LINEA DIRECTA ASEGURADORA S.A. DATA POLICY ADDITIONAL INFORMATION

Data Controller. Who will process your data?

  • The data controller is Línea Directa Aseguradora S.A. Compañía de Seguros y Reaseguros, S.A., with CIF (Company Tax Code) A-80871031 and address at Ronda de Europa, 7, Tres Cantos, Madrid, C.P. 28760.
  • You can contact us by email at the following address: departamentolegal@lineadirecta.es . If you wish to contact Línea Directa, please use the above email, or by calling 902 325 325.
  • If you need to contact our Data Protection Officer, you can do so at dpo@lineadirectaaseguradora.com or by a letter addressed to the same address, including the “Data Protection Officer” as the addressee.
  • Purposes. Why do we need your data?

    Some data uses are necessary (to comply with legislation and contracts) and others are additional (they depend on whether you give your consent or where any legitimate interest is observed), and they are considered compatible because their aim is to send you commercial communications that are really of interest to you, adjusted to your personal profile, or to improve the quality of our services or our products.

    • Necessary data processing, under the contract or in compliance with legislation, involves the following:
      • When you request our products, or when it is time to renew policies, we will use your data to prepare an insurance offer or quote, establishing a price (insurance premium pricing).
      • For pricing, a profile will be produced based on automated decisions, which include consulting common insurance industry claims files, as well as consulting credit files related to compliance or default or default or compliance propensity with respect to monetary obligations, producing profiles that allow us to adjust our prices and be more competitive. See "credit files" section. Public files will also be consulted, such as the land registry (very useful for our home insurance in order to complete and check the information you supply to us about your home), or files from the Directorate General of Traffic, for the same purpose in car insurance, and which will help us to avoid mistakes about the insured vehicle and speed up the purchase process.
      • We will also use your data to conclude the insurance contract with you, to maintain it, renew it and, in general, to proceed to the management and control of any policy or policies you take out, including the management of any claims that may occur, as well as managing and keeping the corresponding telephone calls. In order to conclude the contract, legislation may sometimes force us to carry out suitability and appropriateness tests, which we will proceed to carry out.
      • All insurers must create accounting provisions to guarantee that we can pay any claims made by any insured customers. This means we need to make profiles and take automated decisions that allow us to predict the statistical risks of claims occurring, which means using your data for these purposes of statistical studies and models, classifications or scoring, as well as preventing fraud in risk selection and claims management, by performing accident analysis.
      • The data may be supervised, and hence communicated, to the administrative authorities responsible for ensuring compliance with legislation and solvency, in this case the General Directorate of Insurance and Pension Funds.
      • To set lower prices and prevent fraud, all insurers can consult common claims files, and they must therefore communicate their data to these files as well. See "common insurance industry files" section.
      • The law authorises us, in order to comply with the insurance policy and its consequences, to use your data to:
        • Determine the health care that should have been provided to the injured party, as well as any compensation that may be appropriate, when this has to be paid by Línea Directa.
        • Suitable payment to health providers or reimbursing the insured or their beneficiaries for any health care expenses that may have been incurred within the scope of a health care insurance contract.
        • In addition, in the case of Línea Directa, please note that it constitutes a group, which may make it necessary to communicate personal data between companies in the group in order to comply with the supervision obligations established by law.
        • Finally, the law also enables us to communicate data to reinsurance companies, if any, that is strictly necessary for the conclusion of the reinsurance contract in the terms set forth in Article 77 of Insurance Contract Law 50/1980 of 8 October, or for carrying out related operations, these being understood to be the performance of statistical or actuarial studies, risk analysis or investigations for customers, as well as any other activity related to or arising from the reinsurance activity.
      • We will also use your data to send you information and quotes that you have requested from us, in the way you have indicated to us, including emails or equivalent means of communication, and in the periods authorized by you to do so.
    • Additional processing covered by legitimate interest, which it is possible to object to:
      • Legislation requires us to keep your identifying data up to date, as well as any other information included as necessary in each contract, and for which public data (public records, land registry data or other data that has been made manifestly public) may be used if it is necessary to fulfil identification obligations or others established in the previous paragraphs.
      • Conducting surveys. We always want to provide the best service and we want you to help us improve. That’s why we may also use your data to conduct quality surveys about the service that we provide, thanking you for your cooperation from now on.
      • It may also be necessary to transfer data to group companies for administrative purposes, or for fraud prevention, based on legitimate interest.
      • We want you to know about us and to be able to benefit from discounts and offers, both our own and those from third parties with which we reach agreements of interest to you and provided that your expectation of privacy is respected. This is why it is possible that processing may involve the sending of commercial communications by any channel, including email or equivalent means of communication, to notify you about customer loyalty activities, promotional surveys, prize draws, etc. on insurance, financial products, the world of cars, housing and decoration, as well as sports and health. Remember that you can always object to this purpose at any time.
      • We may in addition adapt our commercial offers to your particular profile and this will allow us to be more competitive with you. To do this, information will be collected from data related to your own purchasing activity and the policy itself, as well as your browsing. No automated decisions will be made based on this profile that produce legal effects concerning you. Remember that you can always object to this purpose at any time.
      • Updating your data for commercial purposes, and for which public data (public records, land registry data or other data that has been made manifestly public) may be used.
      • Creating behaviour models with pseudonymized and anonymous data, to create new products or improve the service we provide you.
      • Legal entity contact details related to your professional location will also be processed based on legitimate interest, with the purpose of maintaining business relationships or those of any other kind with the legal entity in which the affected person provides their services. The same will apply to data belonging to individual business people when it only refers to them in this capacity and is not processed to establish a relationship with them as individuals.
    • Additional processing, covered by your consent and which you can always withdraw, involves:
      • Data assignment. Línea Directa belongs to the Bankinter Group, which allows you access to the commercial advantages of this group, and for which data may be shared for commercial purposes, if you have given your consent to do so. Remember that you can always object to or revoke your consent for this purpose at any time.
      • Sending you commercial communications about products and services from third parties, or products not similar to those you have purchased, by any means including telephone, post and email, SMS, equivalent means of communication, or warning during browsing. Especially in financial, insurance, motor, home, health, investment, property, electronics, telecommunications, leisure, hospitality and travel fields.
      • The use of cookies for the purposes set out in the "cookies policy" that you can consult before you start browsing.
      • If it uses geolocation devices, when you consent to the provision of a service that requires them.
      • The inclusion of your data in loyalty channels, prize draws or other products in which you participate or have participated, according to the conditions of these.

