AXA ASSISTANCE respects your privacy and ensures that all your personal data are processed in accordance with best practices in terms of privacy and personal data legislation, including the General Data Protection Regulation (2016/679), hereinafter GDPR.
This document constitutes the personal data processing policy applicable to use of the website.
UPDATING THIS POLICY
AXA ASSISTANCE may update this Policy in response to legal, technical, or business changes. In the event of an update, AXA ASSISTANCE will take appropriate measures to inform you of the significance of these changes. When required by law, AXA ASSISTANCE will seek your consent for any material changes to the processing of your personal data. This Policy was last updated on 04 SEPTEMBER 2024.
LEGAL DISCLAIMER - CONTROLLER
SA INTER PARTNER ASSISTANCE
A member of the AXA ASSISTANCE Group
Registered office: Boulevard du Régent 7, B-1000 Brussels
Registered with the Crossroads Bank for Enterprises under No. 0415.591.055, Brussels Companies Register, An insurance company accredited under code 0487
(hereinafter referred to as "AXA ASSISTANCE").
DEFINITIONS
The Publisher draws the attention of Users of its website to the following points:
"AXA ASSISTANCE" means SA INTER PARTNER ASSISTANCE, described above;
- "Data" means personal data;
- "Publisher" means AXA ASSISTANCE;
- "Legislation" means Belgian, European, and international laws and regulations on the protection of privacy and the processing of personal data, including GDPR and the Belgian laws and decrees supplementing this Regulation;
- "Controller" means the controller within the meaning of GDPR; the controller is AXA ASSISTANCE;
- "GDPR" means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC;
- "Processor" means the processor within the meaning of GDPR;
- "User" means any person using the Mobile Application;
- "You" or "Beneficiary" means the beneficiary of assistance services (as defined in the contractual terms and conditions of your contract or policy), who accesses, consults, and uses the Mobile Application for the purpose of implementing Assistance Services.
PURPOSE OF PROCESSING
The personal data you provide to AXA ASSISTANCE via the website may be processed by AXA ASSISTANCE for the following purposes:
- Provision of assistance services,
- Management and performance of the contract or insurance policy entered into with AXA ASSISTANCE,
- Development, management, adaptation, and updating of the website and/or its features,
- Analysis (including technical or statistical analysis) of website uses and/or its features and connections to the website,
- Management of the register of persons,
- Customer service,
- Detection, prevention, and combating of fraud,
- Anti-money laundering and terrorist financing,
- Portfolio monitoring,
- Compliance with the legislation (tax, social security, accounting, etc.) applicable to the assistance services provided for in your contract or insurance policy,
- Statistical research.
Insofar as disclosure of personal data is necessary for the purposes listed above, personal data may be disclosed to other AXA Group companies, to companies and/or to persons working with these companies (lawyers, experts, medical advisers, reinsurers, co-insurers, insurance intermediaries, service providers, other insurance companies, representatives, pricing monitoring office, claims settlement offices, Datassur).
These data may also be disclosed to the supervisory authorities, the relevant public departments, and to any other public or private body with which AXA ASSISTANCE may be required to exchange personal data in accordance with applicable legislation.
DATA PROCESSED
Depending on the type of cover or services offered by AXA ASSISTANCE, the following personal data may be processed by AXA ASSISTANCE:
- Identification data (surname, first name, date of birth, etc.),
- Contact details (postal address, email address, telephone numbers, etc.),
- Family composition and marital status (number of children, identity of spouse or partner, identity of family members living under the same roof, etc.),
- Commercial data (contract or policy number, VAT number, etc.),
- Banking and financial data (bank account, bank institution, etc.),
- Health data (medical certificates and reports, invoices, etc.),
- Other personal data necessary to provide the cover taken out or to be taken out with AXA ASSISTANCE.
AXA ASSISTANCE only collects and processes your data to the extent necessary to achieve the processing purposes it pursues.
LEGAL BASES OF PROCESSING
AXA ASSISTANCE processes your Personal Data based on the following legal bases:
- The performance of your contract or insurance policy as well as the general terms and conditions of use for the Mobile Application: in order to provide you with assistance services, to manage or perform your contract or policy, and to manage the Mobile Application,
- The pursuit of AXA ASSISTANCE’s legitimate interests: to manage the Mobile Application, to carry out technical or statistical analyses, to manage the relationship with the Insured, the Beneficiary, or the User, to detect, prevent and combat fraud, and to monitor their portfolio,
- Fulfilment of a statutory and regulatory obligation: in order to comply with and apply the legislation (tax, social security, accounting, etc.) applicable to the assistance services provided for in your policy or insurance policy.
The Personal Data that AXA ASSISTANCE asks you to provide are necessary for the proper use of the Mobile Application and related support services. Failure to provide these data may make it impossible or difficult to enter into or properly use the Mobile Application, its features and/or related support services.
PROCESSING OF HEALTH DATA
When your contract or policy involves the processing of data relating to your health, AXA ASSISTANCE guarantees compliance with the specific rules applicable to this type of processing, by taking all the technical and organisational measures required for this purpose.
- These data are only processed following the data subject’s express consent or, when the data subject is physically or legally unable to give consent, with a view to safeguarding the vital interests of the data subject.
