Data Privacy Notice
Why do we need to collect and process your personal data?
AXA Life Europe dac (as Data Controller – referred to hereafter as “we”, “us” or “our”) is an insurance undertaking with its registered office in Wolfe Tone House, Wolfe Tone Street, Dublin D01 HP90, Ireland.
We will process your personal data (“Data”) for purposes associated with the administration of your insurance policy or to provide you with a benefit under an insurance policy, to carry out marketing, to offer our insurance products and services to you as a prospective customer, to comply with legal requirements on us and for internal statistical analysis.
In particular, we shall use your data to provide insurance services and products in connection with the following non-exhaustive list of activities:
- providing quotations and illustrations;
- underwriting;
- marketing;
- administration of your policy;
- preparing and concluding insurance policies and fulfilling contractual obligations deriving from them;
- collecting premiums;
- settling claims, payments or other benefits;
- reinsurance and coinsurance;
- prevention and detection of insurance fraud and related legal action;
- exercising and protecting insurance rights;
- other specific legal or contractual obligations;
- analysis of new insurance markets or products or services;
- management and internal control;
- statistical activities, including for pricing purposes:
- use of anonymized data for the purposes of analysis and market statistics.
In limited instances we use automated processes to assist with the delivery of our insurance services, in particular to assist with the assessment of quote applications and to generate insurance quotes.
For these processing activities, we rely on the following legal bases under data protection law:
- Processing with your consent.
- To perform our contract with you or enter into a contract with you.
- To comply with a legal obligation that applies to us, for example processing required under our designation as a regulated entity.
- To give effect to a range of legitimate interests associated with our services and products, which includes our legitimate interests as a commercial insurance provider, the legitimate interests of our affiliates and commercial partners connected with our business, and the legitimate interests of our customers and prospective customers as recipients of these insurance services and products and related marketing / advertising.
To the extent that the processing activities described above involve the processing of special category data, for example health data, we will typically be engaging in this processing where the processing is necessary in order to provide a policy of insurance or life insurance.
In the event that we require you to provide us with your Data for contractual or statutory requirement purposes, and you fail to provide the Data, we may be unable to provide you with the underlying services that are underpinned by those contractual or statutory requirements.
What will we do with your personal data?
Your Data will be stored in compliance with Irish legal requirements, and in particular with the General Data Protection Regulation (“GDPR” (Regulation (EU 2016/679)). In accordance with these regulations, we will implement appropriate security measures to protect your Data.
We may perform criminal checks where permitted by law, and may process other Sensitive Data, such as citizenship or nationality information or health information, when connected with the provision of a benefit under your contract of insurance.
We may transfer your Data to external third-party providers performing certain services for us. Such third-party providers have access to your Data solely for the purposes of performing the services specified in the applicable service contract, and we require them to process the Data only in accordance with our instructions and with technical and organisational security measures consistent with the requirements set out in this Notice.
We may be required to disclose part of your Data to other third parties (1) as required by law; (2) to protect our legal rights to the extent authorized or permitted by law. In addition, in the event of a re- organization, merger, sale, joint venture, assignment, or other transfer or divestiture of all or any part of our business, we may transfer your Data to the acquiring entities or parties including the assignment of any consent that you provided to us in respect of the processing of your data.
We are part of the global AXA Group and therefore your Data may be transferred to and processed in third countries that may not be deemed to provide the same level of Data protection as your home country. AXA Group’s Binding Corporate Rules govern the treatment of personal information of European Union residents. Further information about these Binding Corporate Rules is available here:
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In particular, in order to provide you with insurance services including those under your contract with us, we may need to send your data to or receive your data from any of the following third parties:
- IFAs or other distributors who were involved in the distribution of your contract,
- Reinsurers for reinsurance purposes,
- Law firms for the purposes of obtaining legal advice,
- Insurance services firms for managing your policy, including claims handling,
- Services companies providing document management services (printing, archiving, postal services, etc).,
- Companies belonging to the AXA Group for analysis purposes,
- Regulatory bodies such as the Central Bank of Ireland and the UK Financial Conduct Authority to comply with legal requirements,
- Irish Revenue Commissioners and other tax authorities in order to comply with our reporting obligations under FATCA and CRS; in particular, we may need to send them your name and surname, address, tax code, date of birth, policy number and the value of your policy at the end of the reporting period
We will not sell your Data to any third party.
We will retain your Data for as long as necessary to provide our insurance services to you or to meet our obligations under law. Where your contractual relationship with us ends, your data will be retained for a period of seven years following the end of this contractual relationship to facilitate any further processing that may be necessary, such as responding to any claims you have following this termination or to retain records in accordance with our legal obligations.
We process your Data using only manual and IT-based methods and procedures which are appropriate to provide you with insurance services and/or products or, if you agree, to perform market research, surveys and promotional activities. The same methods and processes are used when this data is transmitted to third parties for the same purposes as indicated in this document. Your Data is processed by our employees where this is relevant to their role, and only in accordance with our instructions and for the purposes set out in this privacy notice.
What are your rights under data protection legislation?
You can at any time exercise your rights to access, rectify or erase your Data, restrict or object to its processing, object to the receipt of direct marketing, ask for the Data to be transferred to a third party (data portability), or withdraw consent that you have previously provided to processing, by contacting our internal DPO (by email at data.protection@axa-lifeeurope.com).
You may also file a complaint with the Data Protection Commission by following the steps in this DPC webpage.
You can decide not to provide us with certain information we may request from time to time in connection with your policy, but you need to be aware that failure to provide this information may prevent us from providing you with a service or benefit under your insurance policy.