    Time periods. How long will we keep your data?

    • The data that you give us to request an insurance policy may be kept during the validity of the offer at least, asking you for your consent when it is collected to keep it for a maximum period of two years, in order to offer you our rates at the end of the annual maturity of the insurance that you purchase from other companies. Remember that you can always object to or revoke this consent.
    • Data collected for the conclusion of an insurance contract, or any that arises during the above, will be blocked when it is no longer required for the purposes for which it was collected. This blocking will lead to your data being stored solely at the disposal of public administrations, judges and courts for the purpose of any possible liability arising from processing and for the duration of such liability. Once this period has expired, your data will be deleted.

    Why is it sometimes necessary to create profiles and adopt automated decisions?

    • As stated above, to set the lowest rate in accordance with your personal conditions it is necessary to take decisions based on automated or computerized analysis of the data you have given us, or files that may be accessed for this purpose. The logic behind these decisions is to attend flexibly and objectively to everyone in the insurance purchase and renewal processes, considering the same circumstances for everyone, in a computerized form.
    • Insurer solvency rules also oblige us to carry out statistical studies and prepare profiles about each insured customer, in order to anticipate and estimate the probability of a claim occurring. Suitable accounting provisions can therefore be provided to guarantee payment (money reserves foreseen for the payment of claims). To do this, it is necessary to take complex computer-based decisions and create insured profiles with which to manage the risks covered.
    • Finally, modern marketing involves making offers and discounts adjusted to your particular profile, adjustments that require analysis of the specific circumstances of each person using computer tools.

    Legitimation. Why do we need your data and possible objection to processing?

    • Legitimation for the necessary processing comes from the request to conclude or the existence of an insurance contract concluded with you, as well as the legal obligations arising from this. You can always see your current contracts in your NUEZ application. In particular, this necessary processing based on law is authorized by Law 20/2015 of 14 July, on the regulation, supervision and solvency of insurance and reinsurance companies.
    • Additional processing that can be objected to is based on Art. 20 et seq. of Law 34/2002 of 11 July, on Information Society and Electronic Commerce Services, as well as the existence of a legitimate interest to send commercial communications to customers and to proceed with the preparation of non-complex personal profiles. The legitimate interest of this party focuses on considering marketing to be an essential purpose of any company, in accordance with recital 47 of the Data Protection Regulation, as well as the consultations and replies given by the data protection authorities. Remember that you can always object.
    • The remaining additional processing is based on the existence of your consent. Remember that you can always revoke or object to it later. The conclusion of the contract or contracts that you want to conclude are at no time subject to or dependent upon obtaining this consent for additional purposes.

