Contents (click to jump to a particular section):
For many years, the companies in the Vanbreda Group have assigned privacy a high priority. We process the personal data of each natural person with care and in a way that takes full account of the relevant legislation, regardless of whether this natural person is a (potential) policyholder, an insured person, injured party, beneficiary, contact person for a company, witness, expert or anything else.
This statement explains why Vanbreda collects personal data, what we do with it and what your rights are.
The Vanbreda Group is a collection of companies who deal with insurance brokers and various insurance activities, providing opinions, asset management, risk management and claims handling and/or activities that relate to any of these. Each company within the Group is recognised as an independent insurance broker.
The Vanbreda Group in Belgium consists of: Vanbreda Risk & Benefits – FSMA no. 13718 A-R (BE 0404.055.676), Vanbreda Ausloos – FSMA no. 47833 A (BE 0474.182.421), Vanbreda Cornelis – FSMA no. 12565 A (BE 0425.054.196), Vanbreda Credinco – FSMA no. 042518 A (BE 0462.175.702), Vanbreda Geerts – FSMA no. 044401 A (BE 0466.513.679), Vanbreda Huysmans – FSMA no. 067446 A (BE 0478.505.552), Vanbreda Missinne – FSMA no. 013584 A (BE 0426.071.906)
In the Netherlands, the Vanbreda Group is represented by Vanbreda Risk & Benefits Nederland and in Luxembourg by Vanbreda & Lang.
The Vanbreda Group has close links with the insurance company Justitia. Justitia specialises in insurance of customised Employee Benefits plans that are developed by the Vanbreda Group to suit individual companies holding the policy.
The data controller for your personal data is the Vanbreda company that collected the data. We refer in this statement to the data controller as "Vanbreda".
Depending on the situation, we may process the following personal data: your identity data, your contact data, health data, financial data, social security number, etc. We process this personal data solely for one of the reasons listed under point 4.
3.1 You have the right to view your personal data
If you want to know whether Vanbreda processes your personal data, and if so which data, you can ask to view it. Vanbreda will then provide you with the most comprehensive list possible of the personal data being processed in its open files. Given the large volume of personal data processed by Vanbreda, we ask you to specify which information or which processing activities your request relates to. Personal data which only exists in back-up or log files, or which cannot be directly linked to you, will not be included. Given the sensitivity of health data, this is not sent by default. In this case, we ask that you give us details of a doctor to whom we can send the data, so that they can make the data available to you.
3.2 You can have your personal data corrected
If it appears that the personal data we are processing about you is incomplete or not (or no longer) correct, you can correct or complete said data (or have this done).
3.3 You can sometimes have your personal data deleted
Your personal data is automatically deleted over the course of time. You will find a more detailed explanation of this in point 6. If you believe that your personal data should not be processed, you can ask Vanbreda to delete said data sooner.
3.4 You can object to certain uses of your personal data
Due to a certain situation in which you find yourself, it may that you cannot agree to any processing on the basis of Vanbreda’s legitimate interests. In this case you can raise an objection to the processing of your personal data and Vanbreda will have to consider the merits of your specific interests as well as its own. Only if there are imperative, legitimate reasons that outweigh your interest (e.g. combating fraud) or in the context of a (future) legal action, will Vanbreda continue to process your personal data.
If you object to the processing of your personal data for direct marketing, Vanbreda will end all processing for this purpose.
3.5 You can oppose certain uses of your personal data
You can ask Vanbreda to restrict the processing of your personal data if, for example, time is needed to check the accuracy of your personal data, where the processing is not legal, if Vanbreda no longer requires this personal data (but you do in the context of a legal action) or if you have raised an objection to a specific type of processing and the consideration of competing interests still needs to be carried out.
3.6 You can ask for your personal data to be transferred to another party
For personal data that you have provided to Vanbreda, and data that was obtained with your consent or on the basis of a contract and which is being processed by an automated procedure, you can ask that it be transferred to you or someone else.
3.7 You can sometimes reject decisions being taken on the basis of automated processing
In some of our processes, decisions are taken without any human intervention. An example of this is the reimbursement of a claim for which it is clear even to a computer that for the specific situation a reimbursement is obviously the outcome. You are informed of the existence of this kind of automated decision-making, and of the underlying logic used as part of the process itself. You can always get in touch with your contact person at Vanbreda if you have any questions about these automated decision-making processes or if you do not agree with a decision and wish to provide additional information.
3.8 You can withdraw your consent
You can withdraw your consent at any time for the personal data processed by Vanbreda on the basis of your consent. If you withdraw your consent, Vanbreda may no longer be able to provide certain services.
3.9 How can you exercise these rights?
If you wish to exercise one of these rights, it is important for you to:
Depending on the scope and impact of your request, Vanbreda may ask for additional information.
The best idea is to send your request to your contact at Vanbreda.
For questions or complaints about exercising your rights, you can also address the Vanbreda Data Protection Officer using our form, by e-mail at firstname.lastname@example.org or by post to Vanbreda Risk & Benefits NV, attn. Data Protection Officer, Plantin en Moretuslei 297, 2140 Antwerp, Belgium.
You can find more information about the legislation relating to the protection of personal data at cnpd.public.lu, the website of the Luxembourgish Data Protection Authority. You can also submit complaints to them.
