Privacy Protection Policy

I. Controller

INTER PARTNERS ASSISTANCE N.V., active under the trade name AXA PARTNERS BELGIUM, with registered office at Regentlaan 7, 1000 Brussels, recorded in the Crossroads Bank for Enterprises under the number 0415.591.055 (hereafter referred to as "AXA PARTNERS BELGIUM").

II. General

1. Our commitment to protect your personal data

We know that respect for the confidentiality of your personal data is essential for maintaining your trust. We apply procedures to protect your data against any attempt at unauthorised use or disclosure. We have a worldwide team available that occupies itself with data protection and a network of data protection managers to guarantee the security of your data in all of our business units. AXA PARTNERS BELGIUM forms part of the AXA Group. The AXA Group is the first insurance group in the world to have defined a number of Binding Corporate Rules. These rules form an internationally recognised standard for data protection and were approved by the Commission for the Protection of Privacy and by 15 other European authorities that are responsible for the protection of personal data (Belgian Official Journal 6/10/2014, p. 78547).

2. Our commitment concerning the use of your personal data

We offer you solutions relating to prevention and protection that are constantly being adapted thanks to an in-depth analysis of the risks you are confronted with. For this we collect your personal data and use them in accordance with the law. We have drawn up general terms and conditions for the processing of your personal data within the framework of our service and insurance activities. You will receive or have received these conditions upon purchase of the service or insurance product. You can always request a new copy from your insurance intermediary or our partner from whom you purchased the product. We have drawn up procedures and contractual provisions in order to oblige all of our employees, commercial representatives, consultants and service providers to preserve the confidentiality of your data. Our prospective customers can give us personal information that we need in order to offer them an insurance policy which they specifically need – both upon the initial signing and throughout the term of the contract. We regard ourselves as the guardian of these data. In some cases we can, in collaboration with other companies, offer products to our customers, but only if we are convinced that these products have a real added value for our customers.

III. Website

1. Introduction

You can consult the website of AXA PARTNERS BELGIUM without communicating your personal data. However, certain pages may be reserved for visitors who register in advance or provide certain personal data and information. This information and data are intended to enable us: to respond to your request for information, or to provide to you the requested information/documentation or the requested service, or to keep you informed of our activities and/or new products and services. On the other hand, AXA PARTNERS BELGIUM can also install cookies on your computer or mobile device (smartphone, tablet, etc.). Cookies are small files that the server of AXA PARTNERS BELGIUM installs on the hard disk of your computer or on other mobile devices (smartphones, tablets, etc.). Cookies are used in order to store certain data permanently or temporarily. You will find more information on this subject in the 'Cookie Policy' chapter of the current policy.

2. Categories of processed data

The data that are collected via this website can include, but are not limited to, your first and last name, home address, e-mail address, telephone number, age, login data and other identifying information. However, AXA PARTNERS BELGIUM will not save or process sensitive data via this website. By 'sensitive data' is understood personal data relating to race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, as well as the processing of genetic data, biometric data with the goal of identifying a natural person as a unique individual, data concerning the health or data on the sexual life or sexual orientation of a natural person.

3. Purposes of the data processing

Your personal data that you share with us via this website are collected with a view to the advertising and promotion of the products and services offered by AXA PARTNERS BELGIUM, market research, statistical and actuarial studies, customer relations management and, where applicable, the proposal, negotiation, conclusion and execution of the contracts and insurance policies offered by AXA PARTNERS BELGIUM. The communication of your personal data takes place on a voluntary basis with regard to advertising and promotion for the products and services offered by AXA PARTNERS BELGIUM, market research, statistical and actuarial studies and customer relations management. The communication of your personal data within the framework of our services and insurance products such as your home address, your e-mail address, your personal status, your bank account and, in the event of medical assistance, information about your health, etc., is a necessary condition for the proposal, negotiation, conclusion and execution of the contracts and insurance policies offered by AXA PARTNERS BELGIUM. In the last case, the storage and processing of your personal data are governed by the applicable contractual conditions of AXA PARTNERS BELGIUM.

4. Addressees of the data

In order to meet your needs as well as possible and to offer you the most appropriate services in relation to the above-mentioned objectives, your personal data can be communicated to other companies of the AXA Group, to companies and/or persons who are associated with them (lawyers, medical advisors, experts, reinsurers, co-insurers, service providers, etc.), intermediaries (brokers etc.) and/or third parties with whom AXA PARTNERS BELGIUM has concluded agreements relating to the processing of your data.

