Privacy & Data Protection policy

Who is responsible for processing your data?

All data provided by Users on www.howdeniberia.com will be incorporated and processed, through telematic, computer, physical and, in any case, automated means, in files owned by Howden Iberia SAU (hereinafter referred to as « HOWDEN «), being the entity responsible for these files.

In this sense, the entity responsible for processing the data is the following:

Name: Howden Iberia SAU, Insurance and Reinsurance Brokers

Residence: Calle Montalbán number 7, Ground floor, 28014 Madrid (Spain).

Email: [email protected]

Furthermore, HOWDEN has a data protection officer , whose functions are defined in Article 39 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter referred to as " GDPR «).

Contact of the Data Protection Delegate: [email protected]

Who can provide us with data?

The data to which Howden has access is transmitted directly by the interested party or, through third parties, based on the contractual relationship between client and broker or the provision of services via corporate mail, calls, questionnaires, etc.

By accessing our website, for the purposes detailed in the data protection information, the user declares that he or she is over 16 years of age. Likewise, if the data you provide to us belongs to minors, one of the parents or guardians of the minor must expressly authorize the processing of such data, including, where appropriate, data relating to health.

All data provided by the user, whether mandatory to provide the service or information, or additional data to complete that information and request, are considered true and correct, that is, they correspond to your real situation.

All data is provided voluntarily and you give us your consent to process it, both computerized and automated, for specific and legitimate HOWDEN purposes, not being used for incompatible or unauthorized purposes.

What data do we collect?

When submitting an information inquiry or contacting us by email, we may ask you to provide us with a series of personal data and information, such as your name, surname, address, email and contact telephone number, security social security, information about your salary, banking details, health, pensions, as well as other elements provided through forms designed to meet the specific needs of current or potential customers. This data that we request, and which is subject to processing by HOWDEN, will always be adequate, relevant and not excessive to your request for information or service.

For what purposes do we process your personal data?

At Howden, we will process the data you provide while browsing and using our website, which has been collected through the corresponding form or obtained through the recording of telephone conversations or other means, including health, for the following purposes:

Regarding navigation and use of our website, we will process your data to:

• Offer you more personalized navigation and a better experience as a user of our website.
• Develop statistics on the countries and servers that visit the web most frequently.
• Know the busiest times for visitors to the Web and make precise adjustments to avoid access problems.
• Know the effectiveness of the different buttons and links that are directed to our server, in order to improve those that offer better results.
• Update a record of user activity via the web.
• In relation to the forms provided for contracting, ordering or pricing our products or the products of insurance companies, we will process your data:
• Manage our activity as an insurance intermediary and compliance with the insurance contract itself.
• Requests for rates and procedures for products offered through this website or from insurance companies.
• Comply with the legal obligations that apply to us.
• Maintain and manage its relationship with the different entities of the Group in an integral and centralized manner.
• Manage and delimit risks, prevent and investigate fraud in risk selection and claims management, even if the insurance contract is not formalized or, where appropriate, has expired.
• Carry out statistical studies and calculations, surveys, market trend analysis and quality control.
• Process, monitor and update any request for information, commercial, pre-contractual or contractual relationship.

Furthermore, in the forms in which you have given us your consent, we will process your data for this purpose:

• Send you information and advertising, including by electronic means, about offers, products, recommendations, services, promotions, gifts and loyalty campaigns, extraction, storage of data and marketing studies, in order to adapt our commercial offers to your profile particular, whether or not any operation is formalized, or when applicable, once the existing contractual relationship has ended; as well as carrying out surveys, statistics and analysis of market trends and sweepstakes, and may, in the event of an award, publish them on this website, as well as process and transfer them to the tax administration for the purpose of making payment for account charged to Personal Income Tax, if applicable.
• Send (user's prior subscription through the Subscription Area) electronic newsletters.

This site is being measured using Google Analytics solutions. These solutions use tags on pages and anonymous cookies, in order to analyze the information received (for example, number of visits, duration of visit, behavior on the page...) and based on them, improve the user experience and improve digital processes of operation and communication.

More information about the Google Analytics privacy policy can be found at http://www.google.com/intl/es_ALL/privacypolicy.html .

How is the information used?

HOWDEN will use the information you provide to us for the following purposes:

• Receive, manage, process and respond to queries and requests for information that you make/send to us through the contact methods available on our website or by contacting our offices and delegations.

To whom will your data be communicated?

By sending us a query or request for information via contact email, you are giving us informed, conscious and express consent to process the data provided to HOWDEN .

From that moment on, HOWDEN may communicate your data, exclusively for the purposes indicated in the section «For what purposes do we process your personal data», to other entities belonging to Hyperion Insurance Group Limited (hereinafter « HYPERION GROUP «) ( www. hyperiongrp.com ), subsidiaries and affiliates, as well as third parties with whom it enters into collaboration agreements.

In this sense, any entity belonging to the HYPERION GROUP , including subsidiaries and affiliates, may transfer the information it provides to us to any other group entity, or to third party collaborators, as long as the information serves to make an offer that may benefit you, within the scope of the business that HOWDEN carries out, respecting in all cases the applicable legislation on the protection of personal data and without the need for interested parties to be informed of each first communication made.

