Personal Data Protection Policy Forsea’s

Preamble

 Forsea’s the company attaches the greatest importance to the protection of the personal data and privacy of its customers and of anyone who accesses its websites and applications (hereinafter referred to as “Sites”).

All operations on your personal data are carried out in compliance with the regulations in force and, in particular, with the Law No 78-17 “Informatique et Libertés” (French Data Protection Act) dated 6 January 1978 as amended and the Regulation No 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.

This Privacy Policy (hereinafter referred to as “Policy”) describes how Forsea’s (hereinafter “Forsea’s” or “we”) processes the personal data of insured persons and their beneficiaries, customers and employees, any physical person or legal entity entering into a commercial or non-commercial relationship with Forsea’s, and any other Internet user who accesses the Sites (hereinafter referred to as “the User” or “you”).

 Article 1. Definitions

Terms and expressions beginning with a capital letter, whether used in the singular or plural, shall have the following meanings:

“Personal data”: any information relating to a natural person who can be directly or indirectly identified or identifiable, by referring to an identification number or to one or more elements that are specific to them.

“Processing of personal data”: any operation or set of operations performed using processes that may or may not be automated, applied to personal data, such as the collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, or disclosure by transmission, dissemination or otherwise making available, alignment or combination, erasure or destruction, etc.

“Controller”: physical person or legal entity, the public authority, the service or whatever other body that, alone or jointly with others, collects and processes of personal data.

“Recipient”: physical person or legal entity authorized to obtain the communication of data recorded in a file or a treatment because of its functions.

“Services”: services provided by Forsea’s, in particular through the Sites.

 

Article 2. Scope

Forsea’s carries on an e-commerce activity under of French law n°2004-575 of 21 June 2004 on confidence in the digital economy.

The purpose of this Policy is to inform Users of the way in which their personal data are collected and processed by Forsea’s.

Article 3. Identity of the data controller

Personal data are collected by Forsea’s, SA with a share capital of CHF 102,000, registered RC GENEVA under the number Fed : CH660-2872010-1, head office is located at 1-3 Rue Chantepoulet 1201 Geneva Switzerland, represented by Benoît Lecat, in his capacity as Chief Executive.

Article 4. Purposes and legal basis of data processing

In the context of the operation of the Sites and / or the provision of the Services, Forsea’s is required to collect and process Users’ personal data for the purposes and legal bases described below:

Purpose of date processing  

Legal basis

 

Signing, management and execution of contracts with our clients (from the pre-contractual phase to termination of the contract) Execution of pre-contractual or contractual measures
Study of the specific needs of the client / insured
Execution of contract guarantees
Invoicing management, monitoring of unpaid invoices and their collection
Exercise of appeals and the management of claims and litigation
Examination, acceptance, pricing, risk monitoring
Development and analysis of statistics and actuarial studies
Compilation of files for trade statistics purposes
Management of requests related to the exercise of your rights
Customer relationship management (invitation to events and management of their participation, conduct of satisfaction surveys, etc.) Legitimate interest of the controller
Management of access of the Sites and their use
Realization of statistics and measures of frequentation of the Sites
Management and improvement of the commercial relationship and / or our Services
Sending of newsletters, solicitations and promotional messages to customers
Processing of applications through the recruitment form Express and specific consent of Users (*)
Sending newsletters, solicitations and promotional messages to non-client prospects
Commercial management of non-customer prospects
Fight against money laundering and terrorist financing with the establishment of a monitoring system that can lead to a suspicious transaction report Compliance with a legal, regulatory or administrative obligation to which the controller is subject
Fight against fraud which may lead to registration on a list of persons at risk of fraud

(*)This consent may be withdrawn at any time by the User.

When collecting data, the User will be informed if certain data must be filled in or if they are optional by means of an asterisk. The mandatory information we ask you to provide is necessary to provide the expected service. If you do not provide them to us, Forsea’s may be prevented from responding to the request or form in question.

Article 5. Nature of the data processed

Forsea’s may have to collect the following data:

  • data relating to your civil status: surname, first names, address, telephone number (fixed or mobile), fax number, postal and e-mail address, date and place of birth, sex, internal processing code allowing the identification of the client (this internal processing code is separate from the registration number in the national register for the identification of natural persons, the social security number and the bank card number);
  • data relating to the professional situation (profession, socio-professional category, employer);
  • data relating to your personal life (family situation: marital status, matrimonial regime, number of children, etc.);
  • data relating to economic and financial information (means of payment, direct debit authorization, RIB);
  • connection data, particularly when using our online services (IP addresses, logs, terminal identifiers, connection identifiers);
  • data necessary to combat fraud, money laundering and terrorist financing;
  • contact data relating to newsletter subscriptions: name, first name, address, telephone number (fixed or mobile), fax number;
  • data relating to offences, convictions and security measures;
  • data on the location and geolocation of persons in relation to the insured risks or services offered;
  • data relating to the determination or assessment of damages and benefits (victim data, health reimbursement data, description of physical injuries, production of medical certificates, medical questionnaires);
  • data relating to your health for certain insurance contracts;
  • social security number (in the context of the conclusion of certain insurance or mutual health insurance contracts).

