Data Protection Policy - Allianz Insurance

Data Protection Statement

This privacy statement/notice tells you how we use your information and confirms that your Data Controller is Allianz p.l.c. (“we”, “us”, “our”), Allianz House, Elm Park, Merrion Road, Dublin 4, D04 Y6Y6. Email: click here. Our Data Protection Officer is contactable at: DataProtectionOfficer@allianz.ie or please write to The Data Protection Officer, Allianz p.l.c., Allianz House, Elm Park, Merrion Road, Dublin 4, D04 Y6Y6.

Direct Allianz Customers - Data Protection Statement – Allianz p.l.c. Fair Processing Notice

This privacy statement/notice tells you how we use your information and confirms that your Data Controller is Allianz plc (“we”, “us”, “our”), Allianz House, Elmpark, Merrion Road, Dublin 4, D04 Y6Y6, Ireland. Email: info@allianz.ie. Our Data Protection Officer is contactable at: DataProtectionOfficer@allianz.ie or please write to The Data Protection Officer, Allianz plc, Allianz House, Elmpark, Merrion Road, Dublin 4, D04 Y6Y6, Ireland.

1. What Personal Information We Collect

Type of Information

The type of information we collect and use will differ depending on the type of product or service you have with us but includes (please note that this is not an exhaustive list):

Name, address (including Eircode), date of birth, policy numbers, contact details (mobile number and email address for customer identification and digital communication purposes), PPS number (or any other relevant tax identification numbers) (if required by legislation), occupation, employment details, gender, IP address, insurance requirements including details about your home or vehicle, years of residency in Ireland or the UK, driving licence details, the intended use of the vehicle (social, domestic, pleasure, commute to work or education), marketing preferences and renewal dates of policies with other insurers, claims history, bank and payment card details, records of payments and arrears, VAT and other relevant tax numbers, CCTV footage, membership status of any relevant bodies, penalty point information and Road Traffic offences, telematics data, dashboard camera video footage, credit score and on-board vehicle diagnostics information. Further details of information we collect can be found under specific headings in this Data Protection Statement.

Other People’s data:

As well as collecting your personal data, we may also use personal information about other people, for example, family members you wish to insure on a policy, dependents (where relevant for suitability purposes), insured persons (where different from the applicant/policyholder) family health history of insured persons, limited personal information about trustees/beneficiaries (where policies are under trust), executors, nominated representatives and attorneys (under power of attorney).

If you are providing personal information about another person in paper or electronic format or video we require you to let them know what information you've shared with us, share this data protection notice with them and ensure that they have given you permission to provide this information to us. If you or they have any concerns please ask them to contact us in one of the ways described in this notice. Special categories of data of other’s people will be processed solely if they are necessary for the provisions of a policy of insurance and for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

Sensitive information

We may ask for health information or details of past or pending offences, unspent criminal convictions or other sensitive information about the person who is being insured, their family members or any other persons associated with the insurance policy. We recognise the sensitivity of collecting this information, so we will only ask for it to arrange, manage or administer an insurance contract, handle claims, or prevent fraud. Where we process health data for the purpose of a policy of insurance we will take suitable and specific measures to safeguard the fundamental rights and freedoms of individuals.

Given the fact that data relating to health and criminal convictions is particularly sensitive information, we only collect and use such data as follows:

Purpose: Health data is used for the purposes of obtaining/providing quotes and providing insurance services; to assist in the administration of a policy, including fraud prevention and investigation, handling a complaint or processing a claim you may have.

Basis: Irish Data Protection law permits us to use health data where we need to and where it is proportionate for the purposes of a policy of insurance.

Purpose: Unspent Criminal conviction data is collected and used for the purposes of obtaining/providing quotes and providing insurance services; to assist in the administration of a policy, including fraud prevention and investigation, handling a complaint or processing a claim you may have .

Basis: Performance of a contract: under which we provide insurance services and assisting in the administration of a contract (the insurance policy); and to take steps at your request before entering into a policy (e.g. obtaining/providing a quote)

We may also need to use your health and/or criminal data for the purposes of establishing, exercising or defending legal rights, including in connection with claims or proceedings and where authorised by law.

You do not have to provide us with any personal information, however, should you be unable to provide us with the required personal data, we will be unable to provide you with a quote, insurance or process a claim that you make.

2. How we collect your personal information

We may collect personal information about you from: you; your named driver (if you are purchasing or renewing a motor policy); joint policyholder; our intermediaries, your broker (or other representative), insured persons (where different from the applicant/policy owner); when you visit one of the Allianz Group websites (where you are purchasing or renewing a policy) or through cookies and other similar technologies when you visit our website or download and use one of our apps; when you visit a website aggregator; insurance industry databases and other commercial databases; third parties involved in a claim (including a claimant, private investigators engaged by us, witnesses, solicitors, health practitioners, medical representatives and independent experts); from public authorities; communicating with us via social media platforms; requesting any information from us; other people who live with you in an insured property (if you are purchasing or renewing a home insurance policy); your agents, attorneys (under powers of attorney), nominated representatives (including health practitioners and medical representatives) and other third parties relevant to you and/or the policy, including your legal advisers; publicly available information including social media websites and online content, newspaper articles, TV, radio and other media content, court judgements; telephone calls, which we may record, analyse with or without artificial intelligence or monitor for insurance, regulatory, training and quality purposes; other records within Allianz if you have or have had other insurance policies with or sought a quote from us or another Allianz company or third party claims; Insurance Ireland (insurance industry’s representative body) who operate a confidential phone line (Insurance Confidential) for individuals to report suspect fraud; and Credit referencing agencies.

Where you provide personal data relating to any person under the age of 16 years (“child”), Allianz will seek to verify that you are the parent/guardian of such a child. This is to ensure that you can authorise the processing of personal data relating to that child in order for Allianz to provide the insurance, deal with a complaint or claims.

3. How we use your personal information

Purpose: to obtain/provide a quote, for underwriting and pricing an insurance policy including making a decision as to whether we can provide you with cover and at what price; and to investigate, validate, arrange, handle, manage or administer a claim which you or another person makes in relation to your insurance policy.

Legal Basis: Legitimate interest in managing our business; for the performance of a contract under which we provide insurance; and in order to take steps at your request prior to entering into a contract of insurance.

Purpose: To provide you with insurance cover, administer and process your insurance policy, including dealing with any queries or changes, payments, renewals and processing a cancellation of your policy; make payments to you or receive payments from you; provide you with services such as breakdown assistance; processing of any complaints; and maintain and store records on our computer systems.

Legal Basis: For the performance of a contract under which we provide insurance.

Purpose: To verify your identity.

Legal Basis: In order to take steps at your request prior to entering into a contract of insurance; for the performance of a contract under which we provide insurance; to comply with legal obligations.

Purpose: To carry out financial sanctions checks and prevention of financial crime.

Legal Basis: For the performance of a contract under which we provide insurance; in order to take steps at your request prior to entering into a contract of insurance; to comply with legal obligations; and public interest.

Purpose: To comply with laws and regulations.

Legal Basis: To comply with legal obligations. For motor policies only, in compliance with the Road Traffic Act 1961 (as amended) we share details of your policy with the Motor Insurers Bureau of Ireland (The details on MIBI processing activity can be found on https://www.mibi.ie MTPL section), the Minister for Transport, Tourism and Sport and An Garda Síochána for the purposes of section 78A as autonomous data controllers.

