We, at Fender S.A., are committed to protecting your personal data.

We have policies and procedures in place to ensure that the information you share with us is held securely and processed in accordance with our data privacy obligations.

The purpose of this Privacy Notice is to outline how we collect, process and store personal data received either directly from our individual clients or indirectly through our commercial clients.

Legal Framework
The collection and processing of personal data are subject to the provisions of this Privacy Policy, the EU General Data Protection Regulation 2016/679 (hereinafter “GDPR”) as well as the applicable National, European and International Law on the protection of natural persons with regard to the processing of personal data.

Data Controller/Data Processor
Fender S.A. (hereinafter “Fender”),, processes personal data as a Data Controller and is responsible for deciding how those are to be handled.

Under certain circumstances and within the scope of a specific agreement signed between the parties, Fender may, subject to the provisions of the Law, process personal data of clients as a Data Processor.

Personal Data
In order for us to provide insurance quotes, insurance policies, and/or handle any claims or complaints, we collect, retain and process personal data about you. This information may include:

• Identification Information
Name, surname, contact details, gender, marital status, date & place of birth, ID details, VAT registration number, social security number, passport number, driver’s license number, job title, employment history, family details.

• Financial Information
Income information, bank account details, credit & debit card details.

• Special Categories of Personal Data (information regarding physical & mental health)
Medical history (physical & medical conditions), medical treatment, medical exams, surgeries, injuries, disabilities, deaths, medication, alcohol consumption, drug abuse, smoking.

• Credit & Anti-Fraud Data
Social security clearance certificate, tax clearance certificate, credit history, sanctions and criminal offences regarding fraud and/or money laundering.

• Risk Details
Information regarding the risk against which you are seeking insurance coverage. This may include data relating to your health or other special categories of personal data.

• Claims History
Information regarding previous and current claims which may include data relating to your health or other special categories of personal data.

It is essential that you provide us with accurate and specific information. If during your relationship with us, any of the information you have provided to Fender is incorrect or any personal data has changed, please inform us accordingly in order to update our files.

Collection of Personal Data
We may collect information either directly from you, your family members or your employer who must have acquired the relevant authorization by yourself beforehand.

Personal data might be collected from your application:

• for insurance coverage
• for the amendment of the insurance policy
• for the renewal of the insurance policy
• for the conversion of insurance policy
• for the cancellation of insurance policy
• for reporting of claim
• for receiving insurance benefits.

Information may be further collected through our authorized personnel or associates and through our website, exclusively within the scope of a specific application/request that the users of the website file electronically.

Use of Personal Data
Under our capacity as insurance brokers, any personal data provided to us will be used for the purposes outlined below:

Quotation and Inception of an Insurance Contract:
• to evaluate