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Eurocross

PRIVACY POLICY & TERMS OF USE

1. INTRODUCTION  

Eurocross MENA is committed to protecting your privacy and handling your personal data in an open and transparent manner. The personal data that we collect and process will vary depending on the product or service we provide to you.

This Privacy Statement:
-provides an overview of how Eurocross MENA collects and processes your personal data, including sensitive data, and informs you about your rights under the EU General Data Protection Regulation (“GDPR”) and any law supplementing or implementing the GDPR; 
-
 is directed to natural persons who are: (a) current or potential customers of Eurocross MENA; and/or (b) beneficial owners or authorised representatives of legal entities or of natural persons which/who are current or potential customers of Eurocross MENA; and/or (c) assisted persons named under any Eurocross MENA assistance policy; and/or (d) third party claimants;
-
 is directed to natural persons who had a business relationship with Eurocross MENA in the past; and contains important information about what personal data we collect, what we do with such personal data, who we may share it with and why and your rights in relation to the personal data you have given us.

For the purposes of this Personal Data Privacy Statement:

-when we refer to “personal data” we mean data which identifies or may identify you and which may include, for example, your name, address, identification number, telephone number, date of birth, occupation and family status; 

when we refer to “sensitive data” we mean special categories of personal data which identify or may identify you and which may reveal, inter alia, details about your past or current physical or mental health status, including data on any physical or mental disease or disability; and
-
when we refer to “processing” we mean the handling of your personal data by us, including collecting, protecting and storing your personal data.

2.WHO WE ARE

Eurocross MENA is a licensed assistance company, registered in the Republic of Cyprus under registration number HE346187 as a limited liability company having its registered office and head office at 14 Spyrou Kypriano, office 101, Limassol, Cyprus.

We have created this Privacy Policy to let you know what information we (or others on our behalf) collect from you when you use our website and the services contained within (the “Services“), how is this information collected and how is it used.

When you access or use our website, you agree that we (or others on our behalf) may collect, use and disclose your information (including Personal Information) in accordance with the terms of this Privacy Policy.

3. COLLECTION OF INFORMATION & HOW WE COLLECT YOUR PERSONAL DATA

We obtain your personal data mainly through any information you provide directly to us or through information provided by third parties. Below is a list of ways in which we collect your personal data:

a-  Personal data collected directly from you, including:
when you complete our insurance policy proposal forms;
  via requests for quotations (online, via phone or through our sales representatives);
via claim forms;
when you contact us for an inquiry, complaint or for any other reason.
b-  Personal data collected from other sources, including:

        -  directly from an individual or legal entity who has a policy with us under which you are insured, for from your employer who has an employer’s liability            insurance policy with us under which you are insured;

          -  via third parties, including:

           our agents who have passed on your personal data to us;

*your authorized representative when you may be incapacitated or unable to provide information;

* in the event of a claim, other parties involved, witnesses, medical professionals, assessors, loss

*adjusters, other experts and lawyers;

*other insurance companies for underwriting and claims handling purposes;

*other service providers, including road assistance and accident care, home assistance and travel assistance;

*Public authorities.

         c- Publicly available sources, including:

- Department of Registrar of Companies and Official Receiver;

- The press and media;

- The internet;

- Road Transport Department.


4.
WHAT PERSONAL DATA WE COLLECT
a-   Personal data

We may collect the following personal data from you depending on the product or service we provide to you:

- Contact details such as your name, address, telephone number, e-mail address and other contact information;
- Identification details such as your identification or passport number, driving licence details and social security number;

-  Biographical and demographic data such as your date of birth, age, gender and occupation;
-
 Financial information such as your bank account number and account details, your payment card details and other financial information;
-
 Information relevant to your insurance policy such as details about your vehicle and property, other policies with Eurocross MENA or with other insurance companies, policy and claim numbers, coverage/peril details and valuation reports;
-
 Information about previous and current claims (including claims relating to policies with other insurance companies) such as details of an incident giving rise to the claim, including its extent and impact;
-
 Details of your visit to Eurocross MENA’s website and information collected through cookies and other tracking technologies including your IP address and domain name, your browser version and operating system and your location data;
-
 Details of transactions you carry out through our website including the quotations obtained for insurance policies;

