Privacy statement

1. ERGO Insurance S.A. respects your privacy

Ergo Insurance S.A. (ERGO) attaches great importance to the protection of privacy.

The personal data of the policyholder and the persons to be insured (together referred to as "data subjects") are processed by ERGO whose registered office is Loxumstraat 25 Rue de Loxum (1000 Brussels) in accordance with relevant Belgian and EU (hereinafter GDPR) Legal framework

The Data Protection Officer of ERGO can be contacted by post at: Rue de Loxum 25, 1000 Brussels and e-mail: privacy@ergo.be

2. Type of personal data

According to its internal privacy filings, ERGO processes the following types of personal data: Identification, Health, Localisation, Biometric, Education and interests, Financial, Consumer habits, Life habits, Housing, Profession, Household composition, Personal characteristics, Leasure and interests, Sound and image recordings.

3. Sources of data

ERGO obtains personal data through application, claims, other forms, telephone calls, emails and other communications means, from various sources, including:

policyholder, its representatives or personal relationship;
brokers, agents, claims investigators, witnesses;
Employer work relations;
medical professionals;
authorities; and
credit reference agencies.

4. Purposes and legal grounds

Personal data are processed for the following purposes and on the basis of the following legal grounds:

4.1. Purpose based on contract

ERGO processes personal data for the following insurance related purposes: all (pre)contractual and management obligations linked to the insurance contract, the customer relationship, the financial processing and potential outsourcing or (co)-reinsurance arrangements, including services or reporting within the ERGO Group, potentially including third parties.

4.2. Purpose based on consent

ERGO processes your data concerning health specifically for (i) drawing up an insurance application; (ii) issue and execution of the insurance contract, including risk assessment (which may also be the subject of a decision) and assessment of eligibility; (iii) fulfillment of pre-contractual and contractual obligations and obligations deriving from the insurance relationship with the Data Subject; (iv) management and settlement of claims and disbursements during the performance of the insurance contract; (v) recovery from third parties responsible for a claim; ((vi) possible litigation (vii) prevention, detection and investigation of insurance fraud and (viii) reinsurance purposes. This data (as well as that provided in the past) can only be processed with your consent. If you do not given your consent, the conclusion and/or proper performance of the insurance contract could be prevented without reimbursement of the insurance premium.

4.3. Purpose based on legitimate interests

ERGO processes personal data for the following purposes: fraud prevention, quality and security controls, training and marketing purposes.

4.4. Purpose based on legal provisions

ERGO processes personal data for the following purposes: all mandatory laws and regulations organizing identification and anti-money laundering, legal procedures, legal and regulatory obligations applicable to the financial sector and to commercial entities.

If necessary, data processing can be automated, under the supervision of a medical doctor, and with eventual manual intervention.

For purpose of communication on health related data, ERGO will send a copy of the relevant information to you or to your physician (medical data). Your physician can always communicate to the medical adviser of ERGO any medical certificate or report necessary for the proper assessment or execution of the contract. This information is limited to a description of the health status, including history at the time of the occurrence of the claim, to address the contractual provisions.

5. Automated Decisions

ERGO uses procedures for processing personal data, potentially including health related data, involving automated decisions affecting the conclusion or execution of contracts (e.g. online insurance subscription, claims management, etc.). You always have the right to human intervention, to express your views and to challenge the decision.

6. Data Retention

Personal data are retained for the duration of the agreement with ERGO and thereafter until the expiry of the legal retention obligations, in particular tax and accounting obligations and until the end of contractual liability.

7. Recipients

Beside the transfers related to mandatory laws and as necessary for the purposes indicated above, the personal and health related data may be communicated by ERGO to the following third parties:

The companies of the ERGO Group for reinsurance, financial and reporting purposes;
Processors located in the European Union or outside, on behalf of and under instructions of ERGO;

8. International transfer

ERGO does not currently allow transfer of Personal Data outside of the EU.

Data may be processed in EU or non-EU countries , including countries which are considered by the EU Commission as not guaranteeing an adequate level of protection of personal data.

In this case ERGO, as controller, will take appropriate measures to safeguard the personal data, including contracting with EU Standard Contractual Clauses and inform the customer accordingly.

9. Data Subject Rights

Upon written, signed and dated request, data subjects can, on their data: access, rectify and correct, erase, restrict or object to the processing, request portability, withdraw their consent.

The above rights may be subject to certain legal conditions, modalities or limits as set out in the GDPR.

In order to exercise your rights, please contact the Data Protection Officer of ERGO by post at Loksumstraat 25 Rue de Loxum, 1000 Brussels or by e-mail to privacy@ergo.be.

In accordance with Article 77 of the GDPR, you may also address or lodge a complaint with the Data Protection Authority at the following address: 1000 Brussels, Rue de la Presse, 35 (Tel. 32 2 274 48 00 - Fax + 32 2 274 48 35 - commission@privacycommission.be) or with the supervisory authority of the country of your habitual residence, for the exercise of your rights. You may also address or lodge a complaint with the “Autoriteit Persoonsgegevens” at the following address: Postbus 93374, 2509 AJ DEN HAAG (Tel. (+31) - (0)70 - 888 85 00).