If you provide us with third party contact information, please ensure that you ensure that this Policy is communicated to such third parties before you disclose their data to Forsea’s.

Article 6. Data collection

Data is collected:

  • either directly with you through a contact, membership or subscription form for one of our Services ;
  • or from persons interested in the contract (subscriber of an insurance contract, employers of insured persons or employees who benefit from the services subscribed by the latter) ;
  • or with the persons involved in the contract (experts, victims, etc.);
  • either with our commercial partners (insurers, reinsurers, brokers, business indicators, subcontractors);
  • or with the staff of Delta Insurance Group.

Article 7. Data recipients

Within the strict framework of the stated purposes and where necessary, the recipients of the data collected are:

  • the various departments and entities of the Delta Assurances Group in the course of carrying out their missions;
  • insurance companies, insurance distributors, banking and credit institutions, social organizations, health professionals, healthcare and third-party payment networks;
  • subcontractors and service providers of Forsea’s;
  • persons interested in the contract (person in charge, victims, witnesses, third parties interested in the execution of the contract);
  • some regulated professions such as lawyers, notaries, auditors, consultants.

In the event that Forsea’s entrusts the data processing activities to subcontractors, the latter will be chosen in particular for sufficient guarantees as to the implementation of appropriate technical and organizational measures, in particular in terms of reliability and security measures.

Article 8. Transfers of data to public authorities and agencies

In compliance with the rules or Regulation in force, the data may be transmitted to the competent authorities at their request and in particular to public agencies, exclusively to meet legal obligations, court officers, ministerial officers and authorities responsible for debt recovery.

Article 9. Transfers of data to third countries or international organizations

In the event of the transfer of personal data for the purposes described above between Member States or non-member States of the European Economic Area and when this is essential for the provision of its Services or in order to meet its legal obligations, Forsea’s undertakes to use third parties located in a country considered by the European Commission as ensuring an adequate level of protection.

If the third party is not located in a country considered by the European Commission to ensure an adequate level of protection, Forsea’s then contractually fixes compliance with data protection and information security provisions with the recipients concerned and takes all necessary measures to ensure that guarantees are strictly observed by third parties.

Article 10. Data stored period

Forsea’s will keep the User’s personal data in a secure environment for as long as necessary to achieve the purposes for which they were collected or for the minimum retention period provided for by applicable legislation, in particular in civil and commercial matters.

Some personal data may be stored by Forsea’s for longer periods of time exclusively for archival or statistical purposes.

Data processed in the context of prospecting operations with the User’s consent may not be kept for more than 3 years after the last contact made by the User or in the context of his opposition.

Article 11. Social networks

If the User has an account on social network sites and accesses the Sites without first registering for the Service, Forsea’s may receive information from said social networks to facilitate the creation of an account on the Sites.

When the User uses a Service via a social network site, the User authorizes Forsea’s to collect, store and use all the information he or she has provided to the social network site, such as his or her username, surname and first name, profile image and data relating to the use of this Service.

Article 12. Personal data concerning minors

The Forsea’s Sites are not intended for minors under fifteen (15) years of age.

If you are under fifteen (15) years old, we ask you not to provide any personal data via the Forsea’s Sites.

Article 13. Cookies

The User is informed, when first browsing the Sites, by means of a banner that appears on the page accessing the Sites, that, when connecting to the Sites and when using the Services, cookies or other technologies are used, subject to the choice expressed by the User; this choice may be modified at any time.

A cookie allows its issuer, during its validity period, to recognize the relevant terminal (computer, tablet, smartphone, etc.) each time it accesses digital content containing cookies from the same transmitter. A cookie records information about the User’s computer’s browsing on our Sites (the pages visited, the date and time of the visit, etc.) that we may read during subsequent visits.

These cookies facilitate navigation and improve the user-friendliness of the Site. The User may refuse the recording of cookies by configuring the settings of his browser, as indicated below. Access to certain services and sections of the Sites may, in this case, be altered or even impossible.

Several types of cookies may be used by the Site:

cookies strictly necessary for navigation on the site and to guarantee its proper functioning;

  • cookies strictly necessary for navigation on the site and to guarantee its proper functioning;
  • cookies which allow to establish statistics of frequentation;
  • advertising cookies, which make it possible to provide offers related to the User’s interests.
  1. a) Cookies for browsing the Site

Browsing cookies improve the performance of the Services in order to provide the User with a better use of the Site. These cookies do not require the prior information and consent of the User to be placed on the User’s terminal.