Purpose: For marketing purposes, market research, customer satisfaction surveys, and data analytics including profiling, to develop and enhance our service and products, the customer relationship and the customer journey as part of our business strategy; for management information purposes including portfolio assessment, risk assessment, performance reporting and management reporting; for a proposed portfolio transfer, reorganisation, transfer, disposal or other transaction relating to our business; managing our business effectively (e.g. with third party service suppliers); for audit purposes and managing our legal affairs including exercising our legal rights and defending claims; to maintain arrangements we have with reinsurers; for quality purposes; to manage our IT security and network; to carry out statistical analysis and reporting to help improve services and products; staff training in how to perform their duties and provide a better service to you; monitor recorded customer calls to assess our staff’s customer service; analyse recorded calls also with artificial intelligence for quality monitoring, for customer journey and process improvement, for employee coaching; for compliance monitoring; for reporting purposes; analyse web chats conversations from our websites also with artificial intelligence to enhance the customer journey and to enable the machine learning element; to enable access to our websites using QR codes; provide online services; and to enhance our applications and product offerings.

Legal Basis: Legitimate interest in managing our business; to better understand our customers; improve product and/or service enhancement; and monitor and assess business performance.

Purpose: To detect and prevent fraud.

Legal Basis: For our legitimate interest in managing our business; in order to take steps at your request prior to entering into a contract of insurance;

for the performance of a contract under which we provide insurance; and to comply with our legal obligations.

If you are purchasing a policy, we also use certain information and consult certain databases as follows:

Information Used: logging of any new claims notifications and any claim settlement for damage and injury.

Purpose: to confirm your personal data and verify claims information and/or for prevention and detection of crime and fraud through the Claims and Underwriting Exchange Database and Insurance Link Anti-Fraud register.

Processing is necessary: for our legitimate interest in managing our business.

Information Used: address details.

Purpose: to verify address and surrounding location information using the Ecad Database.

Processing is necessary: in order to take steps at your request prior to entering into the policy or for the performance of your policy.

Information Used: vehicle registration number.

Purpose: to identify whether a vehicle has been taxed, NCT or if the vehicle has been involved in a claim or written off using the VRN system.

Processing is necessary: in order to takes steps at your request prior to entering into the policy or for the performance of your policy.

Information Used: Driving Licence Number.

Purpose: to validate your driving licence number with the relevant authority; to validate the number of penalty points disclosed by you; to validate the licence date and country of origin of the licence.

Processing is necessary: in order to takes steps at your request prior to entering into the policy or for the performance of your policy.

Information Used: registration number of your vehicle.

Purpose: provide information about your insurance policy for inclusion in the Motor Third Party Liability Database (MTPL); the information contained on this database may be used by government bodies such as an Gardai Siochana (Gardai) and the Motor Insurance Bureau of Ireland (MIBI) for purposes permitted by law, including electronic licensing and law enforcement.

Processing is necessary: to comply with legal obligations.

Information Used: registration number of your vehicle.

Purpose: If you have a commercial motor fleet or motor trade policy, you will be issued with a Unique Identification Number by your insurer to upload your personal information on to the National Fleet Database. We and other government bodies such as the Gardai and MIBI can check this database for the information you have uploaded. For further information, please go to www.nfd.ie.

Processing is necessary: in order to take steps at your request prior to entering into the policy or for the performance of your policy; and. to comply with legal obligations.

Information Used: vehicle registration number and No Claims Discount (NCD) PIN.

Purpose: When we provide you with a quote or renew your policy of motor insurance, we access the National Vehicle Data File controlled by the Department of Transport, Tourism and Sport to validate: driver numbers; and number of penalty points per driver.

Where you provide us with an NCD PIN number, we will verify your No Claims Discount information using the IIDS Hub, where such information is made available by your previous insurer.

Processing is necessary: in order to take steps at your request prior to entering into the policy or for the performance of your policy.

4. How we share your personal information with others

We may share your personal information with: the Allianz Group, our agents, third parties who provide services to us (engineers, repairers, motor assessors, loss adjustors, expert appraisers, expert witnesses etc.) your intermediary and other insurers (either directly or via those acting for the insurer such as loss adjusters or investigators); providers of essential services (e.g. telecommunications, postal/courier providers, IT service providers, software providers, card payment processor in their role as independent data controllers https://www.aibms.com/privacy/); other third parties involved in administering your contract; regulatory bodies and law enforcement bodies, including the Garda (for example, where we are required to do so to comply with a relevant legal or regulatory obligations); reinsurers who provide reinsurance to Allianz (reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations; they will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies); witnesses to any accidents/incidents to which you are involved; any party you have given us permission to speak to (e.g. your representative, a relative or a friend); any party named under your insurance policy; industry and trade bodies; and claimants and their legal or medical representatives.

The personal information you provide may be used by us and shared with other insurers as well as certain statutory and other authorised bodies for anti-fraud purposes: other insurance companies to confirm information provided (including where you are purchasing a motor insurance policy, for the purposes of validating any No Claims Discount) and to safeguard against non-disclosure and help prevent fraudulent claims; public bodies including the Department of Tourism, Transport and Sport, the Department of Finance and the Gardai; the Insurance Link Anti-Fraud register (for more info see www.inslink.ie) to prevent and detect fraud; the Integrated Information Data System (IIDS) to verify information including penalty points and No Claim Discount (NCD) to combat fraud; the Motor Insurers’ Bureau of Ireland (MIBI) to assist in preventing or detecting theft and fraud and to pay claims; private investigators, tracing debtors or beneficiaries, recovering debt, managing your accounts and/or insurance policies; vehicle history check suppliers/ databases to protect our customers, inform our acceptance criteria and assist in claims investigations; and other fraud prevention, ID verification databases available in the insurance industry and publicly available information to detect or prevent possible criminal activity or fraud.

We will use your personal information to detect and prevent fraudulent practices and fight financial crime to meet our regulatory responsibilities. If you purchase a product from our website or other Allianz sales channel, we will also ask you for payment details. We need this information so we can process the payment associated with any product purchased. We collect information to help us improve our products and services and let people know about products and services that we believe will be of interest to them. This may be through a range of channels including via email, online advertising or social media. We will always do this in accordance with marketing preferences provided.

Where we obtain data from the above sources, the categories we obtain will be personal data or claims information relating to insurance profiling, claims handling and fraud prevention. We may need your consent for the processing of certain data and in these cases, we will inform you of such processing and the reason for this at the time consent is captured.

Protecting Information Outside the European Economic Area

Your personal data may be transferred to and/or accessed from a country outside the European Economic Area (“EEA”). We will always take steps to ensure that any transfer of information outside the EEA is carefully managed to protect your privacy rights. Such transfer/access within the Allianz Group will be covered on the basis of the Allianz Group binding corporate rules (BCRs) which contractually obliges each member to ensure that your personal information receives an adequate and consistent level of protection wherever it is transferred within the Group. Where we transfer your data to a non-Allianz Group member or other companies providing us with a service, we will obtain contractual commitments and assurances from them to protect your personal information. These assurances are well recognised certification schemes like Standard Contractual Clauses. We will only transfer your personal information to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. Any requests for information we receive from law enforcement or regulators will be carefully validated before personal information is disclosed.

Representation

If you provide information about someone else, such as an additional insured, we will endeavour to provide this Data Protection Statement to them. Where it is not possible to do so, you must make them aware of this Data Protection Statement and the terms of the insurance (including changes to the terms or processing activities) and encourage them to read this Data Protection Statement to find out more.

Online Information

When you visit the www.allianz.ie website, we may record information about your computer or mobile device, including hardware and software used, general location, when and how you interact with our websites. This information is used to note your interest in our websites and improve customer journeys.

