Colonnade Insurance S.A. Luxembourg – Sucursala Bucuresti (“Colonnade”) is committed to protecting the privacy of the individuals we encounter in conducting our business.
- this website (the “Site”) http://www.colonnade.ro;
- the software applications made available by us for use on or through computers and mobile devices (the “Apps”);
- our social media pages; and
- other social media content, tools and applications (our “Social Media Content”)
collectively (including the Site, the Apps and our Social Media Content) referred to below as the “Colonnade Electronic Services”,
and through other means (for example, from your application for queries and claim forms, telephone calls, e-mails and other communications with us, as well as from claim investigators, medical professionals, witnesses or other third parties involved in our business dealings with you).
Who to contact about your Personal Information
If you have any questions about our use of your Personal Information you can e-mail: DataProtection.Romania@colonnade.ro or write to: Customer Service Department, Colonnade Insurance S.A. Luxembourg – Sucursala Bucuresti, Victoria Center Building, 145th Calea Victoriei, 8th Floor, District 1, Bucharest, Romania.
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Personal Information that we collect
Depending on your relationship with us (for example, as a consumer policyholder; non-policyholder insured or claimant; witness; commercial broker or appointed representative; or other person relating to our business), Personal Information collected about you and your dependants may include:
- General identification and contact information
Your name; address; e-mail and telephone details; gender; marital status; family status; date and place of birth; passwords (including on our systems); educational background; physical attributes; activity records, such as driving records; photos; employment history, skills and experience; professional licenses and affiliations; relationship to the policyholder, insured or claimant; and date and cause of death, injury or disability.
- Identification numbers issued by government bodies or agencies
Social Security or national insurance number; passport number; tax identification number; military identification number; or driver’s or other license number; or copies of identity documents or of other documents for identification.
- Financial information and account details
Payment card number; bank account number and account details; credit history and credit score; assets; income; and other financial information.
- Medical condition and health status
Current or former physical or mental or medical condition; health status; injury or disability information; medical procedures performed; personal habits (for example, smoking or consumption of alcohol); prescription information; and medical history.
- Other sensitive information
In certain cases, we may receive sensitive information about your trade union membership, religious beliefs, political opinions, family medical history or genetic information (for example, if you apply for insurance through a third-party marketing partner that is a trade, religious or political organization). In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud. We may also obtain sensitive information if you voluntarily provide it to us or you have provided to medical centers or institutions and health care centers or institutions (for example, if you express preferences regarding medical treatment based on your religious beliefs).
- Telephone recordings
Recordings of telephone calls to our representatives and call centers.
- Prevention and investigation of crime, including fraud and money laundering
For example, we may be requested by law enforcement agencies to provide them with certain information.
- Information enabling us to provide products and services
Location and identification of property insured (for example, property address, vehicle license plate or identification number); travel arrangements including reservation numbers; age categories of individuals you wish to insure; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organization; and other insurance you hold.
- Marketing preferences and customer feedback
You may let us know your marketing preferences, enter a contest or prize draw or other sales promotion, or respond to a voluntary customer satisfaction survey. It is also possible for us to have a contact with you in order to obtain a feedback on the services provided to you and/or to obtain your opinion for new services. Despite, we are willing to inform you that we will strive to contact you for marketing preferences mainly to protect your interests and to improve the quality of servicing you.
- Social media account and information from Apps
We may receive certain Personal Information about you when you use our Apps or Social Media Content, including your social media account ID and profile picture, and other Personal Information that you provide to us. If you elect to connect your social media account provided by another social media service provider to your account(s) on any of the Colonnade Electronic Services, Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your social media account profile or your friends’ profiles.
How we use Personal Information
We use this Personal Information to:
- communicate with you and others as part of our business.
- send/provide you important information regarding changes to our policies, other terms and conditions, the Colonnade Electronic Services and other administrative information.
- make decisions about whether to provide insurance; provide insurance and assistance services, including claim assessment, processing and settlement; and, where applicable, manage claim disputes.
- assess your eligibility for payment plans, and process your premium and other payments.
- provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers).
- prevent, detect and investigate crime, including fraud and money laundering, and analyze and manage other commercial risks.
- carry out market research and analysis, including satisfaction surveys.
- provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed.
- personalize your experience on the Colonnade Electronic Services by presenting information and advertisements tailored to you.
- identify you to anyone to whom you send messages through the Colonnade Electronic Services.
- allow you to participate in contests, prize draws and similar promotions, and to administer these activities.
Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these carefully.
Facilitate social media sharing functionality
Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management.
Resolve complaints, and handle requests for data access or correction.
Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism or to data protection; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence).
Establish and defend legal rights; protect our operations or those of any of our group companies or insurance business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.
International transfer of Personal Information
Due to the global nature of our business, for the purposes set out above we may transfer Personal Information to parties located in other countries (including the Canada, in the United States and other countries that have a different data protection regime than is found in the country where you are based). For example, we may transfer Personal Information in order to process international travel insurance claims and provide emergency medical assistance services when you are abroad. We may transfer information internationally to our group companies, service providers, business partners and governmental or public authorities.
