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This Privacy Policy and Protection of Personal Data applies generally to the collection and processing of personal data provided by clients, potential clients, of the services provided, whether offline or online, by the Bónus Mediação de Seguros, Lda. at the Insurance and Pension Funds Supervisory Authority (ASF) under number NIF 511144768, with registered office at Av. Arriaga, 77, 2º Andar sala 205, Funchal from now on briefly referred to as “Bonus”, namely those collected through forms, websites, simulators, proposals, documents or other means, in paper or electronic form, intended to allow contact with the Bonus, also applying to the exercise of rights, by the data owner, in relation to them, in terms of applicable legislation, namely, but not limited to, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to it concerns the processing of personal data and the free movement of such data (GDPR). This POLICY is of a general and abstract nature, so the information provided in it can be supplemented or removed, totally or partially, by other policies, notices or more specific information that may have been or may be made available by the MEDIATOR in the context of certain types of processing of personal data.



Article 1


Responsible for the processing of personal data


The above-identified MEDIATOR, whose activity is regulated by Decree-Law No. 144/2006, of July 31, and corresponding regulations published by ASF and, depending on the respective category of insurance mediator, under the terms of the contracts, protocols, agreements or conventions established with the "INSURANCE COMPANIES" - companies that have received authorization from the competent authority of one of the Member States of the European Union to exercise the insurance activity -, from now on only "INSURERS", may have the most various forms and modes of relationship, business models and performance in relation to INSURERS, with a reflection on the purposes and means of processing personal data of the DATA HOLDER, being able, for this reason, to act, in what concerns the data protection legislation. regards, as “controller”, “subcontractor” or as “joint controller” of personal data, hereinafter only “PERSONAL DATA”, provided by the respective DATA HOLDER when filling in the DOCUMENTS, regardless of their support, directly or through someone else, or that have been generated by the MEDIATOR, either in the context of previous contacts, or in the celebration, execution, renewal or termination, through him, of the insurance contract or operation or that resulted from them and related to the DATA HOLDER, either in his capacity as policyholder, insured, beneficiary or his representative, and also to victims or third parties and their representatives. The provision, to the MEDIATOR, of PERSONAL DATA collected in the context of pre-contractual diligences or in the contracting process, in addition to the cases in which corresponds the information necessary to fulfill the MEDIATOR's legal and contractual obligations, constitutes a necessary requirement for pre -contracts and, well, for the conclusion of the insurance contract and its execution, through it, so, in the event that they are not provided to the MEDIATOR, the contract cannot be accepted by the INSURERS, with the intervention of the MEDIATOR . PERSONAL DATA will be treated by the MEDIATOR, as the case may be, either as "responsible for the treatment", "subcontractor" or as "jointly responsible for the treatment", for the purposes listed in article 4, below, in strict compliance with the provisions of current legislation on the protection of personal data.


Article 2


Data protection contact


The contact for the purposes of matters related to the protection of PERSONAL DATA can be made, in writing, to the following addresses:


Mail:


AT: RGPD Bónus Mediação de Seguros, Lda.


Av. Arriaga, 77, 2nd Floor room 205


9000-060 Funchal


E-mail:


rgpd@bonus-seguros.pt


Article 3


Processing of personal data


PERSONAL DATA provided in the relationship established with the MEDIATOR are treated in accordance with the legally applicable precepts, namely:


treated lawfully, fairly and transparently;


collected for specific, explicit and legitimate purposes and will not be further processed in a manner incompatible with those purposes;


appropriate, relevant and limited to what is necessary in relation to the purposes for which they are treated;


accurate and, if necessary, updated, and appropriate measures must be taken to ensure that inaccurate or incomplete data is erased or rectified, taking into account the purposes for which they were collected or processed later;


preserved in such a way as to permit the identification of their holders only for the period strictly necessary and within the legally permitted scope for the purposes of collection or further processing;


Article 4


Purposes, grounds for the processing and deadlines for the preservation of personal data


PERSONAL DATA are treated for the following purposes based, in each case, on the grounds indicated in the table below and are kept for the time strictly necessary for the pursuit of the same purposes, according to the deadlines (or criteria adopted to define them) indicated in the same table:




Purpose Basis of Licensing Term of Conservation


Necessary treatment for the execution and management of the insurance and insurance mediation contract, or for pre-contractual steps, with the intervention of the MEDIATOR. Presentation, proposal, execution and execution of the insurance contract, pre-contractual steps and support its management, especially in case of accident, with the intervention of the MEDIATOR.