How long we keep your personal information

We will keep your personal data only for as long as it is required for your insurance contract, to handle claims and to comply with our legal and regulatory obligations as documented in our Records Management Policy. For the majority of policy data, this is seven years after the end of that transaction. If you do not accept a quote or complete an application for an insurance policy, your data will be kept for fifteen months and processed in line with this Statement. When a potential claim or actual claim is taken out on a policy, we hold details around this claim until a full and final settlement has been agreed. In most cases this should be seven years after the final settlement date or where a child was involved the later date of seven years after the child has turned eighteen or the settlement date. In certain cases, we are obliged to hold onto records for longer periods and we do so in line with our legal responsibilities. For more information on our data retention policies please refer to the “Contacting Us” section below.

Your rights in relation to your personal information

You have the right to request a copy of your personal data, and to have incorrect personal data about you corrected. You also have the right to object, to withdraw your consent for the processing of your personal data, have your personal data erased, or the processing restricted. Some of the above rights are subject to limitations in order for us to comply with a number of legal and regulatory obligations. You have the right to data portability for insurance purposes (contact dataprotectionofficer@allianz.ie). You also have the right to lodge a complaint with the Data Protection Commissioner. For further information, please see the section “Contacting Us” below.

Automated decision making

As part of the provision of your insurance contract, including at quotation stage, Allianz may use automated decision-making. This means that we may use an automated underwriting model which uses your personal data to evaluate, analyse or predict the performance of your contract of insurance. Premiums are calculated according to the risk of loss, with the risk ascertained on the basis of profiling by way of a pricing tool and system. This avoids unfair discrimination. Certain motor policies also use Telematics (Allianz Safe Driver App) where driving behaviour is used to measure driving performance and to determine the nature and level of the risk associated with your insurance policy. In these cases, suitable safeguards are in place and you have the right to human intervention to express your interests and contest automated decisions. If you are making a claim, we may use profiling and other forms of automated processing to assess if your claim may be fraudulent and we may use your sensitive information, to carry out this assessment. For example, we may use your unspent motoring convictions for motoring insurance. We use automated decision making as it is necessary for entering into, or performance of your insurance policy between you as the data subject and Allianz as data controller, and other uses such as those authorised by law.

In the event that profiling determines you have a high risk profile, we may not be able to offer you an insurance policy. If you wish to review an automated decision with Allianz, please contact us on dataprotectionofficer@allianz.ie.

Up to date information

In order for us to keep your information accurate and up to date, please contact Allianz or your insurance intermediary (where applicable) if any of your details change. For contact details, please see “Contacting Us” below.

Direct Marketing

If your chosen preference is to receive marketing, we may contact you by email, SMS, phone or post to send you Allianz plc branded/co-branded information on special offers, partnerships, competitions, vouchers and products.

Cross Sell: Our agents may reach out to you via email, SMS, phone or post for cross selling purposes if you have provided consent for the same via phone or through our website.

Follow up on a quote: Our agents may reach out to you to follow up on a quote you have requested via email, SMS, phone, post or through our website if you have provided consent for the same.

Consent Preference Update: To opt-out of receiving communication related to direct marketing activities please contact us via phone, email or post.

If you no longer wish your information to be used for marketing purposes, cross sell or to follow up on a quote please write to us at

Allianz Plc, Allianz House, Elmpark, Merrion Road, Dublin 4, D04 Y6Y6 or

e-mail us at info@allianz.ie.

Call us at +353 01-4484848

Contacting Us

If you have any questions about how we use personal information, or if you want to exercise your rights stated above, please contact our Data Protection Officer by either emailing, DataProtectionOfficer@allianz.ie or please write to The Data Protection Officer, Allianz plc, Allianz House, Elmpark, Merrion Road, Dublin 4, D04 Y6Y6, Ireland.

Complaints

If you have a complaint or concern about how we use your personal information, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have the right to lodge a complaint with the Office of the Data Protection Commissioner at any time. The details of the Data Protection Commission are as follows:

Data Protection Commission

21 Fitzwilliam Square S,

Dublin 2

D02 RD28

Telephone: +353 (0)761 104 800 or +353 (0)57 868 4800

Email: info@dataprotection.ie

Fax: +353 57 868 4757

This statement was last updated in October 2021

We may amend this Statement from time to time, in whole or in part, at our discretion. The latest version of this document will always be available at www.allianz.ie and will take effect on the date that it is updated. Please review this Data Protection Statement periodically to ensure you remain informed.

Intermediated Allianz Customers - Data Protection Statement-Allianz p.l.c

This privacy statement/notice tells you how we use your information and confirms that your Data Controller is Allianz p.l.c. (“we”, “us”, “our”), Allianz House, Elm Park, Merrion Road, Dublin 4, D04 Y6Y6, Ireland. Email: click here. Our Data Protection Officer is contactable at: DataProtectionOfficer@allianz.ie or please write to The Data Protection Officer, Allianz p.l.c., Allianz House, Elm Park, Merrion Road, Dublin 4, D04 Y6Y6, Ireland.

1. What Personal Information We Collect

Type of Information

The type of information we collect and use will differ depending on the type of product or service you have with us but includes (please note that this is not an exhaustive list):

Name, address (including Eircode), date of birth, policy numbers, contact details (mobile number and email address for customer identification purposes), PPS number (or any other relevant tax identification numbers) (if required by legislation), occupation, employment details, gender, insurance requirements including details about your home or vehicle, years of residency in Ireland or the UK, driving licence details, marketing preferences and renewal dates of policies with other insurers, claims history, bank and payment card details, records of payments and arrears, VAT and other relevant tax numbers, CCTV footage, membership status of any relevant bodies, penalty point information and Road Traffic offences, telematics data, dashboard camera video footage, credit score and on-board vehicle diagnostics information. Further details of information we collect can be found under specific headings in this Data Protection Statement.

Other People’s data:

Sensitive information

Given the fact that data relating to health and criminal convictions is particularly sensitive information, we only collect and use such data as follows:

Basis: Irish Data Protection law permits us to use health data where we need to and where it is proportionate for the purposes of a policy of insurance.

Purpose: Unspent criminal conviction data is collected and used for the purposes of obtaining/providing quotes and providing insurance services; to assist in the administration of a policy, including fraud prevention and investigation, handling a complaint or processing a claim.

2. How we collect your personal information

We may collect personal information about you from: you; your named driver (if you are purchasing or renewing a motor policy); joint policyholder; our intermediaries, your broker (or other representative), insured persons (where different from the applicant/policy owner); when you visit one of the Allianz Group websites (where you are purchasing or renewing a policy) or through cookies and other similar technologies when you visit our website or download and use one of our apps; when you visit a website aggregator; insurance industry databases and other commercial databases; third parties involved in a claim (including a claimant, private investigators engaged by us, witnesses, solicitors, health practitioners, medical representatives and independent experts); from public authorities; communicating with us via social media platforms; requesting any information from us; other people who live with you in an insured property (if you are purchasing or renewing a home insurance policy); your agents, attorneys (under powers of attorney), nominated representatives (including health practitioners and medical representatives) and other third parties relevant to you and/or the policy, including your legal advisers; publicly available information including social media websites and online content, newspaper articles, TV, radio and other media content, court judgements; telephone calls, which we may record, analyse or monitor for insurance, regulatory, training and quality purposes; other records within Allianz if you have or have had other insurance policies with or sought a quote from us or another Allianz company or third party claims; Insurance Ireland (insurance industry’s representative body) who operate a confidential phone line (Insurance Confidential) for individuals to report suspect fraud; and Credit referencing agencies.

3. How we use your personal information

Legal Basis: For the performance of a contract under which we provide insurance.

Purpose: To verify your identity.

Purpose: To carry out financial sanctions checks and prevention of financial crime.

Purpose: To comply with laws and regulations.