Sharing of Personal Information
Colonnade may make Personal Information available to:
Our group companiesIn respect of business, employment and marketing purposes Colonnade may make Personal Information available to other branches of Colonnade Insurance S.A. (Grand Duchy of Luxembourg) or its group companies. For a list of Colonnade group companies that may have access to and use of Personal Information, please refer to us as provided herein. Colonnade is responsible for the management and security of jointly used Personal Information. Access to Personal Information within group is restricted to those individuals who have a need to access the information for our business purposes, including marketing purposes.
- Other insurance and distribution parties
In the course of marketing and providing insurance and processing claims, Colonnade may make Personal Information available to third parties such as other insurers; reinsurers; insurance and reinsurance brokers and other intermediaries and agents; appointed representatives; distributors; affinity marketing partners; and financial institutions, securities firms and other business partners. Such a provision of personal data in most of the cases is necessary for the sake of the insurance services provided to you and is in protection of your rights under the insurance agreements.
- Our service providers
External third-party service providers, such as medical professionals, accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; travel and medical assistance providers; call center service providers; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; banks and financial institutions that service our accounts; third-party claim administrators; document and records management providers; claim investigators and adjusters; construction consultants; engineers; examiners; jury consultants; translators; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
- Recipients of your social sharing activity
- Governmental authorities and third parties involved in court action
Colonnade may also share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.
- Other third parties
We may share Personal Information with payees; emergency providers (fire, police and medical emergency services); retailers; medical networks, organizations and providers; travel carriers; credit bureaus; credit reporting agencies; and other people involved in an incident that is the subject of a claim; as well as purchasers and prospective purchasers or other parties in any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business, assets or stock.
Personal Information may also be shared by you, on message boards, chat, profile pages and blogs, and other Colonnade Electronic Services to which you are able to post information and materials (including, without limitation, our Social Media Content). Please note that any information you post or disclose through these services will become public information, and may be available to visitors and users of the Colonnade Electronic Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, when using the Colonnade Electronic Services.
Colonnade will take appropriate technical, physical, legal and organizational measures, which are consistent with applicable privacy and data security laws. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have with us has been compromised), please immediately notify us. (See the “Who to Contact About Your Personal Information” section above.)
When Colonnade provides Personal Information to a service provider, the service provider will be selected carefully and required to use appropriate measures, according to applicable law, to protect the confidentiality and security of the Personal Information.
Retention of Personal Information
Personal Information of other individuals
We will provide you with regular opportunities to tell us your marketing preferences, including in our communications to you. You can also contact us by e-mail: DataProtection.Romania@colonnade.ro or by writing to: Customer Service Department, Colonnade Insurance S.A. Luxembourg – Sucursala Bucuresti, Victoria Center Building, 145th Calea Victoriei, 8th Floor, District 1, Bucharest, Romania to tell us your marketing preferences and to opt-out.
If you no longer want to receive marketing-related e-mails from Colonnade on a going-forward basis, you may opt-out of receiving these marketing-related emails by clicking on the link to “unsubscribe” provided in each e-mail or by contacting us at the above addresses.
Receiving mobile messages (for example SMS text messages) / telephone communications / postal mail from us: If you no longer want to receive mobile messages / telephone communications / postal mail from Colonnade on a going-forward basis, you may opt-out of receiving these marketing-related communications by contacting us at the above addresses.
- Our sharing of your Personal Information with our group companies for their marketing purposes:
If you would prefer that we do not share your Personal Information on a going-forward basis with our group companies for their own marketing purposes, you may opt-out of this sharing by contacting us at the above addresses.
- Our sharing of your Personal Information with selected third-party partners for their marketing purposes:
If you would prefer that we do not share your Personal Information on a going-forward basis with our third-party partners for their own marketing purposes, you may opt-out of this sharing by contacting us at the above addresses.
We aim to comply with your opt-out request(s) within a reasonable time period. Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the databases of third parties with whom we have already shared your Personal Information (i.e., to those to whom we have already provided your Personal Information as of the date on which we respond to your opt-out request). Please also note that if you do opt-out of receiving marketing communications from us, we may still send you other important administrative communications from which you cannot opt-out.
Access and Correction Requests, Requests related to Right to Erasure or to a Right to Restriction of Processing, Questions and Concerns.
You have the right to access, correct, and object to the use and disclosure of, or request deletion or suppression of Personal Information on certain grounds. Please contact us as set out in the "Who to Contact About Your Personal Information" section above with any such requests or if you have any questions or concerns about how we process and/or disclose Personal Information. Please note that some Personal Information may be exempt from access, correction, objection, deletion or suppression rights in accordance with local privacy and data protection laws.
You have also the right to request Colonnade to erase personal data concerning you where one of the following grounds applies: 1) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; 2) you – as a data subject - withdraw consent on which the processing is based, and where there is no other legal ground for the processing; 3) you – as a data subject - object to the processing pursuant and there are no overriding legitimate grounds for the processing; 4) the personal data have been unlawfully processed; 5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which Colonnade as a controller is subject; 6) the personal data have been collected in relation to the offer of information society services. We would like to inform you that there are hypothesis in which we have legal reasons to refuse the erasure of your personal data.