- These data are processed under the supervision of physicians (consulting physicians), subject to medical secrecy, as well as by AXA ASSISTANCE employees specifically designated for this purpose.
- Medical certificates and other documents containing these data, which is necessary for the negotiation, entry into, or performance of the contract, including claims management, are only processed by specially authorised managers subject to enhanced confidentiality, under the supervision of medical advisers. Processing only concerns data relating to the current state of health of data subjects and which are strictly relevant with regard to the risk for which these documents have been drawn up.
- These data are only transferred when this proves necessary and the recipients provide sufficient guarantees to ensure compliance with the specific rules for their processing.
REQUIREMENT TO PROVIDE PERSONAL DATA
The data subject's personal data that AXA ASSISTANCE asks them to provide are necessary for entering into and performing the insurance contract. Failure to provide these data may make it impossible to enter into or properly perform the insurance contract.
DATA TRANSFER
Insofar as disclosure of personal data is necessary for the purposes listed above, AXA ASSISTANCE may transfer your Personal Data to other persons, whether other AXA Group companies or third parties to other AXA Group companies, or to companies and/or persons working with these companies (assistance service providers, lawyers, experts, medical advisers, reinsurers, co-insurers, insurance intermediaries, service providers, other insurance companies, representatives, pricing monitoring office, claims settlement offices, Datassur). The other AXA Group companies, companies and/or persons working with them to whom Personal Data are disclosed, may be located both within and outside the European Union.
In the event of personal data transfers to third parties located outside the European Union, AXA ASSISTANCE complies with the laws and regulations in force regarding such transfers. In particular, it ensures an adequate level of protection for personal data thus transferred through alternative mechanisms put in place by the European Commission, such as standard contractual clauses, or AXA Group's binding corporate rules in the event of intra-group transfers (Mon. B. 6/10/2014, p. 78547).
DATA RETENTION
AXA ASSISTANCE retains the personal data collected relating to the insurance contract for the entire duration of the contractual relationship or the management of the claim, updating them whenever required by circumstances, extended by the statutory retention period or the limitation period, in order to be able to respond to requests or any redress that may be initiated after the end of the contractual relationship or after the closure of the claim.
AXA ASSISTANCE undertakes to keep your Personal Data secure, confidential, and accurate for the period of use authorised herein. At the end of the retention period, your Personal Data will be anonymised or destroyed.
CONFIDENTIALITY
AXA ASSISTANCE has taken all necessary measures to preserve the confidentiality of Personal Data, and to protect itself against any unauthorised access, misuse, modification, or deletion thereof. As such, AXA ASSISTANCE complies with security and service continuity standards and regularly assesses the security level of its processes, systems, and applications as well as those of its partners.
RIGHTS OF THE DATA SUBJECT
You have the right to:
- Obtain confirmation from AXA ASSISTANCE as to whether or not Personal Data concerning you are being processed and, if so, to access such data,
- Have your Personal Data rectified and, if necessary, supplemented if they are inaccurate or incomplete,
- Have your Personal Data erased in certain circumstances,
- Restrict the processing of your Personal Data in certain circumstances,
- Object, for reasons relating to your specific situation, to the processing of your Personal Data, based on AXA ASSISTANCE’s legitimate interests. AXA ASSISTANCE no longer processes Personal Data unless it can demonstrate that there are compelling legitimate grounds for processing which override the interests and rights and freedoms of the data subject,
- Object to the processing of your Personal Data for direct marketing purposes, including profiling for direct marketing purposes,
- Not form the subject of a decision based solely on automated processing, including profiling, producing legal effects concerning or significantly affecting this decision. However, if such automated processing is necessary to enter into or perform a contract, you have the right to obtain human intervention from AXA ASSISTANCE, to express your point of view, and to challenge AXA ASSISTANCE’s decision,
- Receive your Personal Data provided to AXA ASSISTANCE in a structured, commonly used and machine-readable format; forward these data to another controller when (i) the processing of your Personal Data is based on your consent or for the purposes of performance of a contract, and (ii) the processing is carried out using automated processes; and arrange for your Personal Data to be forwarded directly from AXA ASSISTANCE to a controller, where technically possible,
- Withdraw your consent at any time, without prejudice to any processing activities carried out lawfully prior to the withdrawal of your consent, when the processing of your Personal Data is based on your consent.
CONTACTING AXA ASSISTANCE
You can contact AXA ASSISTANCE to exercise your rights at the following addresses. Your request must be accompanied by a photocopy of both sides of your identity card (or any identity document):
By post:
Data Protection Officer Inter Partner Assistance S.A.
Boulevard du Régent 7
B-1000 Brussels
By email:
dpo.bnl@axa-assistance.com
AXA ASSISTANCE will process requests within the time limits provided for by law. Unless the request is clearly unjustified or excessive, no payment will be required for the processing of your requests.
FILING A COMPLAINT
If you believe that AXA ASSISTANCE is failing to comply with the relevant regulations, you are invited to consult AXA ASSISTANCE as a first step. You can also file a complaint with the Data Protection Authority at the following address:
Data Protection Authority
Rue de la Presse, 35
B-1000 Brussels
Tel. +32 2 274 48 00
Email: contact@apd-gba.be
You can also file a complaint with the regional court corresponding to your address.