Purpose: For marketing purposes, market research, customer satisfaction surveys, and data analytics including profiling, to develop and enhance our service and products, the customer relationship and journey as part of our business strategy; for management information purposes including portfolio assessment, risk assessment, performance reporting and management reporting; for a proposed portfolio transfer, reorganisation, transfer, disposal or other transaction relating to our business; managing our business effectively (e.g. with third party service suppliers); for audit purposes and managing our legal affairs including exercising our legal rights and defending claims; to maintain arrangements we have with reinsurers; for quality purposes; to manage our IT security and network; to carry out statistical analysis and reporting to help improve services and products; staff training in how to perform their duties and provide a better service to you; monitor recorded customer calls to assess our staff’s customer service; provide online services; and to enhance our applications and product offerings.

Legal Basis: Legitimate interest in managing our business; to better understand our customers; improve product and/or service enhancement; and monitor and assess business performance.

Purpose: To detect and prevent fraud.

Legal Basis: For our legitimate interest in managing our business; in order to take steps at your request prior to entering into a contract of insurance; for the performance of a contract under which we provide insurance; and to comply with our legal obligations.

If you are purchasing a policy, we also use certain information and consult certain databases as follows:

Information Used: logging of any new claims notifications and any claim settlement for damage and injury.

Processing is necessary: For our legitimate interest in managing our business.

Information Used: address details.

Purpose: to verify address and surrounding location information using the Ecad Database.

Processing is necessary: in order to take steps at your request prior to entering into the policy or for the performance of your policy.

Information Used: vehicle registration number.

Purpose: to identify whether a vehicle has been taxed, NCT or if the vehicle has been involved in a claim or written off using the VRN system.

Processing is necessary: in order to takes steps at your request prior to entering into the policy or for the performance of your policy.

Information Used: Driving Licence Number.

Processing is necessary: in order to takes steps at your request prior to entering into the policy or for the performance of your policy.

Information Used: registration number of your vehicle.

Processing is necessary: to comply with legal obligations.

Information Used: registration number of your vehicle.

Processing is necessary: in order to take steps at your request prior to entering into the policy or for the performance of your policy; and. to comply with legal obligations.

Information Used: vehicle registration number and No Claims Discount (NCD) PIN.

Where you provide us with an NCD PIN number, we will verify your No Claims Discount information using the IIDS Hub, where such information is made available by your previous insurer.

Processing is necessary: in order to take steps at your request prior to entering into the policy or for the performance of your policy.

4. How we share your personal information with others

We may share your personal information with: the Allianz Group, our agents, third parties who provide services to us (engineers, repairers, motor assessors, loss adjustors, expert appraisers, expert witnesses etc.), your intermediary and other insurers (either directly or via those acting for the insurer such as loss adjusters or investigators); providers of essential services (e.g. telecommunications, postal/courier providers, IT service providers, software providers, card payment processor in their role as independent data controllers https://www.aibms.com/privacy/); other third parties involved in administering your contract; regulatory bodies and law enforcement bodies, including the Garda (for example, where we are required to do so to comply with a relevant legal or regulatory obligations); reinsurers who provide reinsurance to Allianz (reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations; they will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies); witnesses to any accidents/incidents to which you are involved; any party you have given us permission to speak to (e.g. your representative, a relative or a friend); any party named under your insurance policy; industry and trade bodies; and claimants and their legal or medical representatives.

Protecting Information Outside the European Economic Area

Your personal data may be transferred to and/or accessed from a country outside the European Economic Area (“EEA”). We will always take steps to ensure that any transfer of information outside the EEA is carefully managed to protect your privacy rights. Such transfer/access within the Allianz Group will be covered on the basis of the Allianz Group binding corporate rules (BCRs) known as the Allianz Privacy Standard (APS) which contractually obliges each member to ensure that your personal information receives an adequate and consistent level of protection wherever it is transferred within the Group. Where we transfer your data to a non-Allianz Group member or other companies providing us with a service, we will obtain contractual commitments and assurances from them to protect your personal information. These assurances are well recognised certification schemes like Standard Contractual Clauses. We will only transfer your personal information to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. Any requests for information we receive from law enforcement or regulators will be carefully validated before personal information is disclosed.

Representation

Online Information

How long we keep your personal information

Your rights in relation to your personal information

You have the right to request a copy of your personal data, and to have incorrect personal data about you corrected. You also have the right to object, to withdraw your consent for the processing of your personal data, have your personal data erased, or the processing restricted. Please note that withdrawing consent and requests for restriction/erasure may affect our ability to provide you with a contract of insurance. Some of the above rights are subject to limitations in order for us to comply with a number of legal and regulatory obligations. You have the right to data portability for insurance purposes (contact dataprotectionofficer@allianz.ie). You also have the right to lodge a complaint with the Data Protection Commissioner. For further information, please see the section “Contacting Us” below.

Automated decision making

Up to date information

Contacting Us

If you have any questions about how we use personal information, or if you want to exercise your rights stated above, please contact our Data Protection Officer by either emailing, DataProtectionOfficer@allianz.ie or please write to The Data Protection Officer, Allianz p.l.c., Allianz House, Elm Park, Merrion Road, Dublin 4, D04 Y6Y6, Ireland.

Complaints

Data Protection Commission

21 Fitzwilliam Square S,

Dublin 2

D02 RD28

Telephone: +353 (0)761 104 800 or +353 (0)57 868 4800

Email: info@dataprotection.ie

Fax: +353 57 868 4757

This statement was last updated in October 2021.

Please review this Data Protection Statement periodically to ensure you remain informed.

Data Protection Statement for Claims Handling ROI & NI – Allianz p.l.c. Fair Processing Notice

This privacy statement/notice tells you how we use your information for handling a claim - notwithstanding the Data Protection Statement provided at policy inception if you are an Allianz customer - and confirms that your Data Controller is Allianz plc (“we”, “us”, “our”), Allianz House, Elmpark, Merrion Road, Dublin 4, D04 Y6Y6, Ireland. Email: click here. Our branch trading address is Allianz plc, 3 Cromac Quay, The Gasworks, Ormeau Road, Belfast, BT7 2JD, Email: click here. Our Data Protection Officer is contactable at: dummy DataProtectionOfficer@allianz.ie or please write to The Data Protection Officer, Allianz plc, Allianz House, Elm Park, Merrion Road, Dublin 4, D04 Y6Y6, Ireland.

This privacy statement/notice is intended to provide information to data subjects in situations where, in the context of a claim, Allianz is processing your personal data and the relevant data has been obtained directly from you or from another party, and therefore not directly from you.

1. What Personal Information We Collect for handling a claim

Type of Information

The type of information we collect might include (please note that this is not an exhaustive list):

Name, address (including Eircode), date of birth, photo ID, policy numbers, contact details (mobile number and email address digital communication purposes in connection with your claim), PPS number, national insurance number (or any other relevant tax identification numbers) (if required by legislation), occupation, years of residency in the UK, employment details, gender, claims history, bank and payment card details, VAT and other relevant tax numbers, CCTV footage, membership status of any relevant bodies, penalty point information and Road Traffic offences, telematics data, dashboard camera video footage, dashboard credit score and on-board vehicle diagnostics information. Further details of information we collect, can be found under specific headings in this Data Protection Statement.

Other People’s data:

As well as collecting your personal data, we may also use personal information about other people in connection with claims handling, for example family members such as minors, witnesses, limited personal information about trustees/beneficiaries (where policies are under trust), executors, nominated representatives and attorneys (under power of attorney), individuals who have an active membership relationship with the policyholder.

