Privacy and Data Protection Policy

1. INTRODUCTION

Concentra Global Corretores de Seguro, SA and the insurance sector have a solid track record of respecting individual privacy rights and protecting personal information. As a result of legislation, we have further strengthened our commitment to privacy by informing you why and how we collect, use, and disclose your personal information. You can be assured that we will only process personal information in a manner that is reasonable and appropriate to the circumstances.

This Privacy Policy (“Policy”) was developed with the aim of informing you of the principles and obligations to which we are committed regarding data protection.

See the details of our Personal Data Protection Policy here.

2. RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

Concentra Global Corretores de Seguro, SA, with registered office at Rua Embaixador Martins Janeira, nº 14 – 2º, 1750-097 Lisboa, is the entity responsible for processing your personal data.

Concentra Global Corretores de Seguro, SA, as the data controller, promotes the confidentiality and privacy of the data collected, ensuring its protection and proper use in accordance with the terms defined in this Policy.

3. PROCESSING OF PERSONAL DATA

The data provided is processed in accordance with applicable legal requirements, namely:

Treated in a lawful, fair and transparent manner;
Collected for specified, explicit and legitimate purposes and will not be further processed in a way that is incompatible with those purposes;
Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
Accurate and, where necessary, kept up to date, with appropriate measures being taken to ensure that inaccurate or incomplete data are erased or rectified, taking into account the purposes for which they were collected or for which they are further processed;
Stored in a way that allows identification of their owners only for the period strictly necessary and within what is legally permitted for the purposes of collection or subsequent processing.

4. COLLECTION OF DATA FROM OTHER SOURCES

Concentra Global Corretores de Seguro, SA may collect information regarding the policyholder that is relevant for assessing the risk to be insured and setting the contractual conditions of the insurance, from publicly accessible sources, public bodies, industry associations or specialized companies, to supplement or confirm the information provided by the policyholder, within the scope of managing the pre-contractual and contractual insurance relationship.

5. PURPOSES OF PROCESSING COLLECTED PERSONAL DATA

The data processed varies depending on your relationship with Concentra Global Corretores de Seguro, SA, namely:

Customer Data: customer management (administrative management, execution of insurance contracts, acquisition or renewal of policies, policy management, conducting studies for the development of new products and services adapted to customer preferences and characteristics, and carrying out marketing actions, product-oriented or customer-oriented, assessment of insurance needs, ensuring the accuracy and updating of data, invoicing, payment of premiums, among others), prospects (conducting simulations) and prevention of errors or fraud;
User Data from Websites/Platforms: registration on the responsible brand's websites/digital platforms and management of their functionalities;
Partner and Supplier Data: management of the contractual relationship, invoicing and collections, management of the provider network – when applicable;
Data from individuals who contact Concentra Global Corretores de Seguro, SA, whether in the context of a commercial relationship, filing a complaint, reporting a claim, or other matters, to the extent necessary for managing that contact;

The processing of personal data of data subjects, whether provided by them or arising from the contractual relationship, is based on the following principles, aiming to guarantee adequate transparency and lawfulness:

Managing the contractual relationship;
Pre-contractual due diligence;
Formation, management and execution of insurance contracts, including pre-contractual due diligence and procedures necessary for the settlement of claims or the provision of contracted services;
Quality control of services provided (in the latter case based on the legitimate interests of the data controller);
The personal data requested and processed are a necessary requirement for achieving the described purposes. If the data subjects do not provide their personal data, it is not possible to formalize and execute the insurance contract.
The personal data collected within the scope of the service relationship with Concentra Global Corretores de Seguro, SA will be used to ensure the provision of information on products and services, in line with legitimate interest, and these actions will not be directed towards the Client's profile, but will be established within the framework of relationship and service expectations.

As mentioned, personal data such as telephone contact and email address may be used for service communications and/or to provide information about the products/services of Concentra Global Corretores de Seguro, SA, provided that the aforementioned terms are met, namely if there are no impacts on your rights, freedoms and guarantees, in line with a transparent, objective and fair relationship.

Concentra Global Corretores de Seguro, SA will only process data from special categories when necessary under its relationship with us.

Under any circumstances, we will only process these special categories of data based on one of the following grounds:

When necessary for the fulfillment of obligations/exercise of rights regarding labor legislation, safety, or social protection;
When the data has been manifestly made public by its owner;
If the processing is necessary for the establishment, exercise or defense of a legal claim;
If treatment is necessary for reasons of important public interest;
If treatment is necessary for preventive or occupational medicine purposes, or to assess the employee's ability to work;
Because you have given us your consent, in cases where this will be the legal basis for processing your data.

6. To whom do we share your personal data?

Concentra Global Corretores de Seguro, SA may share the collected data with other entities, such as:

(i) The Insurance Supervisory Authority for compliance with legal obligations;

(ii) To subcontractors, so that they may process data under its instructions and on its behalf (including mediation, execution of activities within the scope of the insurance contract, development of commercial and marketing actions, software development companies, equipment maintenance services, professional training services, accounting and consulting services, financial services, and security services). When this occurs, Concentra Global Corretores de Seguro, SA ensures that the subcontractors offer sufficient guarantees of implementing appropriate technical and organizational measures so that the processing complies with the legal and regulatory requirements in force and ensures the protection of the rights of data subjects;

(iii) Insurers in the context of claims settlement; These entities are required to develop appropriate technical and organizational measures to protect data and ensure the protection of data subjects' rights.

