Commitment for protecting your privacy
You’re now using the website of Petcover EU Agentur GmbH, where we offer personalised services as well as information about our company and services. Transparency and integrity during the processing of your personal data is very important to us. We comply with the data protection regulations, in particular the EU General Data Protection Regulation (“GDPR“) as well as those in the Austrian Data Protection Authority (Datenschutzbehörde, “DSB“) and the Insurance Contract Law (“VersVG“) as well as all other relevant laws.
Where this data protection declaration speaks of “Petcover” and/or ” we” and/or “us“, this relates in each case to Petcover EU Agentur GmbH.
I. Personal Data Responsibility
Our Data Protection Officer (“DPO“) can be contacted via the email set out below.
Responsibility for the personal data processing falls on
Petcover EU Agentur GmbH
Klostertal 60, 2770 Gutenstein, Österreich
DPO: Andrew Pearce
E-Mail: [email protected]
II. Basic Principals
We only process your personal data in compliance with the data protection regulations, where a statutory provision allows us to do so, or where you have granted consent. This also applies during the processing of personal data for marketing and advertising purposes.
In the scope of our Internet Services, we may also collect information that, taken as such, does not allow any identification of you in person. In certain cases – in particular in combination with other data – this information may still be regarded as “personal data” in the sense of the data protection laws. Further, we may, by way of the Internet Services, also capture such information that does not allow us to identify you either directly or indirectly; this is e.g. the case for aggregated information on all users of this Website.
III. Which data is processed by us? For which purposes and under what legal basis is the processing in effect?
You may access certain public parts of our Internet Service without providing us with your personal details (such as your name, postal address, or your email address). Also, in this case, we need to collect and store certain information in order to enable your access to our Internet Service. On our Website we use certain analysis tools and have integrated functionalities via third party providers. Further, we offer certain functionalities on our Internet Service for which we need to collect personal data.
We collect and process personal data on our Internet Service to the following extent:
- Logfiles: If you visit our Website, our web server will automatically store data and information relating to the device and browser you use. This could include technical information such as browser, system type, and IP-address. We process this technical information in the logfiles of our systems. We process the technical information in order to enable your access to our Internet Service, to secure the functionality of our Internet Service and the security of our IT systems, and to optimize our Internet Service. The legal basis for this data processing is Art. 6 para. 1 lit. f) GDPR.
- Registration, quote, application process: Within the scope of our Internet Service, we offer you the option to obtain a cost calculation for the desired insurance coverage and an offer to conclude an insurance contract. For this, we request your name, email address, and further details about you and in connection with the risk to be insured. This is necessary in order to establish insurability or, as applicable, the level of potential insurance premium for you. The processing of this data is necessary in each case in order to make the desired quote available to you for cost calculation and in order to be able to send you an appropriate offer via email, if necessary, with the provision of further information on the conclusion of an insurance contract. The processing therefore serves as preparation for entering into a possible insurance contract between us. Thus, the legal basis for the data collection and processing is Art. 6 para. 1 lit. b GDPR.
- Insurance contract including claims management: If you wish to accept the quote, you have the option to conclude the insurance contract with us directly online as previously explained during the application procedure. In this context, you might, upon receipt of our legal offer, also transmit your payment details for the purpose of paying the insurance premiums due and accept our offer online and may ask for your phone number to contact you if needed in relation to your insurance policy. Following the conclusion of your insurance contract, you will be able to access further information on your account at any time – in particular in connection to the insurance taken out – and potentially include further information or, as applicable, ask to book add-ons to your insurance contract. We will subsequently send you the insurance policy by email. To access your account as well as regarding the administration of your insurance contract, e.g. for the purpose of invoicing or handling of claims, we may request entering data already given during the registration and/or application procedure once again (in particular for the purposes of identification). Furthermore, we will ask for additional personal information and supporting evidence of your claim to prevent fraudulent claims. The legal basis of conducting the insurance contract between you and us is Art. 6 para. 1 lit. b GDPR.
- Policy management: During the period in which your insurance policy is active with us, we might need to process policy changes, and for that, additional personal information might need to be collected.