If you are providing personal information about another person in paper or electronic format or video we require you to let them know what information you've shared with us, share this data protection notice with them and ensure that they have given you permission to provide this information to us. If you or they have any concerns, please ask them to contact us in one of the ways described in this notice. Special categories of data of other’s people will be processed solely if they are necessary for the provisions of a policy of insurance and for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

Sensitive information

We may collect health information or details of past or pending offences, unspent criminal convictions or other sensitive information about the claimant and/or their family members or any other persons associated with the claim. We recognise the sensitivity of collecting this information, so we will only ask for it to arrange, manage or administer a claim, or prevent fraud. Where we process health data, for the purpose of handling a claim we will take suitable and specific measures to safeguard the fundamental rights and freedoms of individuals.

Given the fact that data relating to health and criminal convictions is particularly sensitive information, we only collect and use such data as follows:

Purpose: Health data and Criminal Conviction is used solely for the purpose of handling a claim.

Basis: Irish Data Protection law permits us to use health data where we need to and where it is proportionate for the purposes of a policy of insurance and permits the use of Criminal Conviction data to prevent fraud.

You do not have to provide us with any personal information, however, should you be unable to provide us with the required personal data, we will be unable to process your claim.

2. How we collect your personal information

We may collect personal information about you :

Directly from You; From our clients: our policyholder (e.g. employer/sport club); our named driver; our joint policyholder; your intermediaries; our broker (or other representative); our insured persons (where different from the applicant/policy owner); member of the public (e.g. dash cam footage); insurance industry databases and other commercial databases; third parties involved in a claim (including a claimant, solicitors, witnesses, health practitioners, medical representatives and independent experts, providers engaged by us including engineers, repairers, motor assessors, loss adjusters, expert appraisers, private investigators etc.); public authorities: the Department of Employment Affairs and Social Protection; the Personal Injuries Assessment Board; Public Authorities involved in the claim (e.g. Gardai, PSNI); communicating with us via social media platforms; people connected with you: people who live with you in an insured property; nominated representatives and other third parties relevant to you and/or to the claim, including your legal advisers; publicly available information: social media websites and online content, newspaper articles, TV, radio and other media content, court judgements; telephone calls, which we may record or monitor for regulatory, training and quality assurance purposes; any party you have given us permission to speak to: your representative, a relative or a friend, including health practitioners and medical representatives;other records within Allianz if you have or have had other claims with us; insurance industry’s representative body: ROI- Insurance Ireland who operate a confidential phone line (Insurance Confidential) for individuals to report suspect fraud; and Credit referencing agencies;NI- the Insurance Fraud Bureau who operate a confidential phone line (cheat line for individuals who report suspect fraud); and credit referencing agencies (including but not limited to County Court Judgments and details from the electoral register).

3. How we use your personal information

Purpose: to investigate, validate, arrange, handle, manage or administer a claim that you are making in relation to an insurance policy held by us.

Legal Basis: Contractual and legal obligation connected to a contract of insurance.

Purpose: To verify your identity.

Legal Basis: For the performance of a contract under which we provide insurance.

Purpose: To carry out financial sanctions checks and prevention of financial crime.

Legal Basis: To comply with legal obligations; and public interest.

Purpose: To comply with laws and regulations.

Legal Basis: To comply with legal obligations. For motor policies only, in compliance with the Road Traffic Act 1961 (as amended) we share details of your policy with the Motor Insurers Bureau of Ireland (The details on MIBI processing activity can be found on https://www.mibi.ie MTPL section) and UK Motor Insurance Bureau, the Minister for Transport, Tourism and Sport and An Garda Síochána/PSNI for the purposes of section 78A as autonomous data controllers and in in respect of new and renewed employer’s liability insurance policies.

Purpose: To detect and prevent fraud.

Legal Basis: For the performance of a contract under which we provide insurance; and to comply with our legal obligations.

Purpose: To provide repository policy information in respect of new and renewed employer’s liability insurance policies to assist claimants to effectively and efficiently trace the relevant insurer to the Employers’ Liability Tracing Officer.

Legal Basis: To comply with legal obligations.

Purpose: For satisfaction surveys; to carry out statistical analysis and reporting to help us improving our products and services; for quality assurance purposes; for staff training in how to perform their duties and provide a better service; to monitor recorded customer calls to assess our staff’s customer service; and to enhance our services offerings.

Legal Basis: Legitimate interest in managing our business; improve service enhancement; and monitor and assess business performance.

We also use certain information and consult certain databases as follows:

Information Used: logging of any new claim notifications and any claim settlement for damage and injury.

Processing is necessary: for our legitimate interest in managing our business.

Information Used: vehicle registration number.

Purpose: to identify whether a vehicle has been taxed, NCT or if the vehicle has been involved in a claim or written off using the VRN system. The Motor Insurance Database managed by the Motor Insurers’ Bureau ("MIB"), MID data is used by the DVA for the purpose of Electronic Vehicle Licensing and by the Police Service for Northern Ireland (PSNI) for the purposes of establishing whether a driver's use of the vehicle is likely to be covered by a motor insurance policy and/or for preventing and detecting crime. If you are involved in an accident (in the UK or abroad), other UK insurers and the MIB may search the MID to obtain relevant policy information. Persons pursuing a claim in respect of a road traffic accident (including citizens of other countries) may also obtain relevant information which is held on the MID.

Processing is necessary: for the handling of a claim.

Information Used: Driving Licence Number.

Processing is necessary: for the handling of a claim.

Information Used: Personal Public Service (PPS) Number

Purpose: If you make a claim for personal injuries against an Allianz customer, we are obliged to provide the Department of Employment Affairs and Social Protection with your PPS Number to comply with the Recovery of Benefits and Assistance (RBA) Scheme.

Processing is necessary: to comply with legal obligations.

4. How we share your personal information with others

We may share your personal information with:
third parties: the Allianz Group, our agents, third parties who provide services to us (engineers, repairers, motor assessors, loss adjustors, expert appraisers, expert witnesses, private investigators, claims handling agents etc.), your intermediary and other insurers (either directly or via those acting for the insurer such as loss adjusters or investigators or solicitors); providers of essential services (e.g. telecommunications, postal/courier providers, IT service providers, software providers, payment processor); other third parties involved in administering your claim;
third parties involved in a claim:claimant, solicitors, witnesses, health practitioners, medical representatives and independent experts, providers engaged by us including engineers, repairers, motor assessors, loss adjusters, expert appraisers, private investigators etc.);
regulatory bodies and law enforcement bodies: the Garda and PSNI (for example, where we are required to do so to comply with a relevant legal or regulatory obligations); the Department of Employment Affairs and Social Protection; reinsurers who provide reinsurance to Allianz (reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations; they will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies);
witnesses to any accidents/incidents to which you are involved;
other parties: any party you have given us permission to speak to (e.g. your representative, a relative or a friend, including health practitioners and medical representatives); any party named under your insurance policy; industry and trade bodies; other insurance companies to deal with the claim and to safeguard against non-disclosure and help prevent fraudulent claims ,and other claimants and their legal or medical representatives. If you are making a claim against an Allianz policyholder, we will share your information with our policyholder (e.g. employer/sport club) and or their agent including the financial outcome of your claim; statutory and other authorised bodies for anti-fraud purposes:; ROI- the Insurance Link Anti-Fraud register (for more info see www.inslink.ie) to prevent and detect fraud; No Claim Discount (NCD) to combat fraud; the Motor Insurers’ Bureau of Ireland (MIBI) to assist in preventing or detecting theft and fraud and to pay claims; private investigators, tracing debtors or beneficiaries, recovering debt, managing your accounts and/or insurance policies; vehicle history check suppliers/ databases to protect our customers, inform our acceptance criteria and assist in claims investigations; and other fraud prevention, ID verification databases available in the insurance industry and publicly available information to detect or prevent possible criminal activity or fraud. NI- ; the Motor Insurance Anti Fraud and Theft Register (MIAFTR) and the Insurance Fraud Bureau, Claims and Underwriting Exchange Register (CUE) which are run by the MIB, to prevent and detect fraud; the Motor Insurers’ Bureau (MIB) to assist in preventing or detecting theft and fraud and to pay claims; private investigators, tracing debtors or beneficiaries, recovering debt, managing your accounts and/or insurance policies; vehicle history check suppliers/ databases to protect our customers, inform our acceptance criteria and assist in claims investigations; and other fraud prevention, ID verification databases available in the insurance industry and publicly available information to detect or prevent possible criminal activity or fraud. If you have a motor policy, your personal details will be added to the Motor Insurance Database (MID) managed by the MIB, MID data may be used by the DVA for the purpose of Electronic Vehicle Licensing and by the PSNI for the purpose of establishing whether a driver’s use of the vehicle is likely to be covered by a motor insurance policy and/or for preventing and detecting crime. If you are involved in an accident (in the UK or abroad), other UK insurers and the MIB may search the MID to obtain relevant policy information. Persons pursuing a claim in respect of a road traffic accident (including citizens of other countries) may also obtain relevant information which is held on MID. You can find out more on www.mib.org.uk.

