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1. WHO ARE WE?
Welcome to our website, where as its owner Homebrella is responsible for the handling of your personal data.
Homebrella is a trademark of ADMIRAL INTERMEDIARY SERVICES SA.
AIS SA is a branch of AIS, a Spanish company and intermediary in insurance transactions, Spanish trade registry number A90354911, regulated by the DGSFP (Direccion General de Seguros y Fondos de Pensiones). AIS SA is an indirect subsidiary of Admiral Group plc (www.admiralgroup.co.uk).
The headquarters of AIS SA is located at Calle Albert Einstein 10, 41092 Seville, Spain. The company is authorised to operate in mainland France and is registered with Orias (www.orias.fr) under the number AJ-0213. AIS SA is also registered at the Lille Métropole trade registry under the number 842 188 310. AIS SA is domiciled at 9-10 Rue de l’Abbé Stahl, 59700, Marcq-en-Barœul.
By providing us with your personal data, you consent to us using it. When you provide us with the personal data of third parties, you are confirming that you have previously obtained their consent.
We take the necessary steps to ensure a level of security for your personal data, in connection with and in accordance with the law n ° 78-17 of January 6, 1978, known as “The Data Protection Act” modified in 2004 and the new European regulations, the GDPR (General Data Protection Regulation No. 2016/79 of 27 April 2016), applicable since 25 May 2018.
Other data controllers
We are responsible for the handling of the personal data which we collect about you, including via our website. This means that Homebrella is responsible for the way your data is processed. According to your guarantees your data will also be handled by the following controllers, without whom we would not be able to provide or offer our products or services.
Insurance cover is provided by:
Admiral Europe Compania de Seguros, an insurance company registered in Spain under the number A87987822, whose registered office address is AECS, Calle Sanchez Pacheco 85, 28002 Madrid, Spain. AECS is supervised by the Direccion General de Seguros y Fondos de Pensiones located at Paseo de la Castellana 44, 28046 Madrid, Spain. AECS is a wholly-owned subsidiary of Admiral Group plc.
The authority responsible for supervising insurance companies operating in France is the ACPR (Autorité de contrôle prudentiel et de résolution), located at 4, place de Budapest, CS92459, 75436 Paris Cedex 09.
Assistance services are provided by:
EUROP ASSISTANCE, a French limited company with capital of 35,402,786 euros, a company governed by the French Insurance Code, Nanterre trade registry number 451 366 405, located at 1 promenade de la Bonnette, 92230 Gennevilliers.
Claims are handled by:
CELLINKS – a simplified joint stock company with capital of 100,000 euros. Cellinks is a legal insurance representative registered with the Paris Trade and Companies Registry under number 841 215 791, located at 37 rue de la Victoire, 75009 Paris.
SPB – a simplified joint stock company with capital of 1,000,000 euros, registered with the Paris Trade and Companies Registry under number 305 109 779, registered with the Insurance Intermediaries Registry as a broker under number 07 002 642, located at 71, Quai Colbert 76600 Le Havre.
2. WHAT DATA DO WE COLLECT?
Your data is collected directly from you when you do a quote on our website. The information requested during the quote must be given, without it we cannot offer you a quote.
Examples of data we collect:
- Full name
- Post/Zip code
- Contact information (phone number and email address)
- Date of birth
- Your home features
- The value of your home contents
Special categories of personal data
- Data concerning your health and medical history in the event of a bodily injury
As part of our effort to improve the quality of our services and the training of our employees as well as fulfilling our legal obligations your telephone calls with our call centres may be recorded and listened to. The same goes for emails, SMS and any other exchange between us and yourself.
From the use of our website and our products and/ or services
We collect data about you from your activities, such as how you use our website or services. This allows us to provide you with the best possible experience on our website as well as offers and services tailored to your needs and to work towards their improvement.
3. WHEN DO WE COLLECT YOUR PERSONAL DATA?
We collect information that you provide us voluntarily, including when
- You do a quote on our site;
- You buy your insurance online and make a payment;
- You browse our site, view our products and use our services;
- You participate in a game or contest;
- You contact our customer services;
- You request to be contacted by an advisor;
- You make a claim.