5. Data transfer outside the European Union

If necessary, the third parties to whom your personal data are provided can find themselves both inside and outside the European Union. When sending data to third parties who are established outside the European Union, AXA PARTNERS BELGIUM fulfils the statutory and administrative-law provisions that apply to such transfers and more specifically assumes responsibility for an adequate level of protection for the personal data provided, on the basis of the solutions imposed or recommended by the European Commission, such as standard contractual clauses or Binding Corporate Rules ('BCR') in the event of transfer within a group.

6. Data processing for direct marketing purposes

AXA PARTNERS BELGIUM can process your personal data for direct marketing purposes (commercial actions, personalised advertising, profiling, matching of data, familiarity, etc.) in order to improve the knowledge of your person and your needs, in order to inform you about its activities, products and services and to send you commercial offers. Your data can also be shared with other companies of the AXA Group and your intermediary for direct marketing purposes with a view to similar objectives. In order to be able to offer the most appropriate services within the framework of direct marketing, these personal data can be communicated to companies and/or persons who act as subcontractor or service provider for the benefit of AXA PARTNERS BELGIUM, other companies of the AXA Group and/or the insurance intermediary. Such processing is necessary for the legitimate interests of AXA PARTNERS BELGIUM which include the development of its economic activity. In this case, this processing can be based on the consent of the data subject.

7. Data retention periods

AXA PARTNERS BELGIUM can store and process your personal login data for a period of 12 months. This retention period begins with the most recent time that you logged in. This also applies for personal data that are stored by means of cookies. Other data that are processed within the framework of the objectives defined in other, whether or not contractual, documents may be retained for other periods.

8. Confidentiality

AXA PARTNERS BELGIUM has taken all necessary measures in order to guarantee the confidentiality of personal data and to protect itself against unauthorised access, abuse, modification or removal thereof. For this AXA PARTNERS BELGIUM applies standards concerning security and permanent service and regularly assesses both the security level of its processes, systems and applications and that of its partners.

9. Right to access, rectification, removal, restriction and objection – data portability

You can: get confirmation from AXA PARTNERS BELGIUM as to whether or not your personal data are being processed and, if this is the case, receive access to these data; correct and, if necessary, supplement your personal data which are incorrect or incomplete; under certain circumstances have your personal data erased; restrict the processing of your personal data in certain circumstances; for reasons that relate to a special situation, object to the processing of personal data on the basis of the legitimate interests of AXA PARTNERS BELGIUM; object to the processing of your personal data for direct marketing purposes, including the drawing up of profiles for direct marketing purposes; not be the object of a decision that is based exclusively on automated processing, including profiling, which has legal consequences for you or which have important consequences for you; if such automated processing is necessary for the conclusion or execution of an agreement, however, you have the right to obtain a human intervention of AXA PARTNERS BELGIUM, to express your position and to challenge the decision of AXA PARTNERS BELGIUM; receive your personal data provided by you to AXA PARTNERS BELGIUM in a structured, commonly used and machine-readable format; pass on these data to another controller, when (i) the processing of your personal data is based on your consent or for the purpose of the performance of a contract and (ii) the processing takes place with the help of automated processes; and have your personal data transferred directly from one controller to another, in so far as this is technically possible; withdraw your consent at any time, without prejudice to the processing that took place lawfully prior to its withdrawal, when the processing of your personal data is based on your consent.

10. How can you exercise your rights?

You can exercise your rights by contacting AXA PARTNERS BELGIUM (see the tab "Contact AXA PARTNERS BELGIUM" of this policy).

IV. Cookie Policy

1. What is a cookie?

When you visit this website, AXA PARTNERS BELGIUM makes use of cookies to improve the use of the website by visitors (for example, by remembering the language) and to collect statistics on the surfing behaviour of visitors to our website. Cookies are small files that are stored on your hard disk or mobile device and with which we can save information on your visit, which we can then read upon a following visit. Cookies can recognise your browser when you visit our website ('session cookie') or upon future repeated visits ('permanent cookie'). The presence of cookies saves you from having to enter your language preferences once again (navigation language choice). The server of AXA PARTNERS BELGIUM can only read cookies that were installed by itself. It has no access to other information on your computer or mobile device. Cookies are stored on your computer or mobile device, in the memory of your browser. The content of a cookie generally consists of the name of the server that installed the cookie, an expiry date and a unique encrypted code. This information is retained for 12 months. You can prevent the storage of cookies on your computer or mobile device by configuring your browser (for this consult the online help page of your web browser). You can also delete the cookies that are stored on your computer or mobile device. You can find more information about this in the General Terms and Conditions of this website.