We will use your personal information to detect and prevent fraudulent practices and fight financial crime to meet our regulatory responsibilities.

Where we obtain data from the above sources, the categories we obtain will be claims information relating to claims handling and fraud prevention. We may need your consent for the processing of certain data and in these cases, we will inform you of such processing and the reason for this at the time consent is captured.

Protecting Information Outside the European Economic Area

Your personal data may be transferred to and/or accessed from a country outside the European Economic Area (“EEA”). We will always take steps to ensure that any transfer of information outside the EEA is carefully managed to protect your privacy rights. Such transfer/access within the Allianz Group will be covered on the basis of the Allianz Group binding corporate rules (BCRs) known as the Allianz Privacy Standard (APS) which contractually obliges each member to ensure that your personal information receives an adequate and consistent level of protection wherever it is transferred within the Group. Where we transfer your data to a non-Allianz Group member or other companies providing us with a service, we will obtain contractual commitments and assurances from them to protect your personal information. Theses assurances are well recognised certification schemes like Standard Contractual Clauses. We will only transfer your personal information to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. Any requests for information we receive from law enforcement or regulators will be carefully validated before personal information is disclosed.

Representation

How long we keep your personal information

Your rights in relation to your personal information

You have the right to request a copy of your personal data, and to have incorrect personal data about you corrected. You also have the right to object, the right to withdraw your consent for the processing of your personal data, have your personal data erased, or the processing restricted. Please note that withdrawing consent and requests for restriction/erasure may affect our ability to provide you with a contract of insurance. Some of the above rights are subject to limitations in order for us to comply with a number of legal and regulatory obligations. You have the right to data portability for insurance purposes (contact dummy dataprotectionofficer@allianz.ie). You also have the right to lodge a complaint with the Data Protection Commissioner. For further information, please see the section “Contacting Us” below.

Automated decision making

As part of the claim handling, Allianz may use automated decision-making. If you are making a claim, we may use profiling and other forms of automated processing to assess if your claim may be fraudulent and we may use your sensitive information, to carry out this assessment. For example, we may use your unspent motoring convictions for motoring insurance. We use automated decision making as it is necessary for entering into, or performance of your insurance policy between you as the data subject and Allianz as data controller, and other uses such as those authorised by law.

Up to date information

Contacting Us

If you have any questions about how we use personal information, or if you want to exercise your rights stated above, please contact our Data Protection Officer by either emailing, dummy DataProtectionOfficer@allianz.ie or please write to The Data Protection Officer, Allianz plc, Allianz House, Elm Park, Merrion Road, Dublin 4, D04 Y6Y6, Ireland.

Data Protection Commission

21 Fitzwilliam Square S,

Dublin 2

D02 RD28

Telephone: +353 (0)761 104 800 or +353 (0)57 868 4800

Locall Number: 1890 252 231

Email: dummy info@dataprotection.ie

Fax: +353 57 868 4757

Please review this Data Protection Statement periodically to ensure you remain informed.

Recruitment Privacy Notice - Allianz p.l.c.

Recruitment Privacy Notice

Last update: February 2023

This data protection notice provides information about the ways in which Allianz PLC (hereinafter referred to as “Allianz”) collects and uses personal data.

Allianz will process all personal data in compliance with the General Data Protection Regulation (GDPR) and any applicable local privacy or other law. This is to provide you with a service you have requested and to meet our statutory obligations.

For the purposes of data protection legislation, the Data Controller of your personal data is:

Allianz PLC

Allianz House, Elm Park,

Merrion Rd, Dublin 4, D04 Y6Y6

E-mail: careers@allianz.ie

Telephone: 00-353-1-6133000

This notice applies to all personal data collected by Allianz in connection with the recruitment and talent acquisition process as outlined below. Allianz can receive the personal information directly from individuals or indirectly from another party such as recruitment agency or another 3rd Party who is engaged to support Allianz in the process.

Personal Data Processed

Allianz collects personal data from candidates for recruitment purposes. The information that Allianz may collect and hold about candidates includes:

Name, address, telephone number(s) and email address
Details of qualification (where required for a role), skills, experience and employment history
Details of eligibility to work in Republic of Ireland and or Northern Ireland Any additional information contained in a candidate’s CV such as referee information, disclosed at interview or otherwise provided to Allianz during the recruitment process.
Details, where required if an individual has a particular need in relation an interview.

Allianz needs to process data to decide whether a candidate is suitable for a given role and therefore to consider an offer of employment. We may also process personal data on a candidate to ensure that we are complying with our legal obligations. Allianz has a legitimate interest in processing personal data during the recruitment process and in keeping records of the process in order to manage the recruitment process, to assess and confirm a candidate's suitability for employment and decide to whom to offer a particular role. Allianz may also need to process candidates’ data to respond to and defend against any legal claims, should they arise.

For certain Executive Management or other designated roles the candidate’s information may be provided to a 3rd party service provider for the purpose of assessing the suitability for the role. In relation to roles that are subject to the Central Bank of Ireland Fitness and Probity obligations personal data may be shared with a 3rd party to enable Allianz to conduct the relevant due diligence searches required. We may undertake checks about you against publicly available information such as electoral roll, court judgements, bankruptcy, research engines or regulator for ethical/behavioural issues or repossessions to comply with our regulatory obligations towards the Central Bank of Ireland. Under the Fitness and Probity Regime, we may collect and process your self-declaration in respect of possible criminal convictions. Once a contract of employment is issued and been accepted by a candidate, Allianz may also contact previous employers named by that candidate as referees for the purpose of obtaining employment references. Contact may be made by Allianz with a previous employer in advance of the contract being accepted with the consent of the individual. The candidate will also be required to provide medical information to Allianz’s occupational health provider for the purposes of assessing his or her capacity to work. Details may also be provided to Allianz so that we can satisfy our obligations under H&S legislation.

If a candidate’s application is unsuccessful, Allianz may keep his or her personal data on file for a period of 12 months.

Lawful Basis for processing

Performance of a contract with you: the processing is necessary for a contract we have with you, or because we have asked you to take specific steps before entering into a contract. For example, we process your data in order to assess your knowledge and experience in order to give you an opportunity to work with us.

Legal Obligation: In circumstances where it’s our legal obligation to disclose or share your data in order to comply, pursuant to a legal request, subpoena or other legal processes, or in order to enforce or apply the company’s Terms of Use and other agreements, including for billing and collection purposes; or to protect the rights, property, or our safety, or others.

Legitimate interest: The processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests. For example, for our legitimate interest of maintaining a file with your personal data for administration purposes.