Legitimate interest of the controller or third parties in the identification, risk assessment, information, clarification and advice of solutions and products.


CONSENT OF THE DATA HOLDER.


Compliance with legal and legal obligations. Until the statutory limitation period for all obligations arising from the insurance contract and related insurance mediation activity.


Prospecting and commercial action Consent of the DATA HOLDER.


Legitimate interests in developing and growing the activity of the controller or third parties. Until the end of one year on the end of the contractual and legal relationship.


Compliance with legal obligations, namely with the authorities, among others, of supervision, tax and fiscal or judicial. Compliance with legal and legal obligations.


Legitimate interests to control the activity of the controller or by third parties.


For declaration, exercise or defense of rights in judicial proceedings. Legal deadline applicable at all times for each legal and legal obligation to be met.


Until the expiry of the statute of limitations or lapse for the exercise of rights.

Article 5


Telephone call recording


In the telephone contacts established between the DATA HOLDER and the MEDIATOR, within the scope of their activity, the latter may proceed, if necessary, to record the calls, with prior information to the DATA HOLDER and with his consent, to manage the relationship pre-contractual and contractual, through the MEDIATOR, and compliance with legal and legal obligations, namely, as a means of proving information or instructions transmitted, as well as for improving the services offered or contracted, and also for quality control of the same. The call recordings will be kept for the periods indicated in the deliberations of the National Data Protection Commission (CNPD) that define the principles applicable to the treatment of call recording data, namely, Resolution 1039/2017.




Article 6


Health data


In the case of some risk coverage to be transferred from the DATA HOLDER's sphere (namely, health insurance, personal accident insurance or others), which fall under the category of special and sensitive data, the presentation, proposition, celebration or execution of the insurance contract, with the MEDIATOR's legal and / or contractual intervention, involves or may involve the processing of data relating to the health of the DATA HOLDER, either within the scope of the pre-contractual relationship, for identification, analysis of the proposed risk and fixing the contractual conditions, whether in terms of managing the contractual relationship, using the coverage, managing claims and, well, in renewal and contractual changes. The MEDIATOR proceeds with the processing of the data in question, whether as “controller”, “subcontractor” or as “joint controller”, for the purposes indicated above, with the consent of the DATA HOLDER or his representative, without prejudice to cases in which the treatment is based on another lawfulness basis (that is, for the purposes of fulfilling obligations and the exercise of specific rights of the MEDIATOR, INSURERS, third parties or the DATA HOLDER itself, in matters of labor law, social security and social protection insofar as such treatment is permitted by European Union or Member State law. Members or by a collective agreement that provides adequate guarantees of the fundamental rights and interests of the DATA HOLDER. to the health of the DATA HOLDER, without which it is impossible to carry out the analysis of the proposed risk, conclude the insurance contract, transfer er er the risk, place and accept the desired coverage or even keep the contract in force with the INSURERS.


Article 7


Data communication


PERSONAL DATA may be communicated to other companies that are in a controlling or controlling relationship (Group), already constituted or to be constituted, that the MEDIATOR integrates or will integrate, whose identification and contact data can be, at all times, requested to the Personal Data Protection Contact, as identified in article 2, above, and may be treated by other entities in relation to which the MEDIATOR shall, if applicable, as a “subcontractor” or “joint controller”, such as who the MEDIATOR has subcontracted its processing and also by its insurance co-mediators or People Directly Involved in the Insurance Mediation Activity (PDEAMS). PERSONAL DATA may also be dealt with by other INSURERS or intermediaries in the context of claim settlement.


For the purposes of the described purposes and in compliance with a legal obligation, PERSONAL DATA may be transmitted to judicial, administrative, supervisory or regulatory authorities, as well as to entities that lawfully carry out or compile data, preventive actions and combat fraud, market studies or statistical or technical-actuarial studies.