Within the scope of the communications indicated in the previous paragraph, international data transfers may be carried out to third countries or international organizations regarding whether or not there is an adequacy decision by the European Commission in relation to them. International transfers to countries that cannot guarantee an adequate level of protection will be exceptional and will be carried out whenever they are essential for the development of relations with the Entity.

HOWDEN , being an insurance broker, in order to carry out its commercial activity, must transfer data to insurance companies and professionals who provide insurance services, who in turn, will act as responsible for the processing of personal data, always to the extent necessary to carry out the actions or benefits contracted/requested by you.

Furthermore, your data may be transferred to Public Bodies and Administrations with competence in the matter, in accordance with the legal regulations in force.

Security of your data

HOWDEN attaches great importance to the security of all personally identifiable information of its customers. Unfortunately, the transmission of information over the Internet is not completely secure; Therefore, we make efforts and allocate resources to improve our website every day and make the resources we make available to you more secure.

Therefore, we have implemented security measures to ensure access, confidentiality, integrity and prevent any loss, misuse and/or alteration of customer data under our control. For example, our security and privacy policies are periodically reviewed and improved as necessary and only authorized personnel have access to user information.

IP addresses

We may collect information about your computer, including your IP address, operating system and browser type, for system administration and to provide more personalized information to your connection point. This is statistical data about our users' browsing actions and patterns and does not identify any person.

Your Rights and Access to Information

In accordance with current community legislation (EU 2016/679 of the European Parliament and the Council of 27 April 2016) and Portuguese law (Law no. 58/2019 of 8 August on the Protection of Personal Data and guarantee of digital rights), you have the possibility of exercising the following very personal rights, proving your identity in a reliable way, either by electronic means (in the case of newsletters and emails), or by written communication addressed to the person responsible for the data, above mentioned. Therefore, the rights you can exercise in relation to your data are the following:

Right of access: the right of a person to request information from the person responsible for a file about whether or not their personal data is being processed.

Right to rectification: right that allows the data subject to request the amendment of inaccurate or incomplete data.

Right to object: the right of a person to object to the processing of their personal data or to the cessation of such processing in specific cases:

• that your consent is not required,
• where files are used for advertising purposes,
• or that the processing aims to adopt a decision regarding the data subject.

Right to be informed: you have the right to be transparent about how we use personal data and to receive information that is subject to "correct processing", both through our privacy/processing notices and through our websites.

The information we provide about our processing of personal data must be:

• be concise, transparent, intelligible and easily accessible
• be written in clear and concise language, especially if they are addressed to a child, and
• be free.

Right not to be subject to individualized decisions: You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects or affects you. Exceptions are made where:

• It is necessary for the conclusion or execution of a contract. It is permitted by EU or Member State law, with appropriate measures to safeguard the rights and freedoms of the data subject.
• There is explicit consent from the person involved.

Right to limit processing . This right allows you:

Request the data controller to suspend data processing when:

• The accuracy of the data is disputed and while this accuracy is checked by the data controller.
• The data subject exercised his or her right to object to data processing, verifying that the legitimate reasons of the controller prevail over those of the data subject.
• Ask the person responsible to save your personal data when:
• The data processing is unlawful and the data subject opposes the deletion of their data and requests, instead, the limitation of their use.
• The data controller no longer needs the data for processing purposes, but the data subject needs them to formulate, exercise or defend their requests.

Right to data portability: possibility of requesting the controller to provide personal data in a structured and clear format to another controller.

Right to be forgotten: immediate deletion of the data subject’s personal data, provided that such data provided:

• are no longer necessary for your purposes
• withdraw authorization
• exercise the right to object to them or that they are treated illegally
• or who is aware of any of the following circumstances:
• Personal data is no longer necessary for the purposes for which it was collected or otherwise processed
• the data subject withdraws the consent on which the processing is based and it is not based on another legal basis
• The data subject objects to the processing under the right to object, for special reasons or for marketing reasons, and if other legitimate reasons for the processing do not prevail
• personal data has been processed illegally
• personal data must be deleted to comply with a legal obligation
• The personal data were obtained as part of the provision of information society services

Our websites www.howdeniberia.com and https://www.howdenportugal.com/ may contain links to other websites, which may belong to our partners, associated companies, among others. If you access these links, please note that you may be asked to provide personal data or information. HOWDEN is not responsible for the data provided to it, as each company must maintain the privacy of its own data . In this sense, the interested party will be responsible for reading and evaluating the conditions of each website.

Responsible for Privacy

At any time you can request, completely free of charge, by letter or email, the exercise of your rights, and must include a photocopy of your Citizen Card, Passport or equivalent document, specifying the request, address for notifications, date and signature and supporting documents the request, if applicable. Such requirements are necessary because we are faced with a personal right, which can only be exercised by the person concerned, or in the case of minors, by the minor's parents or guardians.

Your requests must be sent to our Data Protection Officer at the address previously provided. If you wish to place the order online, you can send the communication to [email protected] , through which we will respond to your request.

Changes to the Privacy Policy

Taking into account continuous changes and improvements in regulations relating to data privacy, HOWDEN may modify or adapt its Privacy and Personal Data Processing Policy . Therefore, we recommend that interested parties, each time they browse the website, review this section, in order to always be informed about updates or improvements, and even regulatory changes.

Modifications to the Privacy Policy
From time to time we may modify or adapt our Privacy Policy and Processing of Personal Data. We recommend that you visit it each time you browse the website in order to always be informed in advance of any data you provide to us.