PRIVACY POLICY OF AXA PEOPLE PROTECTOR SERVICES S.A. UNIPERSONAL

 

Who is your personal data Controller?

You are hereby informed that your personal data will be processed by AXA PEOPLE PROTECTOR SERVICES S.A. UNIPERSONAL, as Data Controller, with registered address in C/ Calle Emilio Vargas 6, 28043 Madrid (Spain).

In order to ensure that your personal data are processed lawfully and transparently, AXA PEOPLE PROTECTOR SERVICES S.A. UNIPERSONAL has a Data Protection Officer, who may be reached at the following e-mail address: [email protected]

 

What are the purposes of your data processing?

Your personal data will be processed for the following purposes:

    • Management of registration on the Health Keeper platform owned by AXA PEOPLE PROTECTOR S.A. UNIPERSONAL, whether through the Website or the App, to include relations between the Health Keeper Platform and its users, in order to ensure that the latter enjoy its advantages and benefits, contents and services, for which a user may be reminded of his/her appointments by SMS or e-mail. If minimum data are not provided for registration, the latter may not be completed.
    • Delivery of commercial correspondence or newsletters, whether or not personalised, on health, healthcare, wellbeing, physical exercise, nutrition, healthy lifestyles
    • Personal profiling based on browsing behaviour, sociocultural factors and the use of big data processing techniques, for market analysis purposes and to inform users on health services, wellbeing, healthcare, physical exercise, nutrition and healthy lifestyles, which may be of interest. This profiling may only be carried out if authorised by the user.
    • Profiling and completion of surveys and check-ups in order to provide the user with personalized recommendations on health and lifestyles. This profiling will only be carried out if, after your registration as a user, the relevant sections are completed on the Health Keeper platform for surveys and medical check-ups (to be filled in voluntarily). This profiling may only be carried out if authorised by the user).
    • Performing statistical analysis with anonymous and aggregated data about the usage of the platform. Examples would be total registrations, active users, visits, trackers connected, user goals, user risks, daily steps, etc.

In any case, all personal data will be treated confidentially and will be adequate, pertinent and not excessive for each one of the purposes indicated and authorized at all times by the user.

 

Lawfulness of your personal data processing

AXA PEOPLE PROTECTOR SERVICES S.A. UNIPERSONAL will process your data lawfully, on the following grounds:

    • Consent for the management of your registration on the Health Keeper platform and the maintenance and provision of contents and services offered by Health Keeper constitute our main lawful grounds for the processing of any personal data requested.
    • For this registration, AXA VERSICHERUNGEN AG (“AXA Switzerland”), insurer of the company you work for, received your personal contact data (first name, last name, language and email address) from your company. AXA Switzerland had provided your personal contact data to AXA PEOPLE PROTECTOR SERVICES in order to invite you to join the Health Keeper Platform and – in case of interest – register on the Health Keeper CH platform.
    • Consent to delivery of commercial correspondence and newsletters.
    • Consent to personal profiling, for market analysis and adequate delivery to the user of personalized commercial correspondence, based on the information and profiling available at all times.
    • Consent to personal profiling, based on health surveys and medical check-ups in various sections of the Health Keeper platform, voluntarily completed by the user.
    • Consent for performing statistical analysis based on anonymous and aggregated data about the usage in the platform.

Data recipients

Your personal data will not be transferred to third parties, except in the following cases and always subject to the user’s prior acceptance:

    • To service providers of different categories, such as IT or marketing services, that are part or are needed to operate the platform.
    • To AXA GROUP OPERATIONS SAS, (“AXA GO”), for performing report analysis based on anonymous and aggregated data.
    • AXA PEOPLE PROTECTOR SERVICES S.A. UNIPERSONAL provide aggregated and anonymized company-specific reports of the Health Keeper and the performance of the platform to AXA Switzerland.
    • AXA PEOPLE PROTECTOR SERVICES S.A. UNIPERSONAL regularly provide aggregated and anonymized data about the usage of the Health Keeper and the performance of the platform to AXA GO.

For how long will we store your personal data once you have de-registered from the Health Keeper platform?

Your personal data will be blocked when they are no longer necessary for the purpose for which they were gathered. They will only be made available to Judges and Tribunals, the State Prosecutor’s Office or competent Public Administrations, to particularly include data protection authorities, in order to handle any potential data processing liability claims, until these have lapsed. Upon expiry of the statute of limitations, the Bank will proceed with your data erasure.

 

What are your data processing rights?

As a data holder, you are entitled to at any time address a written communication to AXA PEOPLE PROTECTOR SERVICES S.A. UNIPERSONAL, CRM Dept., Calle Emilio Vargas 6, 28043 Madrid, with “User Data” as the reference. Pursuant to applicable data protection regulations, your request must contain the following data subject details: full name, address for notification purposes, a photocopy of your Spanish Identity Card or other legally valid identification document, or that of a guardian representing the data subject, and the specific request being made.

You may also uphold your rights at [email protected], under the same terms indicated above, referring to the right upheld in the subject matter.

Your data protection rights are:

    • Right of Access

You are entitled to have AXA PEOPLE PROTECTOR SERVICES S.A. UNIPERSONAL inform you of whether or not your personal data are being processed and, if so, of your right to access such data and receive information on the processing purposes, categories of data affected by the processing, the recipients of your personal data and the time during which your data will be stored, amongst other information.

    • Right of rectification and erasure

You are entitled to request an erasure of your personal data, provided that legally applicable requirements are met, and to rectify any inaccurate data affecting you when, amongst other reasons, they are no longer necessary for the purposes for which they were gathered.

    • Limited processing, revoked consent and total or partial objection to the processing.

In certain circumstances (e.g. if the applicant challenges the accuracy of his/her data, whilst such accuracy being is verified), you may request that your personal data processing be limited, and only processed to bring or defend any claims.

You are also entitled to revoke your consent and to challenge the processing at any time, for reasons related to your individual situation, should the processing be based on our legitimate interest or that of a third party (including any processing aimed at direct marketing and profiling). In this case, we AXA PEOPLE PROTECTOR SERVICES S.A. UNIPERSONAL will cease its processing, unless it is able to ascertain legitimate reasons.

    • Data portability

You are entitled to receive any personal data provided to AXA PEOPLE PROTECTOR SERVICES S.A. UNIPERSONAL, in structured, standard and mechanically-readable form, and to be able to transfer them to another controller, without this being prevented by the original controller, in the events foreseen by law.

    • Automated decision-making

Furthermore, in addition to these rights, in the case of automated decision-making, profiling included, you are entitled to obtain AXA PEOPLE PROTECTOR SERVICES S.A. UNIPERSONAL’s human intervention, to express your point of view and to challenge any decision.

    • Other

Likewise, if personal data are transferred to a third country or international organization, you will be entitled to be informed about how to access or obtain a copy of suitable guarantees related to such transfer.

 

For any doubt or additional issue related to the exercise of your rights or, in general, the processing of your personal data, you may contact our Data Protection Officer at [email protected]

Finally, you will be entitled to bring a claim before a federal supervisory authority (Federal Data Protection and Information Commissioner, Feldeggweg 1 CH-3003 Berne). https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

 

What is the data source if not provided by the data holder?

Along with the data provided by the applicant in the process to register on the Health Keeper platform, or through access and use of the same, we will obtain information on your browsing behaviour, should you agree.