-  Information about your activities and habits that may expose you to increased insurance risk (for example under the personal accident policy);
-
 Your marketing preferences.
b-   Sensitive data

We may collect the following sensitive data from you depending on the product or service we provide to you:

-details in relation to your past and present physical or mental health including any injury or disability information; and
-habits that may expose you to increased health risks.
-
an activity log unique to you that collects certain administrative and traffic information including without limitation source IP address, time of access, date of access, web page(s) visited, language use, software crash reports and type of browser used.
-
The aforesaid information when you visit or use our website, and also in your communications with us.
c-   Children’s data

We understand the importance of protecting children’s privacy. We may collect personal data in relation to children provided that we have first obtained their parent’s or legal guardian’s consent or unless otherwise permitted under law. Our website is not designed for use by children nor do we provide any online services to children. For the purposes of this privacy statement, “children” are individuals under the age of sixteen (16).

Note that you are responsible for ensuring the accuracy of your Personal data and all other information you submit to us (or to others on our behalf). Inaccurate information will affect the information you receive when using our site and tools and our ability to contact you as contemplated in this Privacy Policy. For example, your email address should be kept current because that it is how we communicate with you.

5. USE OF INFORMATION & WHY WE NEED YOUR PERSONAL DATA

5.1 Personal Data

We will only process your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
a-  Where we need to perform the contract we have entered with you or in order to take certain steps prior to entering into a contract with you.

Processing is necessary for us in order to provide you with an insurance policy and any related services, and more specifically in order to:

review the insurance policy proposal form, deliver the Services and provide you with a quotation;

evaluate the risks to be covered for underwriting purposes;

administer, provide and service your insurance policy;

communicate with you, other insured persons under your insurance policy and/or claimants in order to service the insurance policy;

- communicate with you and resolve any complaints and/or inquiries you may have;

notify you about any changes to our insurance products and/or services;

recover any payment due to us in respect of the insurance products and/or services we have provided to you.

- undertake necessary security ,identity verification checks and process any of your online transactions

- Provide you with promotional offers and information regarding our Services as well as products and services from third parties carefully selected by us, and in order for us to improve our offering of a range of products and services and improved customer service.

 The purpose of processing personal data depends on the requirements for each product and/or service. Τhe insurance policy terms and conditions provide more details of the relevant purposes.

If you do not provide the personal data we request from you, we may be unable to offer you an insurance policy, service your insurance policy, or process your claim.

b-   Where we need to comply with a legal obligation

As an assistance company, we are required to comply with certain legal and regulatory obligations which may involve the processing of personal data. Such obligations and requirements impose on us necessary personal data processing activities for identity verification, compliance with court orders, tax law or other reporting obligations and anti-money laundering controls.

c-   Where we have appropriate legitimate interests to use your personal data

In some cases, we may process your personal data to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights are not overridden by our interests. More specifically, we may process your personal data in order to:
- maintain our accounts and records;
enhance the security of our network and information systems;
identify, prevent and investigate fraud and other unlawful activities, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;
safeguard the security of our people, premises and assets and prevent trespassing through video surveillance;
-  
manage our infrastructure, business operations and comply with internal policies and procedures;
modify, personalize or otherwise improve our services/communications;
defend, investigate or prosecute legal claims;
-  
receive professional advice (e.g. tax or legal advice);
perform data analytics (such as market research, trend analysis, financial analysis and customer segmentation).

d-   Where you have given us your consent

We will only ask for your consent when we wish to provide marketing information to you in relation to our products or services which we believe may be of interest and benefit to you.