Before we process your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law), we make sure we consider and balance any potential impact on you and your rights before we process your personal data.

How long we keep your information

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, primarily for the purposes of satisfying any legal, accounting, or reporting requirements.

We retain candidates’ personal data for 12 months. Personal data of candidates who become employees is held in accordance with the Employees’ Record Retention Policy.

Cross-Border Data Transfers

The Personal Data and other information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), for example where we are asked to share it with Allianz Group Colleagues.

To comply with applicable data protection law, we have implemented international data transfer agreements on the basis of EU Standard Contractual Clauses in order to provide appropriate and suitable safeguards for Personal Data transferred to countries outside the EEA where an adequate level of protection is not already guaranteed.

Disclosure of Personal Data

In order to properly and efficiently perform the recruitment process and to comply with legal obligations, Allianz may disclose personal data to:

Third parties, where required or permitted to do so by law or a requisite Court Order to do so which may include our service providers and statutory bodies, including Workplace Relations Commission, Equality Commission in NI, An Garda Síochána / PSNI, the Revenue Commissioners, HMRC and Professional Bodes such as the Insurance Institute of Ireland.
Legal advisors, Auditors, Other agencies (where applicable)
Relevant public authority (where applicable)Supervisory authorities in other EEA Member States for the purpose of performance of their functions.
Supervisory authorities in countries outside of the EEA where permissible under data protection legislation (i.e. generally, where the European Commission has made an adequacy decision in relation to the country in question or where other appropriate safeguards are in place).

Allianz requires all third parties to respect the security and confidentiality of personal data disclosed to them. Third-party service providers may only process such personal data for specified purposes and in accordance with Allianz’s instructions.

Your Rights

If your personal data is processed by Allianz, you have certain rights in relation to that data, which are outlined in summary form below. Allianz may require further information from you before we can respond to your request. The scope of certain rights may be subject to restrictions or exceptions provided for under data protection legislation.

All requests to exercise your rights will be duly considered by our representatives. Should you believe that any personal data we hold on you is incorrect or incomplete, you have the ability to request to see this information, rectify it or have it deleted. Please contact us through our DPO Office via email at DataProtectionOfficer@allianz.ie so we provide you with the necessary information.

You have the following rights:

Right of Access

You have the right to receive a copy of the personal data Allianz holds about you as well as information about how it is used.

Right to Rectification

You have the right to ask Allianz to correct personal data we hold about you where it is incorrect or incomplete.

Right to Erasure

This right entitles you to require the erasure of your personal data from Allianz’s systems and records. However, this right applies only in certain circumstances (e.g. where we no longer need the personal data for the purpose for which we collected it or where you withdraw consent to our use of your personal data and where there is no other legal basis for continuing to use it).

Right to Restrict Processing

This right entitles you to restrict the processing of your personal data by Allianz. Where this right is exercised, Allianz is still permitted to store your personal data but other use of the data is prohibited, save in certain limited circumstances.

Right to Data Portability

This right allows you to obtain your personal data in a format that enables you to transfer that personal data to another organisation where Allianz is processing your personal data on the basis of consent or on the fulfilment of a contract and if processing is carried out by automated means. You may have the right to have your personal data transferred by us directly to the other organisation, if this is technically feasible.

Right to Object

You have the right to object to the Allianz’s use of your personal data in certain circumstances. However, Allianz may continue to use your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to use your personal data in connection with any legal claims.

Right Relating to Automated Decision Making and Profiling

You have the right not to be subject to a decision based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. We are not currently making any automated decisions.

Right to Withdraw Consent

You have the right to withdraw your consent to the processing of your personal data by Allianz at any time. This will not affect the lawfulness of our processing before the withdrawal. We are not currently using consent as legal basis for processing candidates’ personal data.

Right to Complain to Data Protection Commission

You have the right to lodge a complaint with the Data Protection Commission (DPC) via their website www.dataprotection.ie if you think that we have not processed your personal data in accordance with data protection legislation.

Failure to provide personal information

If you fail to provide certain information when requested, we will not be able to fulfil our legal obligations or enter in a pre-contractual relationship with you.

Modifications of this policy

We may revise this policy occasionally by publishing a new version on our website. You may choose to check this page on a regular basis to note any changes to this notice.

Data Protection Officer

Our Data Protection Officer's contact details:

DataProtectionOfficer@allianz.ie

Allianz p.l.c. Fair Processing Notice for Whistleblowing reporting tool

Protecting your privacy is a top priority for us. Please read this notice carefully.

This Allianz Privacy Notice outlines Allianz plc’s (“Allianz”, “we”, “our” or “us”) policy regarding personal information (i.e., data which can be linked/attributed to an individual person, “Personal Data”) obtained by Allianz through the SpeakUp reporting tool and subsequent compliance investigations.

With our whistleblowing reporting channel, “SpeakUp”, we provide a means for reporting specific incidents of compliance violations e.g. (non-exhaustive list): fraud, theft, corruption, violations of gifts & entertainment policies and procedures, antitrust violations, financial irregularities or breaches of accounting or tax provisions, falsification and/ or manipulation of company business and/ or financial records, any kinds of discrimination or harassment, potential conflict of interest.

This Privacy Notice sets out which kind of Personal Data will be collected, processed, and used, for which purposes, to whom this Personal Data may be shared and which rights you, as the data subject, have in this regard.

1. Who is the data controller?

A data controller is the individual or legal person who controls and is responsible to keep and use personal data in paper or electronic files.

Allianz plc, located in Allianz House, Elmpark, Merrion Road, Dublin 4, Ireland, is the data controller as defined by relevant data protection laws and regulations. In the event that an alleged violation involves also other Allianz Group companies, the other Allianz Group companies will also be data controllers to the extent it is necessary to address the alleged violation. A list of the Allianz Group companies can be found here:

https://www.allianz.com/en/privacy-statement.html#TabVerticalNegative2523488475.

The SpeakUp system is stored in a database operated by Business Keeper GmbH, an independent operator located in 10789 Berlin, Bayreuther Str. 35, on behalf of Allianz SE, which is the German-based holding of the Allianz Group with an address at Koeniginstrasse 28, 80802 Munich, Germany. All data is encrypted, password-protected and stored at a secure location, so that access to the content of the reports on SpeakUp is limited to only authorised employees at Allianz and Allianz SE.

2. What Personal Data will be collected?

We will collect and process various types of Personal Data about you to fulfil the purposes of this notice, including:

Surname and first name
Contact information (e.g., email address, phone number)
Business relationships
Affiliation with Allianz
Information about any complaints(s) made by or about you
Information about any current or former investigations in which you may be involved or concerned
Information to enable the investigation of improper or allegedly criminal activities, or breach of the Allianz Code of Conduct

Allianz encourages you to disclose your identity when you submit a suspected compliance violation. Many investigations can be conducted more quickly and efficiently if the name of the whistleblower is known, since the specialist handling the report can get in touch with the whistleblower directly. However, SpeakUp protects the anonymity of reporters who do not want to reveal their identity. When setting up your secured postbox, you may select a pseudonym/user name and password. As long as you do not enter data which makes it possible to draw conclusions about your identity, your report will be kept anonymous through numerous technical and organisational measures such as encryption.

The information you report may contain Personal Data about other individuals and will be evaluated by Allianz. It may result in the initiation of internal or external investigations and may have other negative consequences for those affected. You should therefore only provide information which you assume to be correct to the best of your knowledge. You should also provide us with the information that is relevant to the alleged compliance violation because, even if we are highly committed to the minimisation principle, we cannot modify the data you provided for audit trail purposes As long as your report is made in good faith and to your best knowledge, you will not face negative consequences for speaking up.

