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Introduction

At Generali Employee Benefits, we understand the importance of respecting your fundamental rights and freedoms regarding your privacy and the protection of your personal data. We are committed to ensure the confidentiality and security of the personal data we collect and process.

This section of our dedicated privacy page aims at informing you about our practices regarding collection, use and disclosure of personal data on and via our website (www.geb.com) and when you interact with GEB through our social channels. It further informs the visitor on his or her privacy-related rights.

For these processing activities, GEB is the responsible data controller as we determine both the why (purpose) and the how (means) of processing:

This privacy notice was last updated on 10/04/2024.

Definitions

For the purpose of our privacy page, the following definition applies: 

How does GEB collect your personal data?

GEB collects your personal data, either directly provided by you (e.g. through the “contact us” section, the “get updates” section, etc.) in order to provide you the services you requested, or indirectly through the mere use of our website.

We may collect your personal data in the following ways:

• When you contact us through our contact form

When you submit a message through our contact form, we collect your name, surname, company name and email address in order to answer your inquiries. Where necessary, those messages are transferred to the relevant GEB staff and departments.

• When you subscribe to our online services such as newsletters

If you decide to subscribe to our newsletters, you will receive regular emails about GEB’s news and latest updates. We need to use the personal data you provided us (name, surname, company name and email address), in order to send you those requested communications. You may choose to unsubscribe to our newsletters and stop receiving our emails by clicking on the opt-out link available at the bottom of each communication.

• When you are using our website

When you are browsing our website, tracking information is gathered with the help of information gathering tools (e.g. cookies). This data is automatically collected through your electronic device in order to enhance your navigation on our website.

• When you interact with us through social channels (LinkedIn, Twitter)

As you are interacting with us through social media, we may collect information in order to be able to answer your questions and fulfil your requests.

Which personal data does GEB collect?

We are collecting personal data you have provided us voluntarily while using the functionalities available on our website (newsletters, contact form, press releases), such as:

• Name and surname;
• Email address;
• The name of the company you are working for;
• Subscription information such as updates you are interested in;
• Any information you decide to provide us through the contact form.

The information you provide is necessary in order for us to be able to process your requests and provide you with the services you requested.

We also use cookies. More information on which cookies we use and what purposes they serve can be found in the dedicated cookies section below (“about cookies”). 

For which purposes does GEB process your personal data?

We collect personal data in a fair and lawful manner for the reasons and purposes as set out below.

Based on your consent, we collect and process your name, surname, email address and the company you work for. We do this in order to be able to send you the newsletters and updates you have subscribed to. You are under no obligation to provide this personal data. However, if you willingly provide this data, you are giving us your consent to process it for the purposes outlined in this section of our privacy page. You can withdraw your consent at any time by clicking on the unsubscribe link indicated in our emails or by sending an email to privacy@geb.com.

Based on the legitimate interest to offer our website’s visitors an optimal and personalized experience and a well-functioning website, we collect and process tracking information (e.g. cookies). Furthermore, in order to continuously improve our website, we collect and process statistical information on the articles you have read and which links you have clicked. 

About cookies

When you are using our website, we collect personal data you passively provide to us in the form of cookies and other similar technologies. A cookie is a unique text file that a website sends to your browser and is stored on your computer’s hard drive. It is used to store a website user’s configuration and preferences (e.g. language). They further enable us to collect information such as your browser type and version, your internet service provider, your IP address, the various pages you are visiting on our website, other websites you may have visited, etc. This information is of value to us as we use it to improve your visit and provide you with a personalized experience when you visit our website. Cookies may contain unique identifiers, which may be considered personal data.

We use different types of cookies:

Strictly necessary cookies – These cookies are necessary for a correct functioning of our website and for the use of the services contained therein. In their absence, our website or at least some sections, may not work properly. Therefore these cookies are always used regardless of the users’ preferences. This category of cookies is always sent from our domain. Users may delete these cookies via their browser settings.

Analytics cookies – These cookies are used to collect information on the use of our website, such as, for instance, the pages visited more frequently. These cookies are sent from our domain or from third party’s domains.

Remarketing Cookies – These cookies allow us to help us deliver targeted online adverts based on past visits to our website on various third party websites across the internet.