4.1 To meet legal requirements
Vanbreda needs certain personal data in order to meet its legal obligations. If it does not have this data available, it cannot sign or renew any contracts with you, or carry out a transaction that was requested by you or by a third party for your benefit.
Legal provisions that cause Vanbreda to process your personal data include:
4.2 To be able to conclude and implement contracts with you
Some personal data is needed in order to be able to sign a brokerage contract or to provide the service that you expect from Vanbreda when implementing the contract.
Vanbreda’s services include, among others, providing advice, offering and recommending insurance contracts, the performance of preparatory work for concluding insurance contracts and the actual conclusion of insurance contracts. Finally, Vanbreda will also help you manage the implementation of insurance contracts. It assists with the preparation of claims and may, if necessary, appoint experts or contact other affected parties and provide them with your personal data.
If you want to make use of a third-party payment system, Vanbreda will also need to process your personal data.
4.3 For the correct provision of our services
Vanbreda will also process your personal data in order to further its legitimate interests.
Processing for this reason includes, among other things:
For this processing, Vanbreda will always balance its own interests against your rights and reasonable expectations. If you do not agree with one of the above forms of processing, you may lodge an objection as described in point 3.
4.4 For the smooth provision of our services to our clients and insurers
Vanbreda will also process your personal data in order to further the legitimate interests of third parties such as clients, employers and insurers. This will only occur when the interest of the other party outweighs the impact on your rights and reasonable expectations,
Processing for this reason includes, among other things:
Wherever possible, this data is communicated to the parties involved on an anonymised basis.
4.5 To carry out direct marketing
Vanbreda wants to offer you products and services that are relevant to you. In addition, we also see it as our job to inform you of new business risks that may, for example, threaten the continuity of your company.
In order to give you the best possible advice, Vanbreda will use the data that it has available. Vanbreda uses your personal data in order to carry out direct marketing. By analysing your personal data, you can enjoy a personalised approach and Vanbreda can present you with specialised proposals. If you would prefer this not to be the case, you can always let us know.
4.6 Because you have provided us with your consent
Certain personal data will only be processed because you have provided Vanbreda with your consent for us to do so. You can remove your consent at any time, without providing any justification.
The withdrawal of consent means that these processes, based on your consent, will no longer be possible in future. The withdrawal of your consent does not mean that processing that occurred in the past on the basis of your consent is suddenly no longer valid.
Your personal data can reach Vanbreda in a number of ways:
If you provide Vanbreda with someone else’s personal data, it is important that this person is informed about it and referred to this privacy statement.
6.1 Vanbreda Group
Your personal data can be transferred to other companies within the Vanbreda Group. In this way, each Vanbreda company can see the information relating to customers, and does not need to ask for the same information every time.
This obviously does not apply to your medical data. This is only processed by the company within which it was collected.
Within the Vanbreda Group, only those people who need the information for processing will have access to your personal data. The data they can access will depend on the reason why they need this access.
Vanbreda may provide your personal data to parties who are involved in implementing a contract or policy. This may be, for example, (potential) insurers, the contact person at a company, (medical) experts and consultants, banks, health insurance funds, etc.
Your medical data is handled with particular care. In order to avoid processing any unnecessary data, we ask everyone to respect the agreements in the insurance policy. In some cases, therefore, you may be asked to send medical information directly to the consulting physician of the insurance company.
If Vanbreda shares this data with a third party (e.g. the insurer or your own doctor), this is only in the context of implementing a contract or paying for a claim.
Vanbreda may also provide your personal data to parties who are involved in handling a claim. These may be, for example, the other party (or their insurers), (medical) experts and consultants, banks, etc.
In order to provide its services as smoothly as possible, Vanbreda uses a number of suppliers and subcontractors. In order to perform their tasks correctly, it may be that they are given access to your personal data. By signing a data processor contract with them, Vanbreda defines some very clear limits about what your personal data may be processed for, and where. In addition, Vanbreda imposes the necessary security standards.
If Vanbreda is legally required to do so, it will share your personal data with the public authorities.
Important: Vanbreda will never sell your personal data.
Vanbreda endeavours to process your personal data within the European Economic Area as far as possible, unless otherwise required to implement a contract (e.g. contact with a local expert for a claim abroad). If this is not the case, Vanbreda will inform you about it.
Vanbreda will only retain your personal data for as long as Vanbreda needs said data for the implementation of its tasks, and representing its interests.
We will delete your data in our active systems at the latest on the expiry of the liability period for potential complaints.
Your data is stored in our back-up systems until it is removed from the storage system. When a back-up system needs to be used, the data that is no longer needed for the defined tasks is first removed from the active systems.
Please contact us via email at email@example.com or by writing to Vanbreda & Lang S.A. / 2-4, rue du Château d'Eau / L-3364 Leudelange / Luxembourg. Alternatively, you can call us under +352 46 54 03.
For any questions and problems relating to the processing of your personal data, you can also contact our Data Protection Officer (DPO) at firstname.lastname@example.org, using our form or by post to Vanbreda Risk & Benefits NV, attn. DPO, Plantin en Moretuslei 297, 2140 Antwerp, Belgium.
This Policy was last updated in April 2018.