    What data and processing is obligatory and what are the consequences of not supplying data?

    • The data collection forms include an asterisk for required fields in order to conclude the insurance contract or to request one. Consequently, this data will be necessary for these purposes and without them it will not be possible to continue the operation.
    • Regarding the uses of the data, those purposes for which specific consent is not requested are necessary to conclude the insurance contract, or to fulfil the legal obligations corresponding to this contract or an insurance quote request. The other purposes are optional, require consent or are based on a legitimate interest, so that you can always object to them according to what has been indicated in the previous section and in the basic information, without the withdrawal of this consent or such opposition determining the performance of the corresponding contract or its request. Purposes related to points 2.2 and 2.3 may therefore be optional.

    Recipients. Who will handle your data?

    • The recipients of the data will be Línea Directa’s technical and commercial services, as well as companies in the Línea Directa group and the Bankinter Group, for internal administrative purposes, including the processing of customers’ personal data. The following are companies in the Línea Directa group: Línea Directa Aseguradora S.A., Línea Directa Asistencia S.L.U., Motoclub LDA S.L.U., Centro Avanzado de Reparaciones S.L.U., Ámbar Medline S.L.U. and LDActivos S.L.U. Fundación Línea Directa. Companies in the Bankinter group include BANKINTER, S.A., BANKINTER CONSUMER FINANCE E.F.C.
    • Data may also be communicated to insurers or reinsurers or to third-party Línea Directa partners or suppliers, which intervene in the management of the Policy and its claims due to reinsurance, coinsurance or claims management operations. To insurance claims adjusters, for example, or the brokers the insurance is purchased from. In all these supplier cases there will be contracts that oblige them to maintain due confidentiality.
    • Data can also be transferred, when legally appropriate, to common insurance industry files (see "common insurance industry files" section), as well as the Claims Records and Policy Register provided for by law, and to the General Directorate of Insurance in the event of claims.
    • Finally, data may be transferred to BANKINTER, S.A., BANKINTER CONSUMER FINANCE, E.F.C., S.A. provided that you have given your consent, or there is a legal provision that makes this transfer possible or legal.

    Rights. What are your rights regarding your data?

    • You have the right to obtain confirmation regarding whether Línea Directa is processing personal data concerning you and, in this case, you have the right to access your personal data and the additional information referred to in art. 15.1 of the Data Protection Regulation.
    • You also have the right to request the rectification of inaccurate data or, where appropriate, to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected, you have withdrawn your consent, or any other cases, according to the provisions of Art. 16 and 17 of the Data Protection Regulation.
    • You may also, in the cases provided for in Art. 18 of the Data Protection Regulation, request restriction of the processing of your data, in which case it will only be kept for filing or defending against complaints, dealing with injunctions or legal requirements.
    • When processing is based on your consent, you have the right to withdraw such consent at any time, without any detriment.
    • You have the right to file any complaints with the appropriate supervisory authority, this being considered to be the Spanish Agency for Data Protection in Spain, without prejudice to the powers that may, if appropriate, be held by other autonomous or supranational bodies, in accordance with the Data Protection Regulation and national regulations.
    • You have the right to request the portability of the data you have provided us, to receive it in a structured, commonly used and machine-readable format, and for it to be transmitted to another data controller, in accordance with Art. 20 of the Data Protection Regulation.
    • In certain circumstances and for reasons related to your particular situation, you may also object to the processing of your data, especially for processing related to the preparation of profiles or automated decisions. In these cases, Línea Directa will stop processing the data, except for compelling legitimate grounds, or for filing or defending against complaints, all in accordance with Art. 21 of the Data Protection Regulation.
    • In cases of decisions based solely on automated decisions that produce legal effects concerning you or that significantly affect you in a similar way, you have the right to obtain human intervention in such a decision, as well as to express your point of view, being able if you wish to challenge such a decision.

    Rights. How can I exercise my rights?

    • You can address your request to exercise your rights by writing to LÍNEA DIRECTA ASEGURADORA, S.A., Tres Cantos, Madrid, Ronda de Europa 7, C.P. 28760 or to the e-mail address departamentolegal@lineadirecta.es
    • In case of any doubt, or in case you do not consider that you have been properly dealt with, please do not hesitate to contact and send your complaint to the Data Protection Officer for the company at email address dpo@lineadirectaaseguradora.com or by letter addressed to the same address, including “Data Protection Officer” as the addressee.

