1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. 

1.5 In this policy, "we", "us" and "our" refer to Think Insurtech SAS For more information about us, see Section 17.

2. How we use your personal data

2.1 In this Section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed [for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.

2.3 We may process your website user account data ("account data"). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4 We may process your information included in your personal profile and your insurance needs on our website to get a comparison quote in conjunction with the Insurance Distribution Directive (EU) 2016/97 of the European Parliament and of the Council of 20 January 2016 on insurance distribution
"Profile data".The profile data may include your Last Name, First Name, Country of nationality, country of residence, email address, telephone number, Skype Id, gender, date of birth, relationship status, occupation
Profile needs.
“Profile needs” Insurance needs (hospitalization & emergency, outpatient treatment care, dental care & vision care, maternity care, medical assistance, CFE (French social security for french abroad)

        The profile data and needs may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.5 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.6 We may process information contained in any enquiry you submit to us regarding health & travel insurance ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or the taking steps, at your request, to enter into such a contract.

2.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR our legitimate interests, namely communications with our website visitors and service users OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.8 We may process information contained in or relating to any communication that you send to us ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The communication data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users and the proper administration of our website and business.

2.9 We may process identify the general category of data. This data may include listing specific items of data. The source of this data is to identify the source. This data may be processed for specific purposes. The legal basis for this processing is consent OR our legitimate interests, namely specify legitimate interests OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.10 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.11 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.12 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.13 Please do not supply any other person's personal data to us, unless we prompt you to do so.

3. Automated decision-making

3.1 We will use your personal data for the purposes of automated decision-making in relation to campaigns, newsletters and advertising.

3.2 All such emails will allow recipients to unsubscribe by using a link at the bottom of each email.

4. Providing your personal data to others

4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for the purpose of providing insurance services to us or to you or to your employer, but no supplier or subcontractor will have the right to use your personal data for its own purposes. The legal basis for this is our legitimate interests, namely the performance of a contract between you or your employer and us and/or taking steps, at your request, to enter into such a contract.

4.4 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.

4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.6    If you access our website or online services through a third-party website, such as Facebook, that website may pass information to us, such as, user ID, name associated with the ID, email address and location, and in addition, other information permitted under the privacy policy for that website. Our website may also return information about you to that website regarding your login.

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2 We and our other group companies have offices and facilities in France and Hong-Kong. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from source OR [the use of binding corporate rules, a copy of which you can obtain from source.

5.3 The hosting facilities for our website are located in Switzerland at Infomaniak ( Rue Eugène-Marziano 25, 1227 Geneva.The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from source.

5.4 The user information collects through Thinkinsurtech contact & webforms, Social networks & Mobile application, it is directly stored into the Google drive File stream and interlinked with the Cloud server. Also, these data's are transferred via API into the Pipedrive CRM and maintained by Google Workspace and Google Cloud products. See the following SaaS platform - https://www.thinkinsurtech.com.  These technicals data are hosted by Google Cloud servers and Infomaniak for the website ISO 14001, ISO 50001 and ISO27001 certified Infomaniak, as well as on our ISO27001 certified Google Workspace and Google Cloud, which has been the subject of SOC 2 and SOC 3 Type II audits. The Google Cloud server has also been brought up to date with the American HIPAA (Health Insurance) and they are registered in France on the ASIP Website as a health data host (HDS) . Under HIPAA, certain information about an individual's health or health care services is classified as protected health information (PHI, or Protected Health Information). Think Insurtech SaS has entered into a BAA (Business Associate Agreement) partnership for protected health data and information. The Google Platform's data protection shield, Gsuite is compliant with the European Union regulatory standards, GDPR (General Data Protection) adopted on 14 April 2016 by the European Parliament. Reference links; https://cloud.google.com/security/compliance/hipaa ; https://cloud.google.com/security/gdpr. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from source.

5.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5.6   Our Privacy Policy and Terms of Use are only in the English language. If your country of residence or the location where you are accessing our website requires that our Privacy Policy and/or Terms of Use be translated into the language of such country or location in order to be binding, please exit our website and do not use any of its content, services or features; if you nevertheless continue to use our website under these circumstances, you will be deemed to have waived the requirements of your country of residence or location where you are accessing our website, and accordingly, you agree that you willingly, voluntarily and irrevocably consent to be legally bound by the English version of our Privacy Policy and Terms of Use.

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

- The duration of your insurance plan for the effective management of your health & travel insurance.
- 3 years when you request a comparison quote.
- 5 years in the event of insurance fraud and 5 years in connection with the prevention of money laundering and the financing of terrorism

 Your data can be accessed and made available in accordance with the provisions of (EU) Data Protection Regulation 2016/679 of 27 April 2016, you have the right to access, rectify and erase data which is inaccurate, incomplete, ambiguous, out-of-date or whose processing would be unlawful and object to and restrict the processing (in the cases provided for by law) and portability (in the cases provided for by law) of your data. You also have the right to specify instructions for the storage, erasure and transfer of this data after your death.
You can exercise these rights by contacting our Data Protection Officer at support@thinkinsurtech.com
In accordance with the provisions of Article L561-45 of the French Monetary and Financial Code, with regard to data monitoring for the purpose of fighting money laundering and the financing of terrorism and the application of financial sanctions, you can exercise your right of access by applying to the French Data Protection Authority, Commission Nationale Informatique et Libertés - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07
You can make a complaint to the French Data Protection Authority, Commission Nationale Informatique & Libertés, online or by post if you feel, having first contacted us, that your rights are not being respected.
You can opt-out of marketing communications from us by contacting our Data Protection Officer. For marketing emails, you can also opt-out by clicking on the unsubscribe link in the email you received. For telephone marketing, you can opt by contacting Opposetel (www.bloctel.gouv.fr) in the application of Article L121-34 of the French Consumer Code.