More precisely, these navigation cookies allow you to:

  • adapt the presentation of the Site to the display preferences of the terminal (language used, display resolution, operating system used, etc.) when Users visit the Site, depending on the display or reading hardware and software that the terminal contains;
  • to access a reserved area with a login and password;
  • to store information relating to the form that the User has filled in on the Site or information that the User has chosen on the Site;
  • to offer the User access to his account or any other space reserved through his identifiers;
  • to implement security measures, for example when the User is asked to reconnect to content or a Service after a certain period of time has elapsed.
  1. b) Audience measurement cookies

Audience measurement cookies help to establish statistics and volumes of visits and use of the various elements composing the Site (sections and content visited, browsing), allowing Forsea’s to improve the interest and ergonomics of the Services.

  1. c) Advertising cookies

Advertising cookies allow to determine in real time which advertising to display according to the recent browsing of the User on the Site in order to limit the number of times the User has seen an advertisement and to help measure the effectiveness of advertising campaign.

Advertising content may contain cookies issued by third parties: either the advertiser at the origin of the advertising content concerned, or a third-party company to the advertiser (communication consulting agency, audience measurement company, service provider). targeted advertising, etc.) or advertising agency, which has associated a cookie with the advertising content of an advertiser.

  1. d) Google Analytics and Privacy

This Site uses a web analysis service provided by Google Inc. (“Google”).

Google Analytics uses “cookies”, text files stored on the User’s computer that allow an analysis of the use of the Site.

The information generated by cookies about the use of this website is transmitted to and stored on a Google server in the United States. Google uses this information to evaluate the use of the website, to compile reports on website activity for website operators and to provide other services related to website and Internet usage. Google may also transfer this information to third parties where required to do so by law or where such data is processed by third parties on Google’s behalf. Under no circumstances will the User’s IP address be associated with other Google data. The User may disable cookies by modifying the settings of his browser; in which case he will not be able to use all the functions of this website. The User may at any time cancel the collection and storage of data by Google Analytics for the period following the time of cancellation, by downloading a Browser-Add-on to disable Google Analytics and installing it for his browser. The Add-on for deactivation can be found at[http://tools.google.com/dlpage/gaoptout?hl=fr].

The User may configure his browser software in such a way that cookies are stored in the terminal or, on the contrary, that they are rejected, either systematically or according to their issuer. The User may also configure his browser software in such a way that the acceptance or rejection of cookies is offered to him from time to time, before a Cookie is likely to be saved in his terminal.

For the management of cookies and User choices, the configuration of each browser is different. It is described in the browser’s help menu, which will tell you how to change your cookie preferences:

For Internet Explorer™ https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

For Safari™ https://support.apple.com/fr-fr/guide/safari/sfri11471/mac

For Chrome™ https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en

For Firefox™ https://support.mozilla.org/fr/kb/autoriser-bloquer-cookies-preferences-sites?redirectlocale=fr&redirectslug=Activer+and+d%C3%A9sactivate+cookies

For Opera™ https://help.opera.com/en/opera-tutorials/turn-on-operas-ad-blocker/

  1. e) Storage period

The length of time cookies are stored varies depending on the type of cookie. Most of us use cookies that self-destruct after the connection has ended. In this case, they are called session or navigation cookies. A log file also allows us to log all accesses to our web pages or downloads of the various files available on our sites for a period of 6 months. Finally, information concerning the User’s consent to cookies is stored for a maximum period of 13 months. Cookies are used for internal use and are not accessible to a third party.

Article 14. Right of persons

In accordance with Law No. 78-17 of 6 January 1978 as amended and Regulation (EU) 2016/679 on the protection of personal data, the User has the following rights on his data : right of access, right of rectification, right to erasure (right to forget), right of opposition, right to limit processing, right to portability.

The User may also define guidelines for the storage, erasure and communication of his personal data after his death.

For reasons relating to his particular situation, the User may object to the processing of data concerning him.

To exercise these rights, please send a letter with acknowledgment of receipt to the following address: Forsea’s 1-3 Rue Chantepoulet 1201 Geneva Switzerland. We recommend that you attach a proof of identity.

Subject to a breach of the above provisions, the User has the right to file a complaint with the CNIL www.cnil.fr.

Article 15. Security measures

Taking into account technological developments, implementation costs, the nature of the data to be protected and the risks to individuals’ rights and freedoms, Forsea’s shall implement all appropriate technical and organizational measures to ensure the confidentiality of the personal data collected and processed and a level of security appropriate to the risk.

Article 16. Changes in Privacy Policy

If this Policy need to be modified by Forsea’s or to comply with Regulation, it will be published on the Sites and will be effective upon its publication. Therefore, we encourage you to review this Policy posted on this Site for possible changes, and to do so each time you return to the Site.

The version had been updated on 07/10/2019.

For any information on the protection of personal data, you can also consult the website of the Commission Nationale de l’Informatique et des Libertés (CNIL) www.cnil.fr

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