Notice on the processing of personal data

The company Global Assistance Services SRL, with headquarters in Bucharest, No. 23 Grigore Mora, 1st Floor, district 1, registered at the Trade Register under no. J40/13401/2017, Tax Identification Number 38020781, processes personal data in order to provide services related to acknowledgment and support for the settlement of certain claim trials filed under insurance policies and in compliance with the legal provisions governing the insurance activity, as well as those relating to the processing of personal data and the free movement of such data.

You can contact the data protection officer appointed by Global Assistance Services SRL by email at dpo@globalassist.ro. You can also access up-to-date information on the data protection policy, as well as additional details regarding the processing of personal data and your rights in connection with such processing, on Global Assistance Services’ website (www.globalassist.ro).

Personal data categories that may be processed by Global Assistance Services in its activity of providing services related to insurance claims:

Personal identification data (surname, first name, address, age, date of birth, sex, telephone, e-mail, Personal Identification Number, home address, correspondence address, handwritten signature, biometric signature). The data are necessary for the provision of services related to insurance claims.

Personal health data (data on physical and mental health or medical conditions stated in medical questionnaires, medical data collected from health care providers for the settlement of services accessed by the insured, medical data collected during the compensation process in case of an insured event). The data are collected in the case of damages related to personal insurance policies (life, health, accidents, medical assistance). They are necessary for determining the amount of the compensation, accessing the insured medical services and their reimbursement.

Data on assets held (data on the vehicle, real estate or insured property owned by an insured natural person, which is the object of the insurance). The data are required in the case of damages related to civil liability insurance for vehicles, CASCO, goods insurance products.

Information regarding the location, image and audio-video recordings of natural persons (video recordings captured by surveillance cameras installed at the headquarters of Global Assistance Services, audio recordings of telephone calls from the call center, IP address captured when using the website). The data is necessary to ensure security and protection in the locations of Global Assistance Services, to improve the services provided, to solve complaints and any requests from customers, as well as to ensure the technical functionality of the online platforms used by Global Assistance Services.

The purpose and legal basis under which Global Assistance Services may process your personal data is:

• settlement of damages.
• internal reporting or reporting to other entities of the group to which Global Assistance Services belongs
• solving complaints and requests from customers
• settlement of potential disputes, submitted to the courts (common law or arbitration, in the country or abroad)
• communications or reporting to the competent state or governmental authorities, institutions or agencies
• ensuring the necessary security measures (audio-video surveillance)

The collection and processing of your data for the purposes mentioned above are based on:

• Fulfilling the contractual obligations
• fulfilling the legal obligations of Global Assistance Services
• the legitimate interest of Global Assistance Services in activities such as: performing statistical analyses and internal reports or reporting to other entities of the group to which Global Assistance Services belongs, verifying the integrity and compliance of data subjects, preventing fraud and unjustified payments related to damage claims, ensuring the necessary security measures, etc.
• your consent

Categories of recipients to whom the personal data collected may be transmitted:

• state authorities (including tax authorities, consumer protection authorities, as well as those in the field of insurance, competent state bodies in criminal matters), as a result of a legal obligation of Global Assistance Services
• providers directly/indirectly involved in the claim settlement trial (e.g. reinsurers, IT services developers, claim agents, insurance call center and assistance providers, partner medical clinics and partner car services, other operators that provide repair services, etc.)
• intermediaries involved in managing your insurance agreements (e.g. brokers, insurance agents – natural persons or authorized legal persons, etc.)
• other companies within the VIG Group (national and/or international)
• law courts or arbitration courts, notaries public, lawyers, bailiffs, translation offices, other authorized services, expert evaluators, as the case may be.

Transfer of personal data to a country outside the European Economic Area

Global Assistance Services may transfer personal data to other companies outside or within the VIG Group, located outside the European Economic Area. For such transfers, Global Assistance Services has taken a number of measures to ensure an adequate level of protection of natural persons, similar to that provided by the European law.

Storage of personal data

Personal data will be processed for at least the duration of the validity of the insurance agreement, as well as subsequently, for the time necessary for the execution of the contractual obligations by either party. The personal data will be stored for as long as necessary for the purposes mentioned above or for the period of time provided by the general legal provisions, as well as those applicable to insurance, in accordance with the Archival Nomenclature applicable to Global Assistance Services. If you agree to the processing of this data for marketing purposes, the personal data collected will be kept until you notify us of the withdrawal of your consent for this purpose.

The rights you have regarding your personal data

You may exercise any of the following rights in connection with the processing of personal data under the conditions specified in the European Data Protection Regulation 679/2016:

The right of access to personal data

It allows you to obtain a confirmation from us stating whether or not Global Assistance Services processes personal data about you and the kind of data that is processed. If the personal data concerning you is not collected from you, we may provide you with any available information on their source unless there is a legal prohibition on the disclosure of the source.

The right to rectification
It implies the right to request the rectification or updating of inaccurate or incomplete personal data concerning you or their completion, when they are incomplete.

The right to delete data or the “right to be forgotten” implies the right to request the deletion of personal data concerning you, in certain circumstances, such as:

(i) the personal data are no longer necessary for the purposes for which they have been collected or processed,
(ii) your data has been processed illegally,
(iii) the data processing has been carried out based on your consent, and it has been withdrawn.

The right to withdraw your consent

Your consent may be withdrawn at any time when the processing of personal data concerning you has been carried out based on your consent. If you withdraw your consent to the processing of health data, the insurance agreement that requires the processing of such data will become ineffective.

The right to restrict processing

It implies the right to request and obtain a restriction on the processing of personal data concerning you, in certain circumstances, such as:
(i) you dispute the accuracy of the data, for the period that would allow us to verify the accuracy of such data,
(ii) your data has been processed illegally, and you object to their deletion, requesting a restriction on their use.

The right to data portability

It implies the right to receive the personal data concerning you and which you have provided to us, with the right to transmit them to another Controller, if the data processing was carried out either based on your consent or on the agreement concluded with us, and the processing of the personal data was performed automatically. This right may be exercised only to the extent that the processing of the data provided has been carried out exclusively automatically and only where the extraction of such data is feasible in terms of the technical capabilities used by Global Assistance Services.

The right to opposition

It implies that, at any time, you have the right to object, for reasons related to your particular situation, to the processing of personal data in certain circumstances, such as:
(i) the processing has been carried out in our legitimate interest or
(ii) the purpose of the processing is direct marketing, including the creation of profiles based on those provisions.
The right not to be subject to a decision based solely on the automatic processing of your data, including the creation of profiles that produce legal effects or significantly affect you
It implies that you have the right to request human intervention from Global Assistance Services, to express your point of view and to dispute the decision.
The right to file a complaint to Global Assistance Services and/or the competent data protection authority
The right to go to court
To exercise your rights or to obtain additional information on the processing of personal data, you can contact the Personal Data Protection Officer of Global Assistance Services:
• by e-mail to dpo@globalassist.ro.
• by post to: Global Assistance Services, No. 2 Sagetii Street, District 3, Bucharest.
• personally submitting a handwritten signed notification to the headquarters of Global Assistance Services
For submitting a notification/complaint to the National Supervisory Authority for the Processing of Personal Data, the contact details are: Website: http://www.dataprotection.ro/; E-mail: anspdcp@dataprotection.ro; Address: No. 28-30 Blvd G-ral. Gheorghe Magheru, District 1, postal code 010336, Bucharest, Romania; Landline: +40.318.059.211, +40.318.059.212