4. HOW DO WE USE YOUR PERSONAL DATA?
We use your data in connection within the provision of our insurance products and services:
For generating quotes. For example, the estimation, selection and pricing of risks associated with the residence. If you have made several quotes, or if you are a current or former customer, the quote data or previous insurance policies may be used for pricing;
For the transfer, management and execution of insurance contracts: for example, the collection of policy data, the verification of the insured’s identity if necessary, changes to the contract, coverage, or banking information, or the outsourcing of services related to the activity of insurance;
For the renewal of your insurance contract.
In order to provide you with continuous insurance cover, we will organise the automatic renewal of your contract each year. However before the automatic renewal of your insurance policy a renewal notice will be sent to you each year, which will remind you of the features of the policy, the new premium and the renewal date.
In accordance with the Terms and Conditions of the policy taken out with Homebrella the subscriber must inform the insurer, as soon as they are aware of any new circumstance likely to modify their risk profile as a customer and thus rendering the original information on the contract inaccurate or obsolete.
To communicate with you about our products, services and news.
We may use your personal data to inform you of our promotional offers and our new products and services by email, SMS, and phone, or through social media when we are legally able to do so and you do not oppose it.
If you no longer wish to receive these communications, you can:
- Unsubscribe yourself from our promotional emails by clicking on the automatic unsubscribe link at the bottom of each email;
- Use the STOP SMS feature to stop receiving our offers by SMS
- Email us at: firstname.lastname@example.org
We also advertise online to keep you informed about our activities, products and services, as well as to help you easily access our services. As with many other businesses, when browsing other websites or apps, you may find Homebrella banners and online ads.
With the purpose of legitimate interests
Sometimes the processing of your personal data is necessary for the legitimate interests we pursue as a business. These may be business or social purposes that require the processing of your data. In this case we will always make sure to strike a balance between our interests based on your reasonable expectations and your relationship with our entity.
For example, we base ourselves on the legitimate interest in the following:
- Homebrella is a brand of Admiral Group, we might occasionally transmit personal data to other companies in the group.
- Conducting actuarial and claims studies for risk selection;
- Refining and improving our pricing models for more accurate premiums;
- Consulting of files of interest (including publicly available sources) for risk analysis;
- Exchanging personal data between the insurance companies mentioned in the contract (Admiral, Europ Assistance, Cellinks …) for statistical and actuarial studies;
- Defining provisions for physical and bodily losses;
- Certain marketing activities;
- Developing trade statistics;
- Interacting with you throughout the life of your contract to ensure that you have the best possible experience as a Homebrella customer;
- Improving your user experience on our site and to allow you to fully benefit from all of its features and services;
- All activities related to research and analysis that allow us to review, develop and improve the services we offer you;
- Conducting audits of our internal procedures to maintain our high standards;
- Exchanging data with providers of choice to add value to our products;
- Centralising the management of intra-group IT resources (software, servers, etc.);
- Preventing unauthorized use of our telecommunication systems and our website;
- Ensuring the smooth running of our operations;
- Profiling for actuarial purposes and market analysis: through computer technologies we may use your data to create profiles, for example to determine which products are best suited to your needs;
- Preventing and detecting fraud (internal and external), but also the investigation and validation of data.
In order to prevent and detect fraud, other insurers may share information about you with members of the Admiral Group at any time. If any information provided is false or inaccurate and fraud is identified, our entity and other organisations may access and use it for fraud prevention purposes.
5. CONFIDENTIALITY AND DISCLOSURE OF YOUR DATA
We will endeavour to treat your personal data as private and confidential. From time to time we may employ agents and subcontractors to process your personal data on our behalf. The same duty of confidentiality and security will apply to them and all processing will be carried out under our instruction.
The collected data may be communicated to other entities, for example:
- As part of our services. For example if you pay by credit card, we send your data to a provider to query your bank and validate your payment.
