WHO WE ARE AND WHAT RULES WE APPLY WHEN PROCESSING PERSONAL DATA

Global Assistance Services SRL, headquartered in Bucharest, 2 Sagetii Street, 3rd floor, Sector 2, registered at the Trade Register under no. J40/13401/2017, Sole Registration Code 38020781, processes personal data in the course of its activities, including for the provision of services related to the assessment and support for the resolution of damage claims opened under insurance policies, upon the instructions of the insurance-reinsurance companies that have contracted us in this respect.

All data processing, both as a personal data controller and as a processor on behalf of other controllers, is carried out in strict compliance with the legal provisions governing the processing of personal data and the free movement of such data (including the General Data Protection Regulation no. 679/2016 – GDPR), as well as with the legal provisions governing insurance activities, labor relations, cybersecurity, the security of objectives, goods, values and the protection of persons, the retention and archiving of documents, and any other legal provisions that may be applicable.

The Data Protection Officer designated by Global Assistance Services SRL can be contacted by you at the email address dpo@globalassist.ro. You can also review information regarding data protection policies, as well as additional details regarding the processing of personal data and your rights in relation to such processing, on the Global Assistance Services website (www.globalassist.ro).

WHAT PERSONAL DATA WE PROCESS

Our policy is to specifically inform the data subjects about the personal data collected and processed in each case where this occurs (e.g., when submitting a request or a response to a request, when concluding a contract, when receiving a CV, etc.).

For example, if you send us a request through the website or directly to the email address asistenta@globalassist.ro, we will collect personal data regarding: the email address and contact details of the person or company representative contacting us, included in the request (e.g., name, surname, email, phone number).

We also process data when you visit our location (e.g., your name) or website (e.g., IP address used to access the site). The data is necessary to ensure the security and protection at Global Assistance Services locations, as well as to ensure and improve the functioning and information provided online by Global Assistance Services.

The categories of personal data that may be processed and the manner of processing by Global Assistance Services while providing services related to insurance claims are strictly determined by the data controllers (insurance-reinsurance companies) for whom we provide these services, and we respectfully urge you to contact them directly for any details.

PURPOSES AND LEGAL BASES FOR PROCESSING PERSONAL DATA

When Global Assistance Services acts as a data controller, the purposes and legal bases for processing personal data may include:

  • Your consent, when it has been explicitly obtained.
  • The fulfillment of contracts to which we are a party and, where applicable, the legal obligations incumbent upon us, according to the legislation in force, for example, in the case of communications or reports that we need to submit to the competent state authorities, institutions, or agencies.
  • The legitimate interest of Global Assistance Services for activities such as: conducting statistical analyses and internal or group reporting, verifying the integrity and compliance assessment of data subjects, fraud prevention, managing potential court cases and pre-litigation phases, deploying necessary security measures, contacting persons we need to interact with for carrying out our activities.

CATEGORIES OF RECIPIENTS TO WHOM COLLECTED PERSONAL DATA MAY BE TRANSMITTED

  • State authorities (including tax authorities, consumer protection authorities, and authorities competent for the insurance industry sector, state bodies in charge with dealing with criminal matters), as a result of a legal obligation of Global Assistance Services.
  • Suppliers directly/indirectly involved in our activity (e.g., IT services providers and developers, damage assessment agents, call-center and insurance assistance providers, partner medical clinics and auto repair shops, other service providers).
  • Other companies within the VIG Group (nationally and/or internationally).
  • Courts or arbitration tribunals, notaries public, lawyers, bailiffs, translation offices, other authorized services providers, expert evaluators, as applicable.

TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

In principle, when acting as a controller we do not transfer personal data outside the EU and EEA. Global Assistance Services may transfer personal data to other companies within or outside the VIG Group, located outside the European Economic Area. Such transfers can only take place if the respective organization or state to which the transfer is to be done can ensure an adequate level of protection according to the requirements of the General Data Protection Regulation. The transfer of data to an international organization or to a state whose legislation does not provide an adequate level of protection, recognized by an adequacy decision issued by the European Commission, is possible only if there are suitable safeguards regarding the protection of the fundamental rights of the data subjects, set forth through contracts/agreements concluded with the suppliers/service providers to whom the data transfer is made or in other legal manners, as applicable.

RETENTION OF PERSONAL DATA

Personal data will be retained as long as necessary for the purposes mentioned above or for the period provided by legal provisions, both general legal framework, as well as rules applicable in the field of insurance, in accordance with the archiving rules applicable within Global Assistance Services.

If you have given your consent for the processing of this data for marketing purposes, the collected personal data will be retained until you notify us of the withdrawal of the consent given for this purpose.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

For the processing of personal data that we undertake as a data controller, you can exercise any of the following rights, as per the conditions specified in the General Data Protection Regulation no. 679/2016:

  • The right to access the personal data: This allows you to obtain from us a confirmation of whether Global Assistance Services processes personal data concerning you and what such data is processed, as well as details about the processing.
  • The right to rectification: This represents 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 erasure or “the right to be forgotten”: This represents the right to request the deletion of personal data concerning you, in certain circumstances. Please note that the current legislation provides for a series of exceptions where the request for data deletion cannot be fulfilled.
  • The right to withdraw consent: Consent can be withdrawn at any time when the processing of personal data concerning you has been carried out based on your consent, resulting in the cessation of processing, without affecting the validity of the processing prior to such withdrawal.
  • The right to restrict processing: This represents the right to request and obtain the restriction of the processing of personal data concerning you, in certain circumstances, such as: when the data subject contests the accuracy of the data, for a period that allows the controller to verify the accuracy of the data; the processing appears to be illegal, and the data subject opposes the deletion of personal data, requesting instead the restriction of their use; when we no longer need the personal data for processing purposes, but they are necessary for the establishment, exercise, or defense of a right in court; the data subject has objected to the processing, for the period needed to verify whether the legitimate rights of the controller prevail over those of the data subject.
  • The right to data portability: This represents the right to receive the personal data concerning you that you have provided to us or to request that it be transmitted to another controller, if the data processing was carried out based on your consent or a contract concluded with us. This right can only be exercised to the extent that the processing of the provided data was carried out by automated means.
  • The right to object: This means 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 is based on our legitimate interest and this does not prevail over the interests, rights, and freedoms of the data subject; or (ii) the processing is for direct marketing purposes.
  • The right not to be subject to a decision based solely on the automated processing of your data, including profiling, which produces legal effects or otherwise significantly affects you: This means that you have the right to request human intervention from Global Assistance Services, to express your point of view, and to contest the decision.
  • The right to lodge a complaint or to file a claim with the courts: You can file a complaint with Global Assistance Services (according to the contact details mentioned below) and/or with the competent data protection authority – the National Supervisory Authority for Personal Data Processing, at the following contact details:

You also have the right to file claims with the competent courts.

To exercise your rights or to obtain additional information on the processing of personal data, you can contact the Data Protection Officer of Global Assistance Services:

  • By email at dpo@globalassist.ro
  • By post at the address: Global Assistance Services, 2 Sagetii Street, 3rd floor, Sector 2, Bucharest
  • By personally submitting a signed notification at the headquarters of Global Assistance Services mentioned above.
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