You may withdraw your consent to such processing at any time. Please note that any processing that was carried out prior to the withdrawal of your consent shall not be affected in any way.
e-   Where we need to process your personal data in order to protect your vital interests or those of another person.

We will only process your personal data on this basis in very rare circumstances, such as where you or a third person is physically or legally incapable of giving consent and only provided that your life, or a third person’s life, is in jeopardy.

 

5.2 Sensitive Data

We will only process your sensitive data under the following circumstances:
a-  When we have your explicit consent to do so

When the insurance policy you wish to purchase or the claim you wish to submit requires the provision of your sensitive data (such as data in relation to your health), we may only collect and process such data with your explicit consent. We will make this clear to you at the point of collection of your sensitive data.

You may withdraw your consent to such processing at any time. However, if you withdraw your consent in relation to your insurance cover or to a claim you wish us to process, then this is likely to impact our ability to provide the relevant insurance services or insurance cover or process any claims under such cover.

b-  Where we need to process your sensitive data in order to protect your vital interests or those of another person.

We will only process your personal data on this basis in very rare circumstances, such as where you or a third person is physically or legally incapable of giving consent and only provided that your life, or a third person’s life, is in jeopardy.
c-  Where processing of your sensitive data is necessary for the establishment, exercise or defense of legal claims which may be related to your insurance policy and/or any claim submitted by you, an insured person or a third party.
 
d-  Where we need to use your sensitive data for reasons of substantial public interest, such as investigating fraudulent claims and carrying out fraud and anti-money laundering checks.

We may also use the aforesaid information to track your use of our website and for other internal purposes, such as evaluating, providing, and improving our services and our website.

We may disclose your Personal data and other information we collect (or others on our behalf) from or about you if required to do so by law, or if we believe in good faith that such action is necessary to comply with a current judicial proceeding, a court order or legal process, or to protect and defend our rights or property, the personal safety of users of the Services or the public.
We reserve the right to share the aforesaid information with banks, credit card companies, and appropriate agencies, if we determine in our sole discretion that you have cheated or attempted to defraud us, or if we suspect you of committing any fraudulent activity (including of fraudulent payment), or any other prohibited transaction.

6.  AUTOMATED DECISION MAKING

When you wish to obtain a quotation or purchase an insurance policy through our website, we will use systems to make automated decisions based on personal data you have provided us with. In particular, the quotation provided to you and/or any possible referral of your request to purchase an insurance policy will be carried out on an automated basis. In such cases, you have the right to contact us to:
(a) give you information about the processing of your personal data (please also see Section 10 of this privacy statement in relation to your rights); and/or
(b) request that one of our employees examines your application and obtain an explanation for the automated decision reached. You also have the right to challenge such a decision. Following such a request, we will reassess your application, taking into consideration both the reasons that a particular automated decision was reached as well as your own point of view.

7.   WHO WE SHARE YOUR PERSONAL DATA WITH

In the course of the performance of our contractual and statutory obligations your personal data may be provided to various departments within Eurocross MENA. Various service providers, insurance partners and suppliers may also receive your personal data so that we may perform our obligations. Such service providers, insurance partners and suppliers enter into contractual arrangements with Eurocross MENA by which they observe confidentiality and data protection according to the terms and conditions of the GDPR number 679/2016.

It must be noted that we may disclose data about you for any of the reasons set out herein above, or if we are legally required to do so, or if we are authorized under our contractual and statutory obligations. All data processors appointed by us to process personal data on our behalf are bound by contract to comply with the GDPR provisions.