(iv) To reinsurers and co-insurers;

(v) Service providers that provide services to Concentra Global Corretores de Seguro, SA; These entities are obliged to develop appropriate technical and organizational measures to protect data and ensure the defense of the rights of data subjects.

(vi) Third-party entities:

when the communication of data is necessary for compliance with legal obligations or court orders,
to satisfy requests from public or governmental authorities (such as the Tax Authority, the Authority for Working Conditions, the Mobility and Transport Authority, Social Security, the Insurance and Pension Funds Supervisory Authority, Compensation Funds, (among others);
other entities that pursue relevant public interests, such as APS – the Portuguese Association of Insurers;

In any of the situations mentioned above, Concentra Global Corretores de Seguro, SA will take appropriate measures to ensure the protection of personal data.

7. How do we protect your data?

To protect personal information and the right to privacy, we are committed to:

We will not collect, use, or disclose your personal information for any purpose other than those we have identified in the shared documents.
We will retain personal information only for as long as is necessary to fulfill the stated purpose or as required by law.
Keep your personal information as accurate, complete, and up-to-date as possible.
Protecting personal information to the best of our ability.
To respond to any request you may make to access or correct the personal information we hold.
Obtain your appropriate consent for the collection, use, or sharing of personal information – provided that it is a lawful source suitable for the specific purpose in question.

Concentra Global Corretores de Seguro, SA adopts appropriate technical and organizational measures to protect Personal Data against accidental or unlawful loss, destruction or damage, and to ensure that the data provided is protected against access or use by unauthorized third parties. Concentra Global Corretores de Seguro, SA guarantees the privacy and security of the transmission of data from its clients and visitors to its websites, and of all information exchanged via the Internet.

8. What are the rights of the data subject?

The holder of Personal Data has the right to request from Concentra Global Corretores de Seguro, SA, by means of a written request addressed to the Data Protection Officer:

Access, under the terms and conditions legally established, to Personal Data concerning you that is processed by the same;
The correction or updating of inaccurate or outdated Personal Data concerning you;
The processing of missing Personal Data when it proves to be incomplete; – The erasure, in cases specifically provided for by law, of Personal Data concerning you;
The limitation, provided the conditions stipulated by law are met, of the processing of Personal Data concerning you.

Upon written request addressed to the Data Protection Officer, the data subject also has the right to:

Withdraw the consent given, when the data processing is based solely on consent;
To object to the processing on grounds relating to your particular situation, where the data processing is based on the legitimate interest of the data controller;
To receive from the data controller, in a commonly used and machine-readable digital format, the personal data concerning you that you have provided, processed by automated means based on:
1. with consent given by the data subject or,
2. in a contract entered into,

They may request, in writing, that the information be transmitted directly to another responsible party, whenever this proves technically feasible.

The Data Subject may also request more detailed information from the Data Protection Officer, specifically regarding the purposes, legal basis, and retention periods, as well as file complaints with them about how their Personal Data is processed, without prejudice to their right to do so with the competent Authority.

9. Automated Decisions

Within the scope of the processes of subscribing to and renewing insurance contracts or operations, Concentra Global Corretores de Seguro, SA may use automated decision-making solutions that are necessary for the conclusion and execution of the respective insurance contract or operation, using information concerning the policyholder or insured parties obtained within the framework of the management of the contractual or pre-contractual relationship, which may result in decisions regarding the contractual conditions applicable to the subscription or renewal. The holder of Personal Data may also request more detailed information from the Data Protection Officer about the logic underlying the processes in question, within the framework of the subscription and renewal of contracts, namely, about the information taken into account for exclusively automated decision-making and how it integrates into the decision-making process. In all cases where Concentra Global Corretores de Seguro, SA makes decisions based exclusively on automated data processing, the respective processes will include, at least, mechanisms that give the data subject the possibility to: (i) express their point of view; (ii) contest the decision; and (iii) request and obtain human intervention in the review and decision-making process.

10. CHANGES TO THE PRIVACY POLICY

This Privacy Policy may be amended periodically by publication on the website of Concentra Global Corretores de Seguro, SA, without the need for prior and express consent from the data subject. Any significant changes will be communicated with a degree of publicity corresponding to their relevance, either through highlighting in the online publication or, if the relevance justifies it, through individualized communication to the data subjects.

11. DATA RETENTION PERIOD

Term	Purpose
50 years	Claims management, personal injury or pension funds; Litigation processes; Compliance with tax obligations; Management of insurance contracts; Reporting obligations to the ASF (Portuguese Insurance and Pension Funds Supervisory Authority).
10 years	Claims management for property damage
7 years	Money laundering prevention Marketing actions
3 years	Complaints Management
1 year	Customer Satisfaction Assessment: Monitoring of commercial actions

12. CONTACTS AND CLARIFICATIONS REGARDING THE PRIVACY POLICY

For clarification of any questions regarding the Privacy Policy of Concentra Global Corretores de Seguro, SA or regarding any form of data processing, as well as for exercising your rights and/or submitting complaints, you should contact us through:

Address: Rua Embaixador Martins Janeira, nº 14 – 2º, 1750-097 Lisbon
Telephone: 213 600 120
Email: dpo@concentragrupo.pt

You also have the right to complain to the National Data Protection Commission (www.cnpd.pt).

Please do not hesitate to contact us if you have any questions.