PRIVACY POLICY – EEA
About us
PIH Reel Media Specialty GmbH (“Reel Media”) (also referred to as “we”, “us”, or “our”) – Company no. 3080528. Registered address, Hohe Bleichen 820354 Hamburg, Deutschland. Court of registration, Hamburg HRB 183511, VAT ID, DE 363691014. Managing Directors Jon Wilkinson and Nikolaus Sühr. Parent Company Reel Media Holdings Ltd, Registered address 65 London Road, St Albans, Al1 1LJ, England. Registered in England, 16466021.
The purpose of this notice
This Notice is designed to help you understand what kind of information we collect in connection with our products and services and how we will process and use this information. In the course of providing you with products and services we will collect and process information that is commonly known as personal data.
This Notice describes how we collect, use, share, retain and safeguard personal data.
This Notice sets out your individual rights; we explain these later in the Notice but in summary these rights include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data.
We will process your personal data in line with:
· The General Data Protection Regulation (EU) 2016/679 (“GDPR”)
· The German Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG)
· The German Telecommunications-Telemedia Data Protection Act (TTDSG), where applicable in relation to electronic communications and cookies
What is personal data?
Personal data is information relating to an identified or identifiable natural person. Examples include an individual’s name, age, address, date of birth, their gender and contact details.
Personal data may contain information which is known as special categories of personal data. This may be information relating to an individual’s health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, or data relating to or sexual orientation.
Personal data may also contain data relating to criminal convictions and offences.
For the purposes of safeguarding and processing criminal conviction and offence data responsibly, this data is treated in the same manner as special categories of personal data, where we are legally required to comply with specific data processing requirements.
Personal data we collect
In order for us to arrange and administer insurance for you we will collect and process personal data about you. We will also collect your personal data where you request information about our services, customer events, promotions and campaigns.
We may also need to collect personal data relating to others in order to arrange and administer insurance. In most circumstances, you will provide us with this information. Where you disclose the personal data of others, you must ensure you are entitled to do so.
You may provide us with personal data when completing online quote or contact forms, when you contact us via the telephone, when writing to us directly or where we provide you with paper based forms for completion or we complete a form in conjunction with you.
We will share your personal data within our group of companies, business, including affiliates, subsidiaries and with business partners. This is normal practice within the insurance industry where it is necessary to share information in order to place, quantify and underwrite risks, to assess overall risk exposure and to process claims. It is also necessary to determine the premium payable and to administer our business.
We also share personal data with authorised third parties; this is necessary where we are required to do so by law, where we need to administer our business, to quote for, source, place and administer your insurances including arranging insurance premium finance, to perform underwriting activities and to process claims. Some examples are:
- Insurers;
- Underwriters;
- Premium finance providers;
- Credit reference agencies;
- Debt recovery agencies;
- Claims handling companies;
- Loss adjusters;
- Insurance brokers;
- Reinsurers;
We will collect your personal data when you visit our , where we will collect your unique online electronic identifier; this is commonly known as an IP address.
When you visit the website, and before the website places cookies on your computer, you will be presented with a message bar alerting you to the use of cookies.
We will also collect electronic personal data when you first visit our website where we will place a small text file that is commonly known as a cookie on your computer. Cookies are used to identify visitors and to simplify accessibility, and to monitor visitor behaviour when viewing website content, navigating our website and when using features. For more information, please see below.
Our website uses the following cookies:
services you should understand that you are forming a contract with us. If you contact us for a quote or request details on the services we provide, we consider ourselves as having a legitimate business interest to provide you with further information about our services.
In some situations, we may request your consent to market our products and services to you, to share your data or to transfer your data outside the European Economic Area. Where we require consent, your rights and what you are consenting to will be clearly communicated to you. Where you provide consent, you can withdraw this at any time by contacting our data protection officer:
By phone: 020 3805 1951 or +44 20 3805 1951 (from abroad)
We will retain your personal data at the end of any contractual agreement for a period of at least 7 . We will retain special category and criminal conviction data for a period of at least 7 years. Where you have submitted a claim, we will retain your data for a period of at least 7 years if it is a non-injury claim; where an individual has been injured (physical and physiological), we will retain your data for at least 7 years. Where you have requested a quote, we will retain your personal data for at least 12 months, where you have contacted us for details of our services and products, we will retain your personal data for at least 2 years. Where you make a complaint, we will retain the data for at least 7 years. Where you or law enforcement agencies inform us about any active investigation or potential criminal prosecution, we will comply with legal requirements when retaining this data.
