Privacy and Personal Data Protection Policy

This Privacy and Personal Data Protection Policy, hereinafter the "PRIVACY POLICY" or just the "POLICY", applies generally to the collection and processing of personal data provided by customers, potential customers, users and users - hereinafter just the "DATA SUBJECT" - of the services provided, both offline and online, by Mediadora de Seguros LIBELINHA D'ÉXITO MED DE SEGUROS LDA, registered with the Insurance and Pension Funds Supervisory Authority (ASF) under no. 417456759, NIF 514281219, with registered office at Avenida Francisco Sá Carneiro edf. Batalha loja 4 8125-154, Quarteira, hereinafter referred to as "MEDIATOR".

Article 1 - Controller of personal data

The MEDIATOR identified above, whose activity is regulated by Decree-Law no. 144/2006, of 31 July, and the corresponding regulations published by the ASF, may act as "controller", "subcontractor" or "joint controller" of personal data, as the case may be, within the scope of insurance mediation. This data may be collected through forms, proposals, documents or other means, on paper or electronically, and used for the conclusion, execution, renewal or termination of insurance contracts with the intervention of the MEDIATOR.

Article 2 - Data protection contact

Postal mail: Personal Data Protection Officer, Estrada da Penha 150C, 8005-138 Faro

Email: geral@cjseguros.pt

Article 3 - Processing of personal data

The personal data provided to the MEDIATOR is processed in accordance with legal principles, namely:

Lawful, fair and transparent treatment;
Specific, explicit and legitimate purposes;
Adequacy, relevance and limitation to what is necessary;
Accurate and up-to-date data;
Storage limited to the period necessary for the purpose;
Integrity and confidentiality of personal data.

Article 4 - Purposes, grounds for processing and retention periods

Personal data is processed for the following purposes:

Execution and management of the insurance contract or pre-contractual steps: up to the legal limitation period for obligations;
Prospecting and commercial action: up to one year after the end of the contractual relationship;
Compliance with legal obligations: according to the applicable legal deadline;
Exercise of rights in legal proceedings: until the expiry of the limitation or forfeiture period.

Article 5 - Recording telephone calls

The MEDIATOR may record telephone calls, with the DATA SUBJECT'S consent, for the purposes of contract management, proof of instructions and improving the quality of service. The recordings will be kept under the terms defined by the CNPD.

Article 6 - Health data

For certain insurances (e.g. health or personal accident), it may be necessary to process health data. This processing depends on the DATA SUBJECT's consent or other legal grounds. Without this processing, it may not be possible to conclude or maintain the contract with the INSURER.

Article 7 - Data communication

The data may be communicated to entities in the MEDIATOR'S group, INSURERS, co-mediators, PDEAMS, judicial and regulatory authorities or entities carrying out statistical studies, fraud prevention or other legal obligations.

Article 8 - Collecting data from other sources

The MEDIATOR may collect personal data from public sources or specialised entities in order to complement or verify information provided by the DATA SUBJECT, with a view to analysing risk or managing the contractual relationship.

Article 9 - Rights of the data subject

The DATA SUBJECT has the following rights, upon written request:

Access to personal data processed;
Rectification or updating of data;
Deletion of data in the cases provided for by law;
Limitation and opposition to treatment;
Data portability in common digital format;
Withdraw consent when applicable;
Complain to the CNPD.

Article 10 - Security of personal data

The MEDIATOR implements technical and organisational measures to protect the data against destruction, loss, alteration or unauthorised access, ensuring its confidentiality, integrity and availability.

Article 11 - Automated decisions

In underwriting or renewal processes, INSURERS may use automated decisions based on the DATA SUBJECT's data. The DATA SUBJECT may request human intervention, express their opinion or contest the decision.

Article 12 - Cookies

MEDIADOR may use cookies on its website to improve the user experience and browsing security.

Article 13 - Changes to the privacy policy

This policy may be amended at any time and published on the MEDIATOR's website or communicated by other means. Relevant changes will be duly highlighted or communicated directly to DATA SUBJECTS.