Cookies for the integration of third parties’ functionalities – These cookies are used in relation to the functionalities of the website (e.g. icons of social media networks for sharing of content or for the use of services provided by third parties). These cookies are sent from our domain or from a third party’s domain.

We advise allowing the use of cookies in order for your browser to work properly and to optimise the use of our website. However, if you do not feel comfortable with the use of cookies, it is possible to opt-out and prevent your browser from recording them. How you can manage your cookies depends on the browser you use:

With which parties does GEB share your personal data and why?

We share your personal data with the following parties:

• Law enforcement, government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation

Within the limits of the applicable laws, we share your personal data to authorities, law enforcement and government agencies upon their request in order to prevent criminal activities, meet national security requirements or respect law enforcement injunctions. 

• Third parties that provide applications & systems

When necessary, we share your personal data with third parties whose services we are using (e.g. hosting services such as cloud providers, security service providers). We do this when using various IT systems and operations.  

We may transfer personal data to countries that are not in the European Economic Area (EEA). However, if such transfer occurs and the country does not fall under a Commission adequacy decision, GEB will ensure that appropriate safeguards are in place that provide sufficient protection for your fundamental privacy rights and freedoms. Such safeguards include, but are not limited to, Standard Contractual Clauses, as approved by the European Commission.

Which rights do you have and how can you exercise them?

GEB respects to the fullest extent the rights you have as a data subject. These rights include:

• The right of access

If you can prove your identity, you have the right to access all the information GEB has on you. This includes whether or not we have any data on you, the purposes for which we process your data, the types of personal data concerned, the recipients to whom your personal data will be disclosed and the rights you have under the GDPR.  

We will provide you with one copy free of charge. For any additional copies, we may charge an administrative fee.

• The right of rectification

You have the right to rectify inaccurate, incorrect or outdated personal data we may have on you. Where personal data is incomplete, you have the right to complete it, including by means of providing a supplementary statement.

• The right of erasure

You have the right to have your personal data erased without undue delay if one of the following conditions applies:

• The personal data is no longer necessary for the purpose for which it was collected;
• You withdraw your consent, if the legal basis for processing is consent;
• You exercise your right to object and we have no overriding legitimate grounds to continue the processing;
• The personal data has been unlawfully processed;
• We have to erase your personal data to be in compliance with a legal obligation under EU or Member State law.

It is up to GEB to assess the presence of the abovementioned criteria.

• The right of restriction

You have the right to obtain from us restriction to processing your personal data if one of the following conditions applies:

• For the period enabling us to verify the accuracy of your personal data, if you have contested the accuracy of the personal data;
• The processing is unlawfully and you request the restriction of processing instead of the erasure of the data concerned;
• We no longer need the personal data for the purposes for which it was collected but you need it for the establishment, exercise or defence of legal claims;
• When you exercised your right to object, for the period we need to verify whether the legitimate grounds we rely upon override yours.

It is up to GEB to assess the presence of the abovementioned criteria.

• The right to data portability

You have the right to receive the personal data you directly provided to us in a structured, commonly used and machine-readable format and transfer it to another data controller. We will not hinder you if you exercise this right.

• The right to object and not be subject to automated individual decision making (including profiling)

You have the right to object, at any time and on grounds specifically related to your particular situation, to the processing of your personal data provided that we process the data concerned based on our legitimate interest. In such case, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing is necessary for the establishment, exercise or defence of legal claims.

Furthermore, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you.

• The right to withdraw your consent

You have the right to withdraw your consent at any time for the processing activities for which we requested your consent. Any processing of your personal data we may have performed before your withdrawal shall remain lawful.

You can exercise your right to withdraw consent by clicking on the unsubscribe link indicated in our emails or by sending an e-mail to privacy@geb.com.

• The right to lodge a complaint with the Data Protection Authority

You have the right to lodge a complaint with the EU Data Protection Authority in your jurisdiction, namely for Luxembourg the National Data Protection Commission (Commission Nationale pour la Protection des Données – CNPD)  (https://cnpd.public.lu/en/commission-nationale.html)

We will duly address all your privacy related requests. Furthermore, within a period of one month, we will provide you either with a comprehensive answer or with clear reasons why the request will take longer than anticipated.

You can exercise you rights by sending an e-mail to privacy@geb.com or by using this form. 

How long will GEB retain your personal data?

GEB will only retain your personal data for as long as is necessary to fulfil the purpose for which we collected it.