Under the circumstances referred to above, recipients of personal data may be, for example:

a-Service providers we have chosen to support us in the effective provision of our products and services to you by offering technological expertise, solutions and support;

b-Auditors and accountants;
c- External legal consultants,
d-
File storage companies, archiving and/or records management companies, and cloud storage companies;
e- 
Financial and business advisors;
f- 
Medical professionals;
g- 
Claims handling experts, such as investigators, assessors and loss adjusters;
h-
Valuators and surveyors;
i-
Third party claimants, their legal representatives and lawyers who seek indemnification under your policy;
j-
Card payment processing companies, such as JCC Payment Systems Ltd;
k-
Accident care and emergency assistance service providers (in relation to motor, home, medical and travel policies) including overseas assistance;
l-
 Governmental and regulatory bodies, including law enforcement authorities, in connection with inquiries, proceedings or investigations by such parties or in order to enable Eurocross MENA to comply with its legal and regulatory requirements;
m-
Our insurance partners such as agents, brokers, other insurance companies, reinsurers and reinsurance brokers.

Some of the recipients of your personal data may be located in third countries (i.e. countries outside the European Economic Area). Processors in third countries are obligated to comply with the European data protection standards and to provide appropriate safeguards in relation to the transfer of your data in accordance with GDPR.

8.   MARKETING

We may process your personal data to tell you about products, services and offers that may be of interest to you or your business.

The personal data that we process for this purpose consists of information you provide to us and data we collect and/or infer when you use our services. We study all such information to form a view on what we think you may need or what may interest you. In some cases, profiling is used, i.e we process your data automatically with the aim of evaluating certain personal aspects in order to provide you with targeted marketing information on products.

We can only use your personal data to promote our products and services to you if we have your explicit consent to do so.

You have the right to object at any time to the processing of your personal data for marketing purposes, by contacting Eurocross MENA either in person or in writing or by contacting us using the contact details set out in Section 2 of this privacy statement.

Even if you inform us that you no longer wish to receive marketing material, you will still receive other important information from us from time to time, such as changes to your existing products or services.

We may ask you to confirm or update your choices, if you purchase any new products or services from us in the future. If you change your mind you can update your choices at any time by contacting Eurocross MENA either in person or in writing or by contacting us using the contact details set out in Section 2 of this privacy statement.

9.   HOW LONG WE KEEP YOUR PERSONAL DATA FOR

We will keep your personal data for as long as we have a business relationship with you. Once our business relationship with you has ended, we may keep your personal data for the longest of the following periods:
(i)  any retention period set out in our retention policy which is in line with regulatory requirements relating to retention; or
(ii) the end of the period in which legal action or investigations might arise in respect of the products and services provided, including your insurance policies and any claims arising in relation thereto.

We may keep your data for longer if we cannot delete it for legal, regulatory or technical reasons. If we do, we will make sure that your privacy is protected and that your data are only used for those purposes.

We shall keep your personal data as a prospective customer for twelve (12) months from the date that the quotation was provided to you, assuming no insurance policies arose in relation to the quotation provided.

10. YOUR DATA PROTECTION RIGHTS

You have the following rights in terms of the personal data we hold about you:

a-Receive access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

b- Request correction (rectification) of the personal data we hold about you. This enables you to have any incomplete, inaccurate or out of date information we hold about you corrected.
c-
 Request erasure of your personal data. This enables you to ask us to erase or remove your personal data where there is no good reason for us continuing to process.

d-Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. In such a case, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interest, rights and freedoms.
e-
You also have the right to object where we are processing your personal data for direct marketing purposes. This also includes profiling inasmuch as it is related to direct marketing.

f- Request the restriction of processing of your personal data. This enables you to ask us to restrict the processing of your personal data if:

 it is not accurate;
-  
it has been used unlawfully but you don’t want us to delete it;
-  
it is not relevant any more, but you want us to keep it for use in possible legal claims;
-  
you have already asked us to stop using your personal data but you are waiting for us to confirm if we have legitimate grounds to use your data.

 

g- Request to receive a copy of the personal data concerning you in a format that can be easily re-used or request the transfer of such data to other organisations.