2. How can you exercise your rights?

You can exercise your rights by contacting AXA PARTNERS BELGIUM (see the tab "Contact AXA PARTNERS BELGIUM" of this policy).

V. Privacy upon the provision of our products and services

1. Introduction

AXA PARTNERS BELGIUM applies the following policy for the processing of your personal data if you conclude an insurance policy or some other insurance product. This policy has no effect on the specific clauses in the contracts and contract proposals that you received from AXA PARTNERS BELGIUM.

2. Categories of processed data

Depending on the type of coverage or services that are offered by AXA PARTNERS BELGIUM, the personal data that can be processed by AXA PARTNERS BELGIUM are the following: - Identification data (last name, first name, date of birth, etc.) - Contact details (postal address, e-mail address, telephone numbers, etc.) - Location data (site of the accident, place staying abroad, etc.) - family composition and civil status (number of children, identity of the spouse or partner, identity of the family members who live under the same roof, etc.) - Commercial data (contract or policy number, VAT number, etc.) - Banking and financial data (bank account, banking institution, etc.) - Information relating to your equipment and vehicles (number plate, car or equipment model, etc.) - Health-related data (medical certificates and reports, invoices, etc.) - Other personal data that are necessary in order to provide the guarantee that was or is being subscribed from AXA PARTNERS BELGIUM. AXA PARTNERS BELGIUM collects and processes your data only in so far as they are necessary to achieve the intended processing purposes.

3. Purposes of the data processing

The personal data that you communicate or which are received legitimately by AXA PARTNERS BELGIUM from companies of the AXA Group, from companies that are related to these companies, from your employer or from third parties, may be processed by AXA PARTNERS BELGIUM for the following purposes: the management of the person database · the management of the insurance contract · the provision of services to the customers · management of the relationship between AXA PARTNERS BELGIUM and the insurance intermediary · the detection, prevention and control of fraud · combatting money laundering and terrorist financing · monitoring of the portfolio · statistical studies

4. Data processing with a view to direct marketing

The personal data, communicated by yourself or lawfully received by AXA PARTNERS BELGIUM, may be communicated to other companies of the AXA Group and to companies that are related to AXA PARTNERS BELGIUM and/or to the insurance intermediary with a view to their own direct marketing or joint direct marketing (commercial actions, personalised advertising, profiling, linking of data, familiarity, etc.), to improve the knowledge of the joint customers and prospects, to inform the latter about their respective activities, products and services, and to provide commercial offers. In order to provide the best possible service in connection with direct marketing, these personal data can be communicated to companies and/or to persons in their capacity of subcontractors or service providers for the benefit of AXA PARTNERS BELGIUM, other companies of the AXA Group and/or the insurance intermediary. These processings are necessary for the promotion of legitimate interests of AXA PARTNERS BELGIUM consisting of the development of its economic activity. In such a case, these processings can be based on the consent of the data subject.

5. Addressees of the data

To the extent that the communication of personal data is necessary for the purposes listed above, your personal data may be communicated to other companies of the AXA Group and to companies and/or persons who are related to it (lawyers, experts, advising doctors, reinsurers, co-insurers, insurance intermediaries, service providers, other insurance companies, representatives, follow-up agencies for pricing, claims settlement agencies, Datassur). These data may also be communicated to the supervisory authorities, to the competent government services and to any other government or private body with which AXA PARTNERS BELGIUM can exchange personal data in accordance with the applicable legislation.

6. Transfer of data outside the European Union

The other companies of the AXA Group, the companies and/or persons who are related to it and to whom the personal data are communicated, can be located either in the European Union or outside of it. In the event of transfer of personal data to third parties who are located outside the European Union, AXA PARTNERS BELGIUM complies with the statutory and regulatory provisions that are in effect for such transfers. AXA PARTNERS BELGIUM guarantees in particular an adequate level of protection for the personal data thus transferred, on the basis of the alternative mechanisms established by the European Commission, such as the standard contractual conditions or also the Binding Corporate Rules for the AXA Group in the event of transfers within the group (Belgian Official Journal 6/10/2014, p. 78547). You can obtain a copy of the measures taken by AXA PARTNERS BELGIUM so as to be able to transfer personal data outside the European Union by sending a request to AXA PARTNERS BELGIUM at the address mentioned below ('Contact AXA PARTNERS BELGIUM').