Article 8


Collection of data from other sources


The MEDIATOR may proceed with the collection of information regarding the DATA HOLDER that is considered relevant for the assessment of the risk to be insured and the INSURERS, with the intervention of the MEDIATOR, fixing the contractual conditions of the insurance, from sources accessible to the public, public bodies , industry associations, existing computer platforms or specialized companies, to complement or confirm the information provided by the DATA HOLDER, within the scope of the management of the pre-contractual and contractual insurance relationship, through the MEDIATOR, including the exercise of the activity insurance mediation under the terms of the specifically applicable legislation, within the framework of the fulfillment of the duties of information, clarification, transmission, advice, assistance and registration that are imposed by said legislation.


Article 9


Data subject's rights


The holder of PERSONAL DATA is entitled to request the MEDIATOR, and through him, the INSURERS, upon a written request addressed to the Personal Data Protection contact:


• Access, under the terms and conditions legally provided, to PERSONAL DATA that concern you and that are subject to treatment;


• The correction or updating of inaccurate or out-of-date PERSONAL DATA that respects it;


• The treatment of missing PERSONAL DATA when they are incomplete;


• The erasure, in the cases specifically provided for by law, of PERSONAL DATA concerning you;


• The limitation, verified the conditions foreseen in the law, of the treatment of PERSONAL DATA regarding it.


By written request, addressed to the Personal Data Protection contact, the DATA HOLDER is also entitled to:


• Withdraw the consent given, when the data processing is based only on consent;


• Oppose processing for reasons related to your particular situation, when data processing is based on the legitimate interest of the “controller” or third parties.


• Receive from the “controller,” “subcontractor” or “joint controller,” in digital format in current use and automatic reading, personal data that concerns him and that has been provided by him, processed by means automated on the basis of:


1. in consent provided by the DATA HOLDER or,

2. in a contract entered into, being able to request, in writing, the respective transmission directly to another responsible person, whenever this is technically possible.


The PERSONAL DATA holder can also request more detailed information from the Personal Data Protection contact, namely on the purposes, legal grounds and conservation deadlines and, as well, submit complaints about the way their PERSONAL DATA are processed, without prejudice to being able to do so, also with the National Data Protection Commission (CNPD).




Article 10


Security of personal data


The MEDIATOR takes appropriate technical and organizational measures to protect PERSONAL DATA against accidental or unlawful loss, destruction or damage, as well as to ensure that the data provided is protected against access or use by unauthorized third parties. The MEDIATOR guarantees privacy and security in the transmission of the data of its customers and visitors to its website and other computer platforms, if available.


Article 11


Automated decisions


Within the scope of subscription and renewal processes for insurance contracts or operations, INSURERS may resort to decision-making solutions by automated means that are necessary for the execution and execution of the respective insurance contract or operation, with the intervention of the MEDIATOR, with use of information, regarding the policyholder or insured, obtained in the framework of the management of the contractual or pre-contractual relationship from which decisions may be made regarding the contractual conditions applicable in the subscription or renewal. The PERSONAL DATA holder can also request, from the Personal Data Protection contact, more detailed information on the logic underlying the processes in question, in the context of contract subscription and renewal, through the MEDIATOR, namely, on the information taken into account, for exclusively automated decision-making and the way it integrates the INSURERS 'decision-making process. In all cases in which the INSURERS make decisions based exclusively on automated data processing, the respective processes will at least include mechanisms that give the data subject the possibility of:


(i) express your point of view;


(ii) contest the decision; and


(iii) request and obtain from INSURERS, directly or through the MEDIATOR, human intervention in the decision-making review process.


Article 12


Cookies


The MEDIATOR may use cookies on its website, if available, to improve the user experience and allow certain operations to be carried out safely.


Article 13


Changes to the privacy policy


This PRIVACY POLICY may be subject to periodic alteration, through publication on the MEDIATOR's website, if available, or by disclosure by any means of which written registration, including electronic or postal mail, without the need for prior and express consent of the DATA HOLDER.


Any changes of a significant nature will be communicated with the degree of publicity corresponding to their relevance, either by highlighting in the online publication, or, if the relevance justifies it, by means of individual communication to the DATA HOLDERS.

Contacts

Av Arriaga, 77, 2º andar - Sala 205 9000-060 Funchal

Contact

portugaltravelinsurance@bonus-seguros.pt
+351 915 555 944

Assistance UK

Luís Barros
+447 714 616 314