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Remember that you voluntarily provide us with your personal data (this means that providing personal data is not required by law). However, such data and information are necessary to provide our services. If you do not wish to provide us with the required information, it may prevent you from using our services.
Your privacy is important to us. We believe that careful handling of data is essential for long-term cooperation. That is why we try to offer our clients a high standard in the processing of personal data.
- WHO PROCESSES PERSONAL DATA?
Personal Data Administrator
MNK Re Polands sp. z o.o. with its registered office in Warsaw at ul. Prosta 20,, 00-805 Warsaw, registered in the Register of Entrepreneurs kept in the National Court Register kept by the District Court for the Capital City of Warsaw Warsaw, XIII Commercial Division of the National Court Register under KRS number 0000930921,, with share capital of PLN 1,000,000, NIP number 5272977504 (“MNK Re ), being an insurance agent entered in the Register of Insurance Agents kept by the Polish Financial Supervision Authority.
- WHAT DATA IS PROCESSED?
2.1 First of all, we process the personal data you have provided to us. These data are in particular:
(i) name and surname,
(iii) date of birth,
(iv) email address,
(v) telephone number,
2.2 Then we process the following data:
(i) about the period in which you used our services,
(ii) from third parties in connection with the concluded legal relationship (if any),
(iii) from publicly available records, i
(iv) from the so-called “cookies” and other similar technologies (further information on “cookies” is included in point 8 below).
- FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS ARE PERSONAL DATA PROCESSED?
3.1 First, we process personal data of both you and third parties, i.e. persons whose data you have provided to us (these persons are also referred to as insured or beneficiaries):
(i) it is necessary to exercise the right or fulfill the obligation resulting from the law;
(ii) it is necessary for the performance of the contract when the data subject is a party to it or when it is necessary to take action before concluding the contract at the request of the data subject;
(iii) it is necessary to perform tasks defined by law for the public good;
(iv) it is necessary to fulfill legally justified purposes pursued by data controllers or data recipients, and the processing does not violate the rights and freedoms of the data subject.
Such data processing results from the law (i.e. your consent is not required).
3.2 In addition, we process your personal data for the following purposes for which your consent is required:
(v) advertising purposes (ours and third parties),
(vi) product surveys,
(vii) data analytics and profiling,
(viii) statistical purposes,
(ix) monitoring and analyzing trends and usage,
(x) to improve ad targeting and measurement,
(xi) assessment of the quality of services provided, and
(xii) to personalize and thus personalize the customer experience.
Data processing related to visiting our website
3.3 Providing personal data is not necessary to gain access to information available to everyone, published on the website. The data protection provisions related to the use of the website are contained in a separate cookie regulation. (see point 7 below).
Data obtained during contact with customers
3.4 The legal basis for the processing of data related to personal data provided on the contact page is the voluntary consent of the person concerned. Personal data may be processed primarily if the person – voluntarily, without any doubts – agrees to it.
3.5 The purpose of processing the data provided via the website is to regularly provide information by phone and/or e-mail about insurance products offered through MNK Re , including in particular providing information about special offers and promotions.
Data processing in connection with the performance of insurance contracts, consideration of insurance claims and consideration of complaints
3.6 The basis for the processing of data related to the consideration of insurance claims and the consideration of complaints is the Act of August 5, 2015 on the consideration of complaints by financial market entities and the Financial Ombudsman.
3.7 The purpose of data processing may be:
(i) Performance of obligations and rights arising from the contract,
(ii) Performing insurance mediation,
(iii) Identification and verification of the client or his proxy,
(iv) Protection and enforcement of rights against the client,
(v) Documenting our activities,
(vi) Government oversight i
(vii) Performing activities in accordance with applicable laws.
Data processing to acquire new customers
3.8 MNK Re. conducts direct activities related to acquiring customers (direct marketing) based on the voluntary consent of the person concerned, which takes place during data collection.
3.9 The purpose of data processing is to enable data processors to initiate personalized inquiries for direct customer acquisition and, on the other hand, to be able to send advertising material to interested persons via e-mail, post or via any other personal communication device to interested persons.
- HOW CAN WE SHARE PERSONAL DATA?
We may share information about you in the following ways:
4.1 We may entrust the processing of personal data to third parties – subcontractors based in the European Union or in the European Economic Community. We will conclude a written data processing contract with each subcontractor. The contract will oblige the subcontractor to perform the contract in accordance with applicable law and to process personal data in a manner that ensures the highest standards, to the same extent as we process.
4.2. Personal data may be transferred to a third country (outside the European economic zone), including countries for which the European Union has not issued a decision on an adequate level of personal data security. In such a case, personal data will be transferred in accordance with the applicable law, while maintaining appropriate standards of personal data security in accordance with the clauses issued by the European Union.