Furthermore you have the right to request Colonnade as a data controller to restrict the processing of your personal data when: 1) the accuracy of the personal data is contested by you, for a period enabling Colonnade to verify the accuracy of the personal data; 2) the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead; 3) Colonnade no longer needs the personal data for the purposes of the processing, but you are required by the data subject for the establishment, exercise or defence of legal claims; 4) you have objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.
When exercising your legitimate rights of data subjects we would like to ask you to consider the fact that the services provided by Colonnade are directly and entirely related to the accuracy and the genuineness of the personal data provided by you.
Other information we collect through the Colonnade Electronic Services
- “Other Information” is any information that does not reveal your specific identity, such as:
- Browser and electronic device information;
- App usage data;
- Information collected through cookies, pixel tags and other technologies;
- Demographic information and other information provided by you; and
- Aggregated information.
Other Information we collect
We and our third-party service providers may collect Other Information in a variety of ways, including:
- through your internet browser or electronic device:
Certain information is collected by most websites or automatically through your electronic device, such as your IP address (i.e., your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, electronic device manufacturer and model, language, internet browser type and version, time of the visit, page(s) visited and the name and version of the Colonnade Electronic Services (such as the App) you are using. We use this information to ensure that the Colonnade Electronic Services function properly.
- through your use of the App:
When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your electronic device accesses our servers and what information and files have been downloaded to the App based on your device number.
- using cookies:
Below is a description of all the cookies we use on our Romanian website, what they do, what data about you they collect and what we use them for:
O Geo Location cookie – When a visitor visits one of our sites for the first time we read their location from their IP address and use this information to assume the country site that they want to visit. This method is not entirely accurate, however, so when they navigate to a particular country site we use a cookie to store this information and to store the language that they chose to view the site. The next time they visit the site we read the cookie and present the same country and language version they used on your last visit. This has the intended benefit that they don’t need to reselect the country site they need each time they come to the site. No Personal Information is collected or used by the cookie.
oSite Catalyst cookie (by Adobe) – This cookie enables us to collect and analyze data about how visitors arrive at our site and then how they interact with our site, including products they may search, content they may view, and the steps leading up to a completed or abandoned sale. We use this aggregated information to adapt our sites to better serve their and other users’ needs and interests, and to provide more relevant and useful information. The cookie is placed on a visitor’s PC on a temporary basis only. The cookie does not collect or use their Personal Information. Instead, it logs an anonymous code which identifies users and this code “follows” the user in their journey through the site. We use the aggregated and anonymous information for statistical analysis.
oDoubleClick cookies - We place a tracking pixel cookie on to all site visitors’ PCs, for the purpose of our banner advertising activity. We use these cookies to know that a visitor has been on our site before and to then place display an appropriate banner ad on to an affiliated network website. No Personal Information is collected. One of the advertisement companies that we use is Google, Inc, trading as DoubleClick. For more information on the DoubleClick cookie, or to opt out from the DoubleClick advertisement cookie please visit: http://www.google.com/privacy/ads/ .
oAffiliate cookie – We use a tracking pixel cookie, which is put on a visitor’s PC and collects only the transaction ID (which identifies any affiliated website the visitor has come from) and a time and date stamp. This enables our affiliate network to track affiliated sales and ensure an affiliate is credited for a sale referred to us. It does not involve any passing of Personal Information.
oYou can refuse to accept the cookies we use by adjusting your browser settings. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Colonnade Electronic Services and some online products.
- using pixel tags, web beacons, clear GIFs or other similar technologies :
These may be used in connection with some Colonnade Electronic Services and HTML-formatted e-mail messages to, among other things, track the actions of users of Colonnade Electronic Services and e-mail recipients, measure the success of our marketing campaigns and compile statistics about usage of Colonnade Electronic Services and response rates.
- physical Location :
Subject to applicable law, we may collect the physical location of your electronic device by, for example, using satellite, mobile/cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. Subject to your marketing preferences as indicated to us or applicable law, we may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
- from you:
Some information (for example, your location or preferred means of communication) is collected when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you.
- by aggregating information:
We may aggregate and use certain information (for example, we may aggregate information to calculate the percentage of our users who have a particular telephone area code).
Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then, in addition to the uses listed in the “Other Information We Collect” section above, we may collect, use, process and disclose Other Information for all the purposes for which we use and disclose Personal Information.
Third party services
Please note that we are not responsible for the data collection, usage and disclosure policies and practices (including the information security practices) of other organizations, such as Facebook®, Twitter®, Apple®, Google®, Microsoft®, RIM/Blackberry® or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or electronic device manufacturer, including for any Personal Information you disclose to other organizations through or in connection with the Colonnade Electronic Services.
Use of the Colonnade Electronic Services by minors
The Colonnade Electronic Services are not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Information through the Colonnade Electronic Services.