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THE PROTECTION OF YOUR DATA - AT THE HEART OF OUR COMMITMENTS

When you entrust us with your Personal Data you are creating a trust-based relationship, and we will do all we can to live up to this trust.

For that reason, we are making the protection of your data our highest priority.

Thus we will do all we can to provide your data with the best possible protection, and we are committed to ensuring it benefits from the highest level of security and confidentiality, in compliance with the applicable French and European regulations (regulation 2016/679/UE and law n° 78-17 passed on 6th January 1978 and subsequently amended), referred to hereinafter as ‘ the applicable Regulations ’.

Within this context, the commitments contained in our policy with regard to the processing of Data have has their basis the following 6 basic principles :

• A sound legal basis : the collection and processing of your Data of a Personal Nature is legitimate and has a specified legal basis that corresponds to the objective (or purpose) and the context of the processing operation.
• Relevance of the data : we only use your data for the previously-defined purpose, and only collect the data that are strictly necessary for achieving this purpose.
• Retention period : we establish the period for which your data will be retained, taking account of the objectives of each processing operation and any relevant legal obligations.
• Security and confidentiality : we place great emphasis on keeping your data protected and secure. Thus we deploy all necessary measures in order to guarantee the confidentiality of these data, and to prevent any breach, loss or damage affecting them, or any disclosure of them to unauthorized parties. These measures are designed in the light of the risks inherent in each processing operation (sensitivity of data, objective of processing operation, etc.).
• Transparency : we operate with transparency, keeping you informed when collecting your Data of a Personal Nature of the way in which we are using them and then of any sharing of the data with third parties.
• Respecting your rights : we are careful to respect your rights, informing you of the purpose for which your data is being processed. You have the right to access, rectify and delete these data, or to object to their collection.

Set out in the General Terms and Conditions of Use for our websites and smartphone apps and in our Privacy policy, is a full statement of our commitments and your rights, and an explanation of the way in which we collect, use, if applicable share, and store your Personal Data.

PRIVACY POLICY

Last updated : February 2022

This Henner Privacy Policy has been drawn up in order to inform you of the terms and conditions governing the collection, processing and use of your Personal Data, and of the rights you hold over these data when using our Site.

Henner reserves the right to amend this Privacy Policy at any time to reflect changes in its websites and smartphone apps, configurations, internal changes in Groupe Henner, or in the relevant regulations, modifications to the procedures for collecting, processing or using your Data of a Personal Nature, or indeed for any other legitimate reason.

Henner will notify you whenever its Privacy Policy is updated. We would however advise you to check on a regular basis for any amendments made to the Policy. The most recent modifications were made by Henner on the date indicated at the start of this document.

1- DEFINITIONS

Within the context of this Privacy Policy, the capitalized or non-capitalized terms listed below shall have the meanings indicated:

Broker : shall designate the natural or legal person who carries out, for remuneration, an insurance or reinsurance intermediation activity.

Data or Personal Data : shall designate any information relating to a Data Subject.

Data subject : shall designate an identified or identifiable individual ; the term ‘identifiable individual’ shall denote an individual who can be directly or indirectly identified, notably through reference to an identifier, such as a name, an identification number, location data, a username, or one or more elements specific to his or her physical, physiological, genetic, psychological, economic, cultural or social identity.

Data Controller : shall designate the individual or organization, public authority, department or any other body that, alone or in collaboration with others, determines the purposes of - and procedures for - the Processing of Personal Data.

Site :shall designate this website accessible to the Brokers pursuant to the partnership with Henner, under the terms of the General Terms and Conditions of Use, and in addition to them by this Privacy Policy.

Processing : shall designate any operation or set of operations that may or may not be carried out with the assistance of automated means and are applied to Data or sets of Data, such as collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, disclosure by transmission, circulation or any other means of provision, alignment or combination, or locking, deletion or destruction.

2- PERSONAL DATA PROTECTION

2.1 Which organization is processing your data?

Within the context of use of this Site, the Data are collected and processed by:

Henner, a ‘Société par Actions Simplifiée’ (simplified joint stock company), entered in the Nanterre ‘RCS’ (trade and companies register) under the reference number 323 377 739, with its registered office located at 14 boulevard du Général Leclerc 92200 Neuilly-sur-Seine.