- Contact after the registration process started: If you have already started to enter the details required for your quote, including your email address, but have not completed it, we may contact you to remind you to complete your application, provided you have consented to receiving product updates and offers from us. The legal basis for this is therefore your consent according to Art. 6 para. 1 lit. a GDPR. You can always request to unsubscribe from further non-essential emails from us.
- Contact support: You can also contact us through the contact form on the website or by calling us. We collect all the data you provide and store it insofar as necessary to process your request. Calls are recorded for quality and training purposes. If necessary, data will be stored longer after completion of processing for reasons of preservation of evidence. The legal basis is Art. 6 para. 1 lit. a, b, f GDPR.
- Fraud Prevention: In certain cases, we will store and process the personal data collected from interested parties even if no insurance contract is concluded. This is to detect and prevent fraud, attempted fraud, and/or other harmful and/or illegal activities. This serves to maintain our justified interests in the prevention of fraud, and illegal and harmful behaviour. The legal basis is Art. 6 para. 1 lit. f GDPR.
- Advertising information by email: If you have agreed to receive product updates and offers from us, we will process your email address, and potentially, information included in your account based on your corresponding consent, in order to be able to send you information with regard to our services, offers, and activities in the areas of household and liability insurance. You can always request to unsubscribe from further non-essential emails from us. Further, we might assess data collected during the delivery and retrieval of our emails for analytics purposes and to improve our communications. Your personal data in connection with an email subscription will not be disclosed to third parties for any purpose other than to allow us to technically send out communications and analyse the results of our communications through our technical providers. We will process your data exclusively for the selection of individualized content and for sending out product updates and offers within the scope of your consent granted. The legal basis is Art. 6 para. 1 lit. a GDPR.
- Statistical evaluations: Where necessary, we may assess your personal data for the purpose of evaluating your preferences to enable interest-orientated marketing, individual addressing, and a continuous optimization of our business processes in a statistical form. We do this in order to get a better understanding of what our customers expect from us. Further, these evaluations help us in the detection of fraud, and the revision and maintenance of security; we conduct this data processing in order to maintain our justified interests; the legal basis is Art. 6 para. 1 lit. f GDPR.
- Social Plug-ins: On our Website, we may use plug-ins of social network sites that allow you to conduct activities with regard to content on our Internet Service (also “Social Plug-Ins”). If you are registered in the respective social network and logged in to it, you may communicate directly with the social network. You may also prevent the loading of Social Plug-Ins with add-ons for your browser e.g. with the script blocker “NoScript” (http://noscript.net/). The legal basis for the provision of social plug-ins on our Internet Service is in our justified interests regarding the design of our Internet Service, in accordance with the needs of our users, Art. 6 para. 1 lit. f GDPR.
- Further justified interests: Where required, we may process your data beyond the purposes mentioned above, for the purpose of maintaining our justified interests or for the interests of third parties; this is based on Art. 6 para. 1 lit. f GDPR. Some of our justified interests are:
- the assertion of legal claims and defence of legal disputes;
- the prevention and the solving of crimes;
- the steering and the further development of our business activities including risk management;
- the prevention of fraud;
- the ability to identify and resolve technical bugs in the system;
- the ability to provide customer support (which is also based on the customer’s consent pursuant to Art. 6 para. 1 lit. a GDPR); and the possible sharing of information as part of a corporate transaction or merger;
- and the possible disclosure of information in the context of a corporate transaction or merger.
Further information on the cookies used by us, their purpose, and legal basis have been compiled by us for you below.
Please also note that some cookies are necessary for the functioning of our website and therefore cannot be disabled (‘Essential Cookies’). Other cookies are used by us for analytics and marketing purposes and these may be disabled from our cookie banner when you first log into our website.
- Advertising Networks: We may in particular use third party providers such as advertising networks and advertising exchange programs which enable us to include advertising for you on the sites of third parties. The operators of these external advertising networks and advertising exchange programs may, in the case of you consenting, use third party cookies, pixel or similar technologies in order to collect data (Art. 6 para. 1 lit. a GDPR). In some cases, we will place cookies or a pixel on our own site in order to identify cases where a user gets to our Website through advertising placed on another website and completes certain activities (e.g. registration, or application for a quote or conclusion of a contract), for the purpose of remuneration of the advertising partner, in which we have a justified interest (Art. 6 para. 1 lit. f GDPR).
