstances data; ix) sociodemographic data; x) academic and professional data; xi) employment data; xii) commercial activity data; xiii) economic and asset solvency data; xiv) financial data; xv) transactional data; xvi) data inferred or deduced from the analysis and processing of the other categories of personal data; xvii) biometric data (not belonging to special categories of data); xviii) geographic location data; xix) 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 of your personal data for which ABANCA Seguros Generales is responsible, specifying the respective legal bases that legitimize them and the purposes of 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 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; consulting data relating to your non-compliance with monetary, financial, or credit obligations that appear in common credit information systems, such as the ASNEF file; 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); ii) the necessary processing of your health data, to determine the healthcare that must be provided to you under the coverage included in the contract, as well as for the proper payment to healthcare providers or reimbursement to the insured or beneficiary of healthcare expenses, all in execution of the Insurance Contract and in accordance with the specific insurance regulations, more specifically Law/2015, of July 14, on the regulation, supervision, and solvency of insurance and reinsurance entities; iii) additionally, and for the rest of the processing of your 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 will provide through the signing and acceptance of the corresponding documents and authorization requests 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 appropriate, to information requests made by public administrations and bodies and competent judges and courts; 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 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, 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 offer you advertising information about products and services similar to those contracted; iv) to conduct satisfaction surveys of our contracted products and services; and v) 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 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 profiles mentioned in section ii) or for the surveys mentioned in section iv), by contacting the email address dpo.abancagenerales@abancaseguros.com.

3.4. Processing carried out with your consent.

Exclusively in the event that we have requested and obtained your prior consent for this purpose, we may 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 our apps), information tailored to your commercial and risk profiles in insurance (i.e., adapted to your interests, needs, and preferences) about products and services of 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 risk profile in insurance 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 risk profile in insurance for the purpose of contracting insurance and for commercial purposes using external sources. We will enrich the information about you that we already have 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 records (e.g., Land Registry, Commercial Registry, INE, and Cadastre); publicly accessible sources (e.g., public lists of persons associated with professional associations, official journals and bulletins, social media, and open social networks); companies within the ABANCA Economic Group to which you have authorized to transfer your personal data to us for the creation by us of your commercial profile and your risk profile in insurance; 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 rating files and files for the preparation of technical and statistical-actuarial studies) and asset solvency and credit files (e.g., ASNEF). All this with the purpose of creating a more complete and in-depth commercial profile and risk profile in insurance for commercial purposes than those created with internal sources, as well as to complete your insurance contracting with a more accurate risk profile, which will allow us to more accurately 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, WhatsApp, or our apps), advertising information tailored to your commercial and risk profiles in insurance (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, WhatsApp, or our apps), information tailored to your commercial and risk profiles in insurance (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).

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 the contingencies and services covered in the insurance contract you have with ABANCA Seguros Generales; viii) to companies within 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) to competent authorities in the field of anti-money laundering and terrorist financing; viii) to common solvency files relating to the fulfillment and non-fulfillment of monetary obligations (e.g., ASNEF); ix) to the State Tax Administration Agency; x) to Judges and Courts; and xi) to entities within 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.

5. What are your rights?

You may exercise your rights of access, rectification, erasure, restriction, objection, and portability of your personal data by contacting the Data Protection Officer 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, accessible on the website www.abanca.com, within the “Legal and Security Aspects” section, located at the bottom of said website, 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, accessible on the website www.abanca.com, within the “Legal and Security Aspects” section, located at the bottom of said website (www.abanca.com/privacidad-salud/). 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 the profiling that may be carried out on your personal data according to the corresponding legal basis.