- To any other insurer, collaborator or third party provider who, due to co-insurance, the management of claims, payments, for the purpose of statistical studies or to counter fraud, would be involved in the handling of claims or the insurance contract.
- In the event of a claim, we will need to exchange some of your data with third parties such as: third parties involved in the incident and their insurer, their lawyer or their representative, medical teams, police and investigators.
- If the mediator or the competent authority is held following a complaint, we may be required to give them your personal information.
- In the event that our organisation undergoes a restructure or is sold to another organisation, in which case you consent that all personal data held by our company is transferred to the new organisation.
- We may disclose your data in exceptional circumstances, such as where we are required by law or other legal process, or where you have made the request or have given your consent.
6. YOUR RIGHTS REGARDING YOUR PERSONAL DATA
In accordance with Articles 12 to 22 of Regulation (EU) 2016/679 (RGPD), you have rights as a data subject, including access, rectification, opposition, deletion, limitation of processing and portability of your personal data. You can exercise these rights by writing to: email@example.com.
Please note that these rights do not apply in all circumstances.
Your rights as a data subject, where applicable, include:
- The right to be informed on the handling of your personal data, including what data is collected, the purposes of the processing and the identity of the controller;
- The right of access to your personal data. If your request relates to someone else’s personal data, or if you are applying on behalf of someone else (for example, your minor child), we may ask you for a copy of the document person’s identity and a letter of authorisation signed by him or her;
- The right to rectify your personal data if it is inaccurate or incomplete;
- The right to erase your personal data (“right to be forgotten”);
- The right to limit the processing of your personal data;
- The right to portability of your personal data. This is the right to receive your data in a structured format, commonly used and machine readable, in particular to pass it on to another controller or to ask us to pass it directly onto another provider;
- The right to object to the processing of your personal data;
- The right not to be the subject of a decision based exclusively on automated processing, including profiling, that leads to legal consequences that implicate you or affect you in a similar way.
All requests should be sent to: firstname.lastname@example.org.
In order to allow us to process your request as soon as possible, please send us the following information:
- Your policy number
- Your full name
- Your email address
- Your telephone number
- The subject of your request
- A description of your request
- A document to confirm your identity (e.g. photocopy of your passport or ID card)
A response will be sent to you within one month (which may be extended by two months, depending on the complexity and the number of requests) following receipt of the request.
7. RETENTION OF YOUR DATA
Homebrella is committed to not keeping your personal data for a period exceeding that necessary for the purposes for which they are processed.
These retention periods are defined according to the processing purposes implemented and take into account the applicable legal provisions imposing a precise retention period for certain categories of data, any applicable limitation periods as well as the recommendations of the French Data Protection Authority “Commission Nationale de l’Informatique et des Libertés” (CNIL).
The security of your personal data is very important to us and we are committed to protecting the information we collect. For this purpose, we implement all the necessary technical and organisational measures to protect your personal data against destruction, loss, modification, access or unauthorised processing. We are also committed to limiting access to personal data to situations in which this access is essential. Employees with access to this data have been informed of their data protection obligations. These security measures are regularly reviewed and adapted to ensure an adequate level of protection.
The security and confidentiality of personal data are based on the best practices of each individual. This is why we ask you not to communicate your passwords to third parties, and to close your browser window after browsing, especially if you access the internet from a computer station shared with other people. This will prevent other users from accessing your personal information.
When you make a quote on our website, your data is processed on a secure server.
Several indicators allow you to check that you are in a protected area:
- The fact that the site address starts with “https: //” indicates that the site is secure;
- The display of a lock icon in the address bar next to “https: //” which means that the connection is encrypted and therefore safer.
Please note that exchanges made over the internet, such as emails, are not secure unless they have been encrypted. Therefore, we cannot be held responsible for any unauthorised access or loss of personal information about you, when it falls outside our scope of intervention and control.
This privacy and data protection policy was published on August 26, 2019. We may occasionally modify it, in which case we will inform you, particularly if we believe that this is a significant change.