On our instruction, Google uses the transmitted data to evaluate your use of our internet presence, compile a report on the activities on the Website, as well as to render further services for us regarding the use of our Websites. (Therefore, there is a commissioned data processing agreement in place between us and Google). The use of Google Analytics therefore serves the purpose of continuously improving our internet presence and to optimise your user experience. These activities are in our justified interest regarding the data processing (Art. 6 para. 1 lit. f GDPR). Further, by clicking a button on our cookie banner on our Internet Service, you expressly agree to the processing of the collected data by Google in the manner, and for the purposes as described above (Art. 6 para. 1 lit. a GDPR).
If you wish to deactivate or change Google Analytics only in respect of the presentation of content tailored to your interests, including advertising, this can be adjusted under “Google adverts on the web” in the settings for Google Adverts.
Further information regarding the purpose and scope of the data collection as well as regarding the further processing and use by Google, including information on your rights or, as applicable, options for configuration for the protection of your personal data can be found under the following links: http://www.google.com/analytics/terms/de.html as well as under https://policies.google.com/privacy?hl=en-US.
- Google Tag Manager: We also use Google Tag Manager. With this service, website tags can be administered via an interface. Google Tag Manager solely implements tags. This means that Google Tag Manager does not place any cookies and no personal data is collected. Google Tag Manager triggers other tags that potentially collect data, but Google Tag Manager does not access this data. If, at domain or browser level, a deactivation of certain websites is affected (see details on the deactivation of cookies given above), this remains in place for all tracking tags to the extent that these are implemented with Google Tag Manager.
- Google AdWords / conversion tracking: On our Internet Service we also use, having gained your consent, (Art. 6 para. 1 lit. a GDPR) the online advertising program “Google AdWords,” and within the scope of this, its conversion tracking. With this, Google AdWords inserts a cookie or a pixel on your computer or, as applicable, on the storage of your mobile device, if you were directed to our Internet Service via a Google advert. These cookies are no longer applicable after 30 days. They do not serve for any personal identification. If the user visits certain pages of our Internet Service and the cookie is still active, both we as well as Google are able to see that you clicked on the advert and were forwarded to our site. We, as well as all other clients of Google-AdWords, receive different cookies. The cookies affected by our Google adverts can therefore not be followed beyond our Internet Service.
The information obtained from the conversion tracking serves to compile statistics on the conversion for us. With this, we learn about the total number of users who clicked on an advert and were forwarded to a site provided with a conversion tracking tag. However, we do not receive any information that would allow your potential identification.
If you do not wish to take part in conversion tracking, you may deactivate the conversion cookie in the settings of your browser. More information on this can be obtained from the Google Data Protection Statement.
You may also adjust your settings for Google Advertising in the Google settings for advertising.
- Facebook Pixel: After gaining your consent, our Website has a re-marketing pixel from Facebook. Via this pixel, a direct connection to the servers of Facebook is provided during your visit to our Website. Through this, it is transmitted to the Facebook server that you have visited this Website and Facebook will assign this information to your personal Facebook user account. To protect your privacy, we do not use the so-called “extended alignment” function, in which this information could be enriched with further personal data (e.g. email address).
IV. Are you obliged to provide us with your data?
The details required for the conclusion of an insurance contract, as well as the information by email, are in the respective areas of the Internet Service (e.g. in an online form) and marked as mandatory information; without providing the mandatory details, we are unable to allow you the use of the respective functionality.
V. Who will receive your data?
Depending on the type of personal data that is processed by our company, only certain departments / organisational units have access to your personal data. These include, in particular, our expert departments concerned with the provision of our services and our IT department. Based on the concept of roles and entitlements, the access is, within our company, limited to those functionalities and such scope as is required for the respective purpose of processing.