6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Your rights

7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law are:

(a) the right to access - you can ask for copies of your personal data;

(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c) the right to erasure - you can ask us to erase your personal data;

(d) the right to restrict processing - you can ask use to restrict the processing of your personal data;

(e) the right to object to processing - you can object to the processing of your personal data;

(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary for compliance with a legal obligation.

7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.11 If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

7.12 To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.13 You may exercise any of your rights in relation to your personal data by written notice to us OR in addition to the other methods specified in this Section 7.

8. Third-party websites

8.1 Our website includes hyperlinks to, and details of, third party websites.

8.2 We have no control over and are not responsible for, the privacy policies and practices of third parties.

8.3    Any links to third-party websites are provided solely for your convenience and are not endorsements or recommendations by us of the parties, their websites, products or services.

8.4    Your access and use of such third-party websites are solely at your own risk; you are responsible to read the privacy and other policies of these websites to see how they treat and secure your personal information.

8.5    Third-party advertising and analytical cookies may be placed by or on behalf of independent advertisers, if any, who advertise on our site. You should review their privacy and cookie policies.

8.6    If you access our website through a mobile application or other types of third-party platform, the privacy and cookie policies for the mobile service or platform through which you downloaded the mobile application or third-party platform may apply in addition to our Privacy Policy and Terms of Use.

9. Personal data of children

9.1 Our website and services are targeted at persons over the age of 18 years old.

9.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

10. Updating information

10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

11. Acting as a data processor

11.1 In respect of insurance data, we do not act as a data controller; instead, we act as a data processor.

11.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

12. About cookies

12.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

12.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

12.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

13. Cookies that we use

13.1 We use cookies for the following purposes:

(a) authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to determine if you are logged into the website;

(b) personalisation - we use cookies to store information about your preferences and to personalise the website for you;

(c) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(d) advertising - we use cookies to help us to display advertisements that will be relevant to you.

(e) analysis - we use cookies to help us to analyse the use and performance of our website and services;

(f) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally;

14. Cookies used by our service providers

14.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

14.2 We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.

14.3 We publish Google AdSense advertisements on our website, together with advertisements from the following advertisers and advertising networks that are distributed by Google: https://adssettings.google.com/authenticated. The advertisements may be personalised to reflect your interests. To help determine your interests Google and its partners use cookies.The cookies are used to track your previous visits to our website and your visits to other websites. You can opt out of Google's personalised advertising by visiting https://www.google.com/settings/ads and you can opt-out of third-party cookies use for personalised advertising by visiting http://www.aboutads.info. You can review Google's privacy policy at https://policies.google.com/privacy.

14.4 We use a Facebook pixel on our website. Using the pixel, Facebook collects information about the users and use of our website. The information is used to personalise Facebook advertisements and to analyse the use of our website. To find out more about the Facebook pixel and about Facebook's use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook's use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217.

15. Managing cookies

15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

15.2 Blocking all cookies will have a negative impact upon the usability of many websites.

15.3 If you block cookies, you will not be able to use all the features on our website.

16. Amendments

16.1 We may update this policy from time to time by publishing a new version on our website.

16.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

16.3 You should check back frequently and regularly to read and ensure familiarity with the most current version of our Privacy Policy and Terms of Use. If at any time our Privacy Policy and/or Terms of Use are no longer acceptable to you, please exit our website and do not use any of its content, services or features.

16.4  All content, materials, and user comments provided to us for publication on our website, and all communications sent to us by email or otherwise are deemed to have been provided or sent in full knowledge and acceptance of the most recent Privacy Policy and Terms of Use as displayed on our website.

17. Our details

17.1 This website is owned and operated by THINK INSURTECH SAS - Simplified Joint stock company with a capital of €860 566,60 - RCS Nanterre 910 9007 005 - Member CNCEF 22/5248 (www.cncef.org)

17.2 We are registered as Intermediaries Insurance & Reinsurance with ORIAS 22002636 (and under the tutorship of the ACPR (Autorite de Controle prudentiel) regulator.

17.3 Our principal place of business is at  Think Insurtech SAS - 3 rue Joseph Riviere - 92400 Courbevoie - France. Tel : +33 1 76 21 10 65/66/67/68/69

17.4 You can contact us:

• (a) by post, to he postal address given above;
• (b) using our website contact form;
• (c) by telephone, on the contact number published on our website; or
• (d) by email, using the email address published on our website.

18. Data protection officer

18.1 Our data protection officer's contact details are: Think Insurtech SAS - 3 rue Joseph Riviere - 92400 Courbevoie - France - Email : team@thinkinsurtech.com ; please send a double-sided photocopy of your ID with your request. 

The English version of this policy is the original version.