7. Processing of health data

If your contract or policy relates to the processing of information about your health, AXA PARTNERS BELGIUM guarantees compliance with the specific rules that apply to the processing of personal health data, by taking all technical and organisational measures that are necessary for this. The processing of such data may only occur with the explicit consent of the data subject or, if he/she is physically or legally unable to give his/her consent, with a view to the protection of the vital interests of the data subject. The processing of these data is performed by AXA PARTNERS BELGIUM employees specially appointed for this task, and under the supervision of doctors (medical advisors) who are subject to the duty of medical secrecy. Medical certificates and other documents in which similar data are included, that are necessary for the negotiation, conclusion or execution of the contract, including claims adjustment, are only provided to the medical advisors of AXA PARTNERS BELGIUM. These medical advisors for their part will communicate to AXA PARTNERS BELGIUM or the persons specifically designated for this exclusively the data concerning the current state of health of the persons concerned which are strictly relevant for the risk for which these documents were drawn up. Transfer of these data only takes place in so far as this is necessary and the addressees offer sufficient guarantees for the compliance with the specific rules for their processing. Prior to this transfer, AXA PARTNERS BELGIUM assures that they are minimised, pseudonymised or, where applicable, anonymised.

8. Data retention periods

AXA PARTNERS BELGIUM stores the personal data that are collected in relation to the insurance contract throughout the term of the contractual relationship or of the management of the claim files, with updating thereof each time the circumstances so require, this extended by the legal retention periods or by the prescription period in order to defend against a claim or possible appeal, filed after the end of the contractual relationship or after the closing of the claim file. AXA PARTNERS BELGIUM stores the personal data relating to refused offers or offers to which AXA PARTNERS BELGIUM gave no effect for up to five years after the issuance of the offer or the refusal to conclude a contract.

9. Necessity to communicate personal data

The communication of your personal data within the framework of our insurance services and products, such as your identity, home address, e-mail address, personal status, bank account and, in the event of medical assistance, information relating to health, etc., is however a necessary condition for the proposal, negotiation, conclusion and execution of the contracts and insurance policies that are offered by AXA PARTNERS BELGIUM. In the last case, the registration and processing of your personal data are governed by the applicable contractual conditions of AXA PARTNERS BELGIUM.

10. Confidentiality

AXA PARTNERS BELGIUM has taken all required measures in order to safeguard the confidentiality of the personal data and to protect against unauthorised access, abuse, alteration or erasure of these data. AXA PARTNERS BELGIUM follows for this the standards concerning security and service provision continuity and regularly evaluates the security level of its processes, systems and applications, as well as that of its partners.

11. Right to access, rectification, removal, restriction and objection – data portability

12. How can you exercise your rights?

You can exercise your rights by contacting AXA PARTNERS BELGIUM (see the tab "Contact AXA PARTNERS BELGIUM" of this policy).

VI. Personal privacy with regard to the recruitment and selection policy of AXA PARTNERS BELGIUM

1. Introduction

Within the framework of its selection and recruitment activities, AXA PARTNERS BELGIUM has a legitimate interest in the collection and processing of the personal data of applicants. AXA PARTNERS BELGIUM attaches the greatest importance to protecting the privacy and the personal data of applicants. AXA PARTNERS BELGIUM therefore wishes with this statement to inform applicants about the goal and the characteristics of the processing of their data. This statement can be adapted or supplemented in order to fulfil legal requirements and/or in order to meet the new priorities of AXA PARTNERS BELGIUM. The applicants are requested to consult this page regularly in order to learn of any changes, given that updates are not subject to an advance notification.

2. Categories of processed data

AXA PARTNERS BELGIUM can collect and process the personal data of applicants, both within the framework of a job opening and after an unsolicited application. These data can be provided by e-mail, by letter, by sending an attachment on the website of AXA PARTNERS BELGIUM, by personal contact or during an interview. These data include, amongst other things, data on the civil status of the applicants (name, sex, address, language, etc.), their contact details (e-mail, telephone, etc.), their education (studies, degrees, etc.) and their professional background (previous employers, references, etc.). These data must be accurate, adequate and relevant. They are limited to the information that is necessary in order to achieve the objectives described below. AXA PARTNERS BELGIUM cannot gather or process any medical data or sensitive data, such as information about race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health or sexuality, unless the applicants expressly consent to this and/or the needs relating to the proposed position and tasks are expressly mentioned.