We may also transfer your personal data within the legally allowed scope to third parties outside of our company. These external recipients may include, in particular:
- Affiliated companies (in particular Petcover EU Ltd), to which we transfer personal data for internal administrative purposes, management and servicing of our insurance product, data analytics, marketing, backoffice, the provision of hosting services and IT services required for the operation of this Website;
- The service providers instructed by us, such as e.g. in the areas of marketing, IT (in particular hosting or disaster recovery), or payment administration who provide services to us on a specific contractual basis, which may include the processing of personal data (in particular we utilise payment service providers for incoming payments. Some of these may have providers having establishments outside the EU / EEA, in particular in the US, Australia or India.
- Non-public and public agencies to the extent that we have legal obligations to transmit your personal data.
- Insurance companies (“insurers”) that insure you. In order for our insurers to be able to insure you, it may be necessary to provide our insurers with information relating to your insurance contract and your claims.
We will transfer your data to external recipients only insofar as this processing is necessary for purposes as permitted by law.
VI. Will an automated decision-making process be used?
We utilize automated decision-making in connection with the provision of our Internet Service. Automated decision-making, as defined in Article 22 of GDPR, may include profiling, which is any kind of automated processing that utilizes personal data in order to evaluate certain aspects of a natural person. The automated decision-making is based, in addition to other factors, on the information you provide during the quote process. We will use automated decision-making to evaluate the information you provide to us to calculate your individual risk profile in order to determine whether we can extend insurance coverage to you, and if so, what your insurance coverage limits and premiums will be, or to process claims you submit.
Under certain applicable laws, you may have the right to certain safeguards as they relate to automated decision-making. Specifically, you may be able to request that the result of the automated decision-making process is recalculated by a human, to express your views related to or contest the result of the automated decision-making process, and receive notification of the contestation outcome. In order to exercise these rights, or for more information about automated decision-making, please contact us at the information provided below. By applying for insurance, you acknowledge that you understand that automated decision-making or profiling may be used as described in this policy and you consent to Petcover’s use of those methods.
VII. Is data transmitted to countries outside the EU / EEA?
In certain cases, there may be a transmission of information to recipients in so-called “Third Countries.” Third Countries are countries outside of the EU or the EEA, and it cannot automatically be assumed that their data protection levels are in line with those in the European Union.
To the extent the transmitted information includes personal data, and we are not required to perform such transmission due to a legal obligation, we secure prior to such transmission that in the respective Third Country or by the recipient in the Third Country, the required appropriate data protection level is met. This may result, in particular, from a so-called “adequacy decision” by the European Commission, by which an appropriate data protection level is determined for a Third Country as a whole. Alternatively, we may base the transmittal of data on the so-called “EU Standard Contractual Clauses.
VIII. How long will your data be stored?
In general, we will store your personal data only as long as we have a justified interest in this storage, and your interests in discontinuation do not overtake the justified interest.
Additionally, without any justified interest, we may continue to store your data where we are statutorily obliged to do so (e.g. for the purpose of fulfilling archiving requirements). We will delete your personal data without any action from your side, as soon as access to the data is no longer necessary to fulfil the purpose of processing, or the storage is otherwise illegal.
The personal data we need to store for the purpose of compliance with retention duties will be stored until the end of the corresponding retention period. Where we store personal data exclusively for the purpose of fulfilling archiving duties, it is normally blocked so that access is only possible where this is required with regard to the purpose of the retention duty.
IX. What are your rights?
- Right to object according to Article 21 GDPR:
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, based on Article 6 para. 1 lit. e or f GDPR, including profiling according to Art. 22 GDPR based on those provisions. In the event of your objection, 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 where the processing serves for the establishment, exercise or defence of legal claims.
Where we process your personal data for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where you object to processing for direct marketing purposes, the concerned personal data shall no longer be processed for such purposes.
You have the possibility, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise your right to object by automated means using technical specifications.
- Further rights of affected persons: Based on the following provisions, you as a data subject have the right:
- to obtain information on your personal data which is stored, Art. 15 GDPR;
- to have incorrect or incomplete data corrected, Art. 16 GDPR;
- to deletion of personal data, Art 17 GDPR;
- to a restriction of the processing, Art 18 GDPR;
- to data portability, Art. 20 GDPR.
Further, you are entitled at any time to file a complaint with the responsible supervisory authority for data protection, Art. 77 GDPR.