The retaining of data is necessary where required for contractual, legal or regulatory purposes or for our legitimate business interests for statistical analysis (profiling) and product development and marketing purposes.
Sometimes we may need to retain your data for longer, for example if we are representing you or defending ourselves in a legal dispute or as required by law or where evidence exists that a future claim may occur.
We analyse data to identify products and services that customers may be interested in; this is commonly known as profiling. You have the right to object to the use of profiling activities and the use of automated decision making (services/tools and techniques).
Please contact us if you object to the use of, or you have any questions relating to the use of, your data, the retention of your personal data or the use of profiling and automated decision-making services/tools and techniques. You can opt out of receiving marketing services by e-mailing Privacy@RMSInternational.co.uk.
International transfers of personal data
Your rights
Individuals are provided with legal rights governing the use of their personal data. These grant individuals the right to understand what personal data relating to them is held, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing. Individuals can also request the deletion of their personal data.
These rights are known as Individual Rights under the General Data Protection Regulation. The following list details these rights:
- The right to be informed about the personal data being processed;
- The right of access to your personal data;
- The right to object to the processing of your personal data;
- The right to restrict the processing of your personal data;
- The right to rectification of your personal data;
- The right to erasure of your personal data;
- The right to data portability (to receive an electronic copy of your personal data);
- Rights relating to automated decision-making including profiling.
Individuals can exercise their Individual Rights at any time. As mandated by law we will not charge a fee to process these requests, however if your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee.
In exercising your Individual Rights, you should understand that in some situations we may be unable to fully meet your request, for example if you make a request for us to delete all your personal data, we may be required to retain some data for taxation, prevention of crime and for regulatory and other statutory purposes.
You should understand that when exercising your rights, a substantial public or vital interest may take precedence over any request you make. In addition, where these interests apply, we are required by law to grant access to this data for law enforcement, legal and/or health related matters.
The flow of data within the insurance sector is complex and we ask you to keep this in mind when exercising your ‘rights of access’ to your information. Where we may be reliant on other organisations to help satisfy your request this may impact on timescales.
If you require further information on your Individual Rights or you wish to exercise your Individual Rights, please contact our data protection officer:
By phone: 020 3805 1951
By email: Privacy@RMSInternational.com
By post: 68 King William St, London EC4N 7HR, United Kingdom
Protecting your data
We will take all appropriate technical and organisational steps to protect the confidentiality, integrity, availability and authenticity of your data, including when sharing your data within our group of companies, business, including affiliates, subsidiaries and authorised third parties.
Data Protection Officer/Data Privacy Representative
To comply with our legal obligations and to ensure data privacy and protection has appropriate focus within our organisation we have a Data Protection Officer who reports to our senior management team. The Data Protection Officer’s contact details are as follows:
By phone: 020 3805 1951
Complaints
If you, or any individual acting on your behalf, consider that the processing of personal data does not comply with applicable data protection laws or you wish to make a complaint, you an contact the Data Protection Office by using the contact details above.
Should you remain dissatisfied with how your data is being handled or wish to complain to the relevant regulator, please see below.
A complaint may be submitted to a supervisory authority in the European Union, in particular in the Member State of your habitual residence, place of work, or the place of the alleged infringement.
For organisations established in Germany, the competent supervisory authority is generally the data protection authority of the federal state (“Land”) in which the relevant entity is established. Further information on the competent authorities is available from the Federal Commissioner for Data Protection and Freedom of Information.
Website: https://www.bfdi.bund.de/DE/Home/home_node.html
Where you, or any individual acting on your behalf, are based outside Germany within the European Union, you may alternatively lodge a complaint with the supervisory authority in your country of habitual residence, place of work, or the place where the alleged infringement occurred.
A list of national supervisory authorities within the European Economic Area, together with their contact details, is available from the European Data Protection Board.
Website: https://www.edpb.europa.eu/edpb_en
How to contact us
If you have any questions regarding this Notice, the use of your data or your Individual Rights please contact our data protection officer:
By phone: 020 3805 1951