Open AI Marketplace FPN

Fair Processing Notice – Home Quotation App (OpenAI Marketplace)

1. Introduction This Fair Processing Notice explains how your personal data is collected and used when you interact with this application made available via the OpenAI marketplace (e.g. ChatGPT). We are committed to ensuring that your personal data is processed in a fair, lawful, and transparent manner, in line with applicable data protection laws including the General Data Protection Regulation (EU) 2016/679 (“GDPR”). 2. Who is the Data Controller? 2.1 During Use within OpenAI Environment While you are interacting with this application within the OpenAI marketplace (including entering information, uploading files, or engaging in conversation): OpenAI acts as the data controller for your personal data processed within its platform. This includes any content you provide such as:

text inputs (e.g. responses to questions),

uploaded documents (PDFs, images), and

any other user-generated content.

OpenAI processes this data in accordance with its privacy policy. [openai.com] 2.2 Data Collection by Allianz Plc Once you:

review the information collected,

verify its accuracy, and

explicitly confirm submission for the purpose of obtaining a home insurance quotation,

Your personal data will be transmitted to Allianz Plc, which will then act as the independent data controller. Any underwriting, acceptance, eligibility, or final pricing decisions will be made my Allianz Plc and not OpenAI following verification of the information provided. 3. Scope of Allianz Responsibility Before Submission Allianz Plc does not have access to or visibility of any raw conversational data, prompts, or uploaded content within the OpenAI platform. Data transfer is limited strictly to user-confirmed structured data fields necessary for the quotation process. Prior to your confirmation to submit data to Allianz Plc:

Allianz Plc does not have access to, or control over, your personal data;

Allianz Plc does not act as a controller or processor in respect of such data; and

Allianz Plc does not assume data protection obligations, including:

responding to data subject rights,

ensuring security of data within the OpenAI platform, or

determining retention periods.

Until you explicitly submit your information to Allianz Plc, Allianz Plc does not receive, access, retain, or otherwise process your personal data. As Allianz Plc has no visibility of your information within the OpenAI environment and cannot identify you from interactions taking place solely within that platform, Allianz Plc is unable to:

provide access to personal data held within the OpenAI environment.

correct or update information provided to OpenAI.

delete information stored by OpenAI.

fulfil requests relating to restriction of processing, objection, or data portability concerning data held by OpenAI.

identify whether you have interacted with the application; or

locate, retrieve, or otherwise act upon personal data that has not been submitted to Allianz Plc.

Any requests relating to personal data processed within the OpenAI platform before submission must be directed to OpenAI, as the data controller for that processing. 4. Data Submitted to Allianz Plc Upon submission, only structured data fields are transferred to Allianz plc to generate your home insurance quote, extracted from your interaction with the application. This includes:

identification details e.g. Full name, contact details, Date of Birth, Occupation

property and risk information relevant to home insurance

At this point Allianz Plc becomes your data controller and Allianz Plc Fair Processing Notice is applicable. You will be able to access and read this Fair Processing Notice later in the customer journey as well. Important Clarification on Data Scope

Only structured fields selected for the quotation process are transferred to Allianz Plc.

Allianz Plc does not receive:

full chat transcripts,

free-form conversational inputs beyond structured extraction, or

uploaded files such as images or PDFs (unless explicitly submitted as structured data fields).

This ensures that Allianz Plc processes only the minimum data necessary for providing a quotation (data minimisation principle).

Allianz Plc processes this data to provide a home insurance quotation, assess risk and eligibility, and fulfil pre-contractual and contractual obligations. Legal Basis of processing is contractual necessity (Article 6(1)(b) GDPR). Please read the detailed fair processing notice here. 5. Uploaded Documents (Images, PDFs) Any documents you upload (e.g. images or PDFs):

are processed within the OpenAI environment while you interact with the app;

are not transferred to Allianz Plc unless explicitly converted into structured fields and confirmed by you;

are not stored or retained by Allianz Plc as standalone documents.

Until submission, such content remains under OpenAI’s control as part of user-generated content. [openai.com] 6. Data Sharing and Transfers Your personal data is not shared with Allianz Plc until you explicitly confirm submission. At the point of submission, only the relevant structured dataset is securely transmitted to Allianz Plc. Prior to that point, any sharing is governed by OpenAI’s own processing activities and third-party arrangements. 7. Data Retention

Before submission: Data retention is governed by OpenAI’s policies. [openai.com]

After submission: Allianz Plc will retain your personal data only for as long as necessary:

to provide the quotation,

meet legal and regulatory obligations, and

for legitimate business purposes.

8. Your Rights Before Submission You should contact OpenAI to exercise your rights (e.g. access, deletion, correction), as OpenAI is the data controller at that stage. After Submission to Allianz Plc Once your data has been shared with Allianz Plc, you can exercise your data protection rights directly with Allianz, including:

access to your data,

rectification of inaccurate data,

erasure (where applicable),

restriction of processing,

objection to processing, and

data portability.

You also have the right to lodge a complaint with your relevant supervisory authority (e.g. the Irish Data Protection Commission). Please refer to the Allianz Plc Fair Processing Notice here. 9. Transparency and Further Information This notice is provided in line with GDPR transparency requirements, which require organisations to clearly explain how personal data is collected, used, and shared. For further information:

refer to OpenAI Privacy Policy for processing within the marketplace; and

refer to Allianz Plc Privacy Notice once your data has been submitted.

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