However, giving knowingly false or misleading information may have consequences for you. The intentional dissemination of false information is liable to criminal prosecution in many countries. In general, please do not provide us with information that is subject to prosecution in your country.

3. For which purposes do we process and use your Personal Data?

We will process your Personal Data for the purpose of providing a global whistleblowing reporting channel to our employees, shareholders, customers and the general public, and to investigate and address improper conduct, including alleged criminal activities (e.g., fraud) and violations of the Allianz Code of Conduct.

Allianz takes appropriate steps to make careful use of the information reported, applying the highest standards of confidentiality, care and caution. The Compliance function is primarily responsible for processing reports received through SpeakUp. Once a report is submitted, our Compliance function will receive the information and check whether an in-depth investigation is required. An investigation may be conducted by internal or external investigation specialists depending on the alleged violation. External specialists are contractually or legally bound by confidentiality obligations to protect Personal Data processed on behalf of Allianz. Audit, Legal and HR functions are also frequently involved in the compliance investigation process. In significant cases, the Board of Management and our Risk Committee of the Board of Directors is informed promptly and is updated on important findings.

The general rule is that SpeakUp should only be used to submit reports related to the compliance categories listed above. However, if the content of your report does not fall under any of the compliance categories, we will forward your report to the responsible Allianz function, provided we deem it necessary and appropriate. For instance, reports on personal matters may be sent to the HR function.

4. On which legal bases do we collect, process and use your Personal Data?

We use the following legal bases for the collection, processing and use of your personal data:

Consent. We rely on your consent to disclose your identity in the event you are a whistleblower. As you enter information into the SpeakUp system, you will be asked for your consent to the collection, processing and use of your Personal Data as described above. You retain your right to withdraw your consent to disclose your identity to the affected persons, but please note that your withdrawal will only be possible within one month of the reporting. We may also need to disclose your identity to other third parties as described in Section 5. If you do not want Allianz to collect, process or use your Personal Data, you may submit a report anonymously.
Legal Obligation. We will process Personal Data to comply with legal obligations to which we are subject (e.g., for maintaining and providing whistleblowing services to our employees).
Legitimate Interest. We have a legitimate interest to ensure that violations of applicable laws or regulations and violations of the Allianz Code of Conduct are appropriately addressed in a timely manner to protect Allianz as well as our employees, shareholders, customers, and the general public from the results and effect of illegal or improper conduct.

5. Who will have access to your Personal Data?

We will ensure that your Personal Data is processed in a manner that is compatible with the purposes specified above.

For the specified purposes, your personal data may be disclosed to the following parties who operate as third party data controllers:

In the event that an alleged violation involves other Allianz Group companies, the responsible function in these companies will be notified;
Allianz SE in cases where the allegations may have an impact on Allianz Group ; and
Authorised external specialists (e.g., outside counsel, auditors, forensic experts, etc.).

For the stated purposes, we may also share your personal data with the following parties who operate as data processors under our instruction:

Authorised agents, contractors, and service providers.

Finally, we may share your Personal Data in the following instances:

Allianz may also be required by law to provide certain government agencies, including, without limitation, government investigation agencies or courts with information about reported compliance violations. If we are obligated to provide such information, as well as in the event of confiscations, we are not able to withhold the Personal Data obtained by Allianz via SpeakUp or the subsequent compliance investigation.
In certain instances, Allianz may not be obligated to share Personal Data with government agencies, but has the legal right to do so voluntarily. Please let us know if you do not want us to voluntarily share your Personal Data, including your identity, with government agencies (unless this disclosure is necessary to safeguard the legitimate interests of Allianz).
It is frequently required by law that accused persons and witnesses named in a report that alleges a compliance violation have to be notified and heard. These persons will have the opportunity to present their view about the report during the course of the investigation. In the case of non-anonymous reporting, the affected persons may have legal rights to information, which may require us to disclose your name absent an overriding interest. Please let us know if you do not want us to give your name as the whistleblower. You retain your right to withdraw your consent to disclose your identity to the affected persons, but note that your withdrawal will only be possible within one month of the reporting.

6. Where will your Personal Data be processed?

Your personal data may be processed both inside and outside of the European Economic Area (EEA) by the parties specified above, subject always to contractual restrictions regarding confidentiality and security in line with applicable data protection laws and regulations. We will not disclose your personal data to parties who are not authorised to process them.

Whenever we transfer your personal data for processing outside of the EEA to another Allianz Group company, we will do so on the basis of the binding corporate rules (BCRs) of Allianz which establish adequate protection for personal data and are legally binding on Allianz Group companies. The public version of the BCRs and the list of Allianz Group companies that comply with them can be accessed on Allianz.com.

Where the BCRs does not apply, we will instead take steps to ensure that the transfer of your personal data outside of the EEA receives an adequate level of protection as it does in the EEA. You can find out what safeguards we rely upon for such transfers (e.g., Standard Contractual Clauses) by contacting us as detailed below.

7. What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the right to:

Access your Personal Data held about you and to learn the origin of the data, the purposes and ends of the processing, the details of the data controller(s), the data processor(s) and the parties to whom the data may be disclosed;
Update and correct your Personal Data so that it is accurate;
Request the deletion of your Personal Data if it is no longer needed for the purposes indicated above;
Obtain your Personal Data in an electronic format;
Restrict the processing of your Personal Data in certain circumstances, for example; where you have contested the accuracy of your Personal Data, for the period enabling us to verify its accuracy;
Object to the processing of your Personal Data on specific grounds relating to your particular situation that override our compelling legitimate grounds for the processing;
Withdraw your consent at any time where your Personal Data is processed with your consent, without affecting the lawfulness of processing based on consent before its withdrawal and on processing done based on other legal basis (e.g., legitimate interest); and
File a complaint with us and/or the relevant data protection authority.

You may exercise these rights by contacting us as detailed in Section 9, below, providing your name, email address, and purpose of your request. Note these are not absolute rights, but we will comply fully with our legal obligations.

8. What security measures have we implemented to protect your Personal Data?

Allianz has implemented reasonable technical and organisational security measures (e.g., access controls, encryption, , etc.) to protect your Personal Data collected by Allianz via SpeakUp and any subsequent compliance investigations against unauthorised access, misuse, loss or destruction.

9. How long do we keep your Personal Data?

We will only retain your Personal Data for 10 years in order to comply with legal requirements connected to the compliance violation being reported. Your Personal Data will be stored for longer if further retention is required by legal, regulatory or contractual obligations, or if it is permitted by law.

10. How can you contact us?

If you have any queries about how Allianz Plc uses your Personal Data, we encourage you to submit a request via the Speak Up tool. Alternatively you can reach out to us by post or email via the details specified below:

Allianz Plc

Elmpark

Merrion Road

Dublin 4

dataprotectionofficer@allianz.ie

If your query is about how other Allianz Group companies use your Personal Data, you can use the contact details listed in this Section 10 and we will forward your request to the Data Protection Officer of the applicable Allianz Group company accordingly.

11. Complaints

Data Protection Commission

21 Fitzwilliam Square S,

Dublin 2

D02 RD28

Telephone: +353 (0)761 104 800 or +353 (0)57 868 4800

Email: info@dataprotection.ie

Fax: +353 57 868 4757

12. How often do we update this Privacy Notice?

We regularly review this Privacy Notice. We will inform you when there is an important change that may have an impact on the processing of your Personal Data.

This privacy notice was last updated in March 2023.

We may amend this Statement from time to time, in whole or in part, at our discretion. The latest version of this document will always
be available at www.allianz.ie and will take effect on the date that it is updated.

Please review this Data Protection Statement periodically to ensure you remain informed.

Date Last Updated: 29/05/2023

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