    Origin:

    • The information we handle is what you give us about you personally, or is from authorised third parties, such as minors you purchase a product for, beneficiaries, non-policyholders, or third parties involved in a claim. This data will be added to that generated later during the validity period of the Policy.
    • In order to set the insurance premium at the lowest possible amount, as well as to compare and complete your data, the law allows us to access and complete your information with various legally accessible databases, based on legitimate purposes, from files owned by third parties, such as the Land Registry, General Directorate of Traffic files, the SINCO files, credit rating files, as well as files with external statistical data, all of them available without restrictions. Furthermore, in certain cases, the data may be updated with data that has been made manifestly public, such as open social media profiles.

    Data categories processed are:

    • Identification data, such as first name, surnames, address, telephone, as well as postal or email addresses
    • Identification codes or passwords, such as the user names and passwords generated to operate our website, as well as the IP addresses leading to a specific operation.
    • Commercial information that may be collected. With respect to cookies, there is a specific cookies policy that you can consult at www.lineadirecta.com
    • Economic and socio-economic data.
    • Claims data.
    • In cases where certain claims exist, or for taking out health insurance policies, data about this health category will also be processed.

    Common insurance industry files.

    • UNESPA

      In accordance with the legal authorization contained in Article 25.4 of Royal Decree Law 6/2004 of 29 October, approving the amended text of the Law on the Regulation and Supervision of Private Insurance, the insurance companies, through their Business Association UNESPA, have established the following files:

      Historical File of Automobile Insurance, whose purpose is pricing and risk selection. The file is established for the information provided by the insurance companies and includes their claims history in the last five years, in the terms expressed in the Law on Civil Liability and Insurance.

      We inform you that the data on your car insurance policy and claims will be transferred to this common file.

      The Common File of total loss, fire and theft in automobile insurance. The purpose of the aforementioned file, produced with the information provided by the insurance companies, is fraud prevention and detection, either by warning the insurance company when the Insurance is purchased, or by detecting fraud already committed in reported claims. The file contains the entire information contained in your insurance contract, including your personal data, as well as the claims reported and payments received. Furthermore, in order to locate vehicles that have disappeared due to theft, the ZARAGOZA CENTRE and the Law Enforcement Forces and Agencies will have access to the information, for the sole purpose of carrying out the pertinent checks on vehicles that are located in order to inform the insurance company of them being available to the owner or, in the event that compensation has been paid for the vehicle, the insurance company itself.

      You are informed that in case you have an accident in which there is total loss, either through damage, fire or theft, the data on your automobile Insurance Policy and information related to the accident will be transferred to that common file.

      If you wish to exercise rights of access, rectification, cancellation and opposition, you can contact TIREA, Ctra. Las Rozas a El Escorial Km 0,3 Las Rozas 28231 MADRID, having to identify yourself by ID, Passport or Residence Card or any other valid identifying document and, if acting through a representative, specific authorization of the interested party, all of this with the purpose of impeding the exercise of rights to those who are not the interested party. In the event that the address in the identity document is different from the address requested for sending information documents and correspondence, the address shown on the identity document will be used, unless stated otherwise and sufficiently demonstrated, since, on being a very personal right, the greatest safeguards must be taken to ensure that the person who exercises the right is the actual interested party, and to ensure the privacy and confidentiality of your data.

    • Insured Vehicles Database (FIVA).

      Under the Mandatory Automobile Liability Insurance, the Insurance Compensation Consortium is responsible for managing the Computerised File of Insured Vehicles (FIVA). All insurance companies operating in this insurance area are required, from the moment they start their operations, to report all registrations and cancellations of motor vehicles insured by them daily to FIVA.

    • Financial solvency files

      In the event that the policyholder has any due and payable debt with Línea Directa, and provided that the legal requirements for this are met, Línea Directa may communicate this non-payment to credit information files, specifically to ASNEF EQUIFAX, managed by the company Asnef- Equifax Servicios de Información sobre Solvencia y Crédito, S.L., and BADEXCUG, managed by Experian Bureau de Crédito S.A.

      Likewise, when deemed appropriate according to the nature of the transaction, Línea Directa will consult solvency files related to the compliance or default or the propensity to default or compliance with respect to financial obligations. If the policyholder is listed at any point in time on any of the files consulted, Línea Directa may decide not to enter into the contract, or not to renew the Policy with this client, without prejudice to the client’s right to claim against this decision.

    What obligations do I have when communicating my data?

    • The Policyholder, or whoever requests the purchase of the insurance, must notify Línea Directa of any changes that occur in the data provided. Furthermore, if details are provided about third parties, such as the insured, beneficiaries, injured parties, etc., their consent must be obtained and these clauses must be passed on to them so that they are understood to be accepted by them.
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