2.2 How do we collect your data?

Your data are collected either directly by Henner when you input them on contact forms or questionnaires as part of the partnership with Henner or when you use the Site and other areas made available to you when you use the services provided on the Site or indirectly by third parties (notably by third-party cookies’ editors) when you browse the Site.

Henner will inform you when the provision of an information is required (notably due to a statutory regulatory or contractual obligation or else simply so that your request can be processed or your inquiry dealt with). Should you fail to provide information marked as “mandatory”, Henner may be unable to deal with the request or inquiry or to process the form concerned.

Those parts of a form that are not marked as “mandatory” are to be dealt with as you see fit - you may opt to complete them or not.

The following categories of Data are liable to be processed within the context of use of the Site :

• Data relating to your identity ;
• Data relating to your professional life in connexion with the commercial relationship between Henner and the Broker ;
• Data relating to the management of the commercial relationship between Henner and the Broker including the management of the partnership between Henner and the Broker;
• Data relating to fight against fraud ;
• Data regarding location and connection ;

2.3 Why do we process your data?

Your data are processed by Henner for the purposes, and on the legal basis, set out below:

2.4 Who can access your data?

Within the context of use of the Site, your data are principally intended for use by Henner but they may also be transmitted to entities within the Henner Group, to third-party cookies’editors or to service providers acting for Henner to carry out internal operations on the Site, notably hosting, maintenance, managing access, or for any operation connected to the activities of Henner for the purposes set out in article 2.3 of this document, but only to the extent that this is required in order to carry out the operations with which they have been tasked. The subcontractors concerned are required to maintain the confidentiality and security of your Data and to deploy the appropriate measures in this connection.

2.5 Where are your data hosted?

Henner undertakes, within the context of its activities and in accordance with the applicable Regulations, to deploy all the appropriate technical and organizational measures to ensure the security, availability, integrity, authenticity and confidentiality of your data, as well as the resilience of its IT systems.

Henner shall favour the hosting and processing of your Data in France or within the European Union (EU).

However, your Data may be transferred to countries outside the EU for the purposes specified above, particularly to entities of the Henner Group* or to third parties as specified in Article 2.4 above. In this case, to guarantee an appropriate level of protection of your Data, transfers of these data are regulated by Standard Contractual Clauses of the European Commission or by any other legal instrument, thus guaranteeing as a high a level of protection as in France.

*Current list of entities of the Henner Group outside the EU: Tunisia, Switzerland, Malaysia, Hong Kong, Kenya, Ivory Coast, Singapore, Canada and USA.

2.6 How long will we retain your data?

Your Data will be retained for the period required for achievement of the purposes set out above, plus the applicable legal provision.

2.7 What are your Rights and how can you exercise them?

In accordance with the applicable Regulations and under the conditions stipulated by these Regulations, you have the following rights:

• Right of access: to obtain information regarding the processing of your Data, and a copy of said Data;
• Right to rectification: to have your data corrected if they are inaccurate or incomplete;
• Right of erasure: to have your data removed, provided you meet the conditions laid down by the applicable regulations;
• The right to withdraw your consent at any point after you have given it ;
• Right to object: to object at any point, for reasons arising from your particular circumstances, to any processing of your Data, unless Henner demonstrates that there are legitimate and compelling reasons for the processing that override your interests, rights and liberties, or that the processing operation(s) are required for the demonstration, exercise or defence of rights within the context of legal proceedings;
• Right to Data portability over the Data that we have received from you and that we require for the contract, or for which your consent was requested;
• Right of restriction of processing: to limit the usage of your Data to retention alone, provided you meet the conditions laid down by the regulations ;
• The right to specify guidelines concerning the fate of your Data after your death.

You may exercise these rights upon request, providing proof of your identity by any means and explaining the purpose of your request, via the following email address : dpo@henner.com or postal address : Henner, Délégué à la protection des données, Conformité/Relation Assureurs, 14 Boulevard du Général Leclerc 92 200 Neuilly sur Seine.

Finally, should a dispute regarding your data persist, you also have the right to lodge a complaint with the CNIL data protection authority :

• either directly via the CNIL website : www.cnil.fr
• or by post : 3 Place Fontenoy – TSA 80715 – 75334 Paris Cedex 07.

3. COOKIES AND OTHER TRACKING FILES

The Site may automatically collect information by means of cookies or tracking files received when you visit the Site.

For more information regarding the cookies that we use and the means by which you can deactivate them, please consult our policy on cookie management accessible here.