3. Purposes of the processing

The personal data that the applicants provide to AXA PARTNERS BELGIUM are processed exclusively with a view to the selection and recruitment of future employees. The goal of this procedure is to investigate and establish the experience, skills and qualifications of the applicants or to be able to match applications with an open position or a profile being sought. The communication of these data is a condition for negotiating about and concluding an employment contract with AXA PARTNERS BELGIUM. The processing activities of AXA PARTNERS BELGIUM include inter alia the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data of applicants.

4. Addressees of data

In order to achieve the objectives described in the preceding section, AXA PARTNERS BELGIUM can pass on the personal data of the applicants either to its own suppliers and subcontractors, or to other subsidiaries of the AXA Group. The selected suppliers and subcontractors act only as mandatories of AXA PARTNERS BELGIUM, which is solely responsible for the processing of the data of the applicants. The latter are obliged to guarantee an adequate level of protection by complying with the rules that apply for the protection of personal data and the standards that apply within the AXA Group.

5. Data transfer outside the European Union

The other companies of the group to which AXA PARTNERS BELGIUM belongs, the suppliers and the subcontractors to whom the personal data of the applicants are communicated, may find themselves both inside and outside the European Union. AXA PARTNERS BELGIUM, when transmitting data to third parties that are established outside the European Union, meets the statutory and administrative-law requirements that apply to such transfers and more specifically assumes responsibility for an adequate level of protection for the transmitted personal data, on the basis of the solutions imposed or recommended by the European Commission, such as standard contractual clauses or Binding Corporate Rules ('BCR') in the event of transfer within a group.

6. Confidentiality

AXA PARTNERS BELGIUM applies adequate technical and organisational measures in order to guarantee the security, integrity, confidentiality and availability of the personal data of the applicants. These measures are both preventive and corrective in nature. The applicant data are only communicated to persons within AXA PARTNERS BELGIUM or to third parties as defined above, that are authorised to process such data with a view to selection, recruitment or negotiation and are protected against unauthorised use, more specifically by an adequate physical or technical separation.

7. Data retention periods

The applicant data are kept throughout the selection and recruitment procedure by AXA PARTNERS BELGIUM. After completion of this procedure, AXA PARTNERS BELGIUM destroys the applicant data, except in the following cases: if AXA PARTNERS BELGIUM is obliged to save them on the basis of a statutory obligation; if the applicant is hired as an employee or if AXA PARTNERS BELGIUM can invoke sufficient justification (more specifically, in order to retain the profile of the applicants until a job opening arises). The personal data of the unselected applicants are in any case kept for a maximum of two years after the conclusion of the selection procedure.

8. Right to access, rectification, removal, restriction and objection – data portability

9. How can you exercise your rights?

You can exercise your rights by contacting AXA PARTNERS BELGIUM (see the tab "Contact AXA PARTNERS BELGIUM" of this policy).

VII. Contacting AXA PARTNERS BELGIUM

If you wish to exercise one of the following rights (access, rectification, removal, restriction and objection – data portability), you can contact AXA PARTNERS BELGIUM in order to exercise your rights at the following addresses: - by letter: AXA PARTNERS BELGIUM - Data Protection Officer, Regentlaan 7, 1000 Brussels - by e-mail: dpo.BNL@axa-assistance.com. Please join a copy of an identity document (identity card, passport, driving licence, etc.) to your request. In order to facilitate our search actions, we would also appreciate it if you could mention your customer data, contract or policy number. AXA PARTNERS BELGIUM deals with the requests within the legal periods. Unless the request is manifestly unfounded or excessive, no payment is required for handling the request.

VIII. Filing a complaint relating to personal data

If you believe that AXA PARTNERS BELGIUM does not meet the regulations on the subject, you are asked to first contact AXA PARTNERS BELGIUM. You can also file a complaint with the Data Protection Authority at the following address: Persstraat 35, 1000 Brussels, Tel. + 32 2 274 48 00, Fax. + 32 2 274 48 35, contact@apd-gba.be You can also file a complaint with the Court of First Instance of your domicile.

IX. Changes and adaptations of this policy

AXA PARTNERS BELGIUM reserves the right to change or adapt this document in whole or part. You can regularly consult this page in order to remain informed of any changes or adaptations.

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