4.3. Third party service providers include healthcare professionals, security professionals, accountants, actuaries, auditors, experts, lawyers and other external professional advisors; travel and medical assistance providers; call center service providers; providers of services related to IT systems, providers of support and hosting services; providers of printing, advertising, marketing and market research services and analysis services; banks and financial institutions servicing our bank accounts; independent claims adjusters; records management providers; construction consultants; engineers; examiners; translators; and other service providers who help us run our business.
Transfer of personal data outside of Poland (within the group)
4.4 We may share your personal information with other entities within the MNK Re Group for the same purposes as set out in section 3.1 above. All entities belonging to the MNK Re Group act in accordance with the law, maintaining the highest standards and process personal data to the same extent as we do.
4.5 In each place where personal data is processed, appropriate technical and organizational measures are used to protect personal data.
For legal purposes
4.6 We may transfer or disclose data without your consent to competent state administration authorities, police, courts and other entities authorized by applicable law.
- HOW DO WE SECURE PERSONAL DATA?
5.1 When processing personal data, we choose methods that are appropriate to the purpose for which the data is processed.
5.2 Access to personal data is available only to authorized persons who, within the scope of their official duties, include the processing of personal data. Access to data is only to the extent necessary for the purpose and nature of the data being processed.
5.3 Before granting access to personal data, each of our employees is properly trained in the protection of personal data.
Technical security of documents and other data carriers
5.4 All documents and other data carriers that we have and that contain personal data are legally protected against access by unauthorized third parties. This includes in particular: storing documents in locked cabinets and in fire-protected and lockable rooms located at our headquarters or in other appropriate and equally secure locations.
Technical security of electronically processed data
5.5 Personal data is stored electronically on a secure cloud computing platform.
5.6 The IT system contains an electronic log that identifies and records when, by whom and why personal data was accessed or otherwise processed.
5.7 Data files are backed up daily and backups are regularly overwritten.
5.8 In the case of repair of IT systems, repairs will be carried out only by trustworthy persons and obliged to comply with obligations and the law in the field of confidentiality with the threat of paying a contractual penalty.
- HOW LONG ARE PERSONAL DATA PROCESSED?
6.1 We ensure that the collected personal data is processed in a form that allows the identification of data subjects for a period not exceeding the time necessary to achieve the purpose of processing. First of all, this means that we process your data during the term of the contract concluded through us and any additional period required to protect and enforce rights and obligations and comply with applicable laws. In addition, specific legal provisions applicable to our business require us to keep records of certain data for a longer period of time, in particular to enable the relevant state administration authorities to perform their tasks.
- WHAT ARE COOKIES?
- WHAT ARE YOUR RIGHTS?
8.1 You can revoke your consent to the processing of your data and/or the sending of marketing and advertising information at any time by sending an e-mail to the following e-mail address: firstname.lastname@example.org or to the following contact address: MNK Re Poland ul. Prosta 20,, 00-805 Warsaw. Withdrawal of consent will not result in any costs, except for data transmission costs depending on the telephone / Internet / postal service provider.
8.2 In addition, you may request in writing:
- a) Confirmation whether your data is or is not being processed,
- b) Information about the processing status (automated or manual) of your personal data in the data set,
- c) Information about the source from which we obtained your data,
- d) Information on the scope of data that is processed,
- e) Information about the need to correct and change your data,
- f) Deletion of your data if the purpose of their processing has been achieved,
- g) Deletion of your data if their processing was unlawful,
- h) Blocking your personal data as a result of withdrawing consent to their processing, if the withdrawal occurred before the purpose of data processing was achieved.
Specific rights are regulated in the relevant legal provisions.
8.3 If you request information about whether and how we process your personal data, we will provide this information within 30 days of your request. If you request the processing of a list of your personal data, we are entitled to adequate compensation for the costs associated with making copies, ordering technical media and sending you information.
8.4 Information provided in accordance with section 8.2 of this Policy will contain the following statements
- a) The purpose for which the data will be processed,
- b) Personal data, if necessary, categories of personal data that will be processed e and full information about the source of data acquisition,
- c) Whether the provision of data is mandatory or voluntary,
8.5 If you find that we or a subcontractor acting on the basis of our order process it contrary to their purpose, contrary to the law or without a legal basis, you can:
(i) Request information/explanation from us or a subcontractor;
(ii) Require us or a subcontractor to correct errors. This in particular includes changing, supplementing or deleting personal data;
(iii) Contact the Data Protection Officer directly.
8.6 If your request turns out to be justified, we will correct the error or have the sub-contractor correct the error.
8.7 If you suffer damage in connection with the processing of your data, you have the right to obtain compensation in court.