 

Withdraw the consent you gave us with regard to the processing of your personal data for certain purposes, such as to allow us to promote our products and services to you and/or to process your sensitive data. In some cases, if you withdraw your consent, we may not be able to process your insurance policy or claim.

To exercise any of your rights, or if you have any other questions about our use of your personal data, please visit Eurocross MENA or contact us using the contact details set out in Section 2 of this privacy statement.

11. RIGHT TO COMPLAINT

If you have exercised any or all of your data protection rights, or otherwise still feel that your concerns about the use of your personal data have not been adequately addressed by us, you have the right to complain in writing at the following addresses: (a) via post at: 14 Spyrou Kypriano, office 101, Limassol Cyprus, (b) via email at: info@eurocross.me, or by (c) by completing our online contact form (www.eurocross.me).  You also have the right to complain to the Office of the Commissioner for Personal Data Protection. You can visit their website to find out how to submit a complaint (www.dataprotection.gov.cy).

12. CHANGES TO THIS PRIVACY POLICY

We may modify or amend this Privacy Statement from time to time.

We will notify you appropriately when we make changes to this Privacy Statement and we will amend the revision date at the bottom of this page. We do however encourage you to review this statement periodically so as to be always informed about how we are processing and protecting your personal information.

13. COOKIES

Our Website uses a browser feature known as cookies, which are small text files which are placed on your device or equipment when you visit certain online pages, to make it work better in order to improve your experience to track your activities, record your preferences, and make our site more responsive to your needs by delivering a better and more personalized experience to you.

The cookies are stored on your device’s hard drive and are used by us to help track your clicks and pass information as you go through the pages within our website. Cookies can allow us to associate navigational information from browsing visits with Personal data you provide at our site.

14. SECURITY

We have implemented suitable security policies, rules and technical measures to protect and safeguard the Personal Information under our control from unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction or accidental loss.

All our employees and data processors that have access to, and are associated with the processing of your Personal data, are obliged to respect the confidentiality of your information. On our website, when your Personal data is transferred, we use the latest 128-bit Secure Socket Layer (SSL) encryption technology to ensure that your data is transferred securely over the internet to our server.

15. USE OF ESP

Since you will be required to send and receive money to and from us in order to use our Services, we may use for the processing of such financial transactions third-party electronic payment processors and/or financial institutions (“ESPs”), and you expressly consent, by agreeing to this Privacy Policy, to have Personal Information necessary for the processing of transactions shared with ESPs.
16. LINKS TO OTHERS SITES

Our site may contain links to other sites. Other sites may also reference or link to our website. We are not responsible for the privacy practices or the content of such other online sites, and any information collected by these third party online sites is not governed by this Privacy Policy, and we assume no responsibility or liability whatsoever for the policies (including privacy policies), practices, actions or omissions of such third parties.

17. GENERAL PROVISIONS

In the event that we sell, assign or transfer some or all of our business or assets to a successor or acquirer, or if we are acquired by or merge with a third party, or if we file for bankruptcy or become insolvent, we may sell, assign or transfer all of your Personal Data and other information provided by you or about you, regardless of your opt status, to such successor or acquirer.

18. DISCLAIMER 
The Services operate “AS-IS” and “AS-AVAILABLE”, without liability of any kind. We are not responsible for events beyond our direct control. We cannot guarantee nor do we represent that there will be error-free performance regarding the privacy of your Personal data, and we will not be liable for any indirect, incidental, consequential or punitive damages relating to the use or release of Personal Information.

19. YOUR ACCEPTANCE OF THIS POLICY
By agreeing to our Terms of Use during the registration process on our website, or by continued use of our Services, you agree to be bound by this Privacy Policy, and to any changes we may make to this Privacy Policy from time to time.

We will notify you of any changes to our Privacy Policy by posting the changes on our website. We recommend that you revisit this Privacy Policy regularly so as to be kept apprised of any such changes. Your continued use of our Services following the posting of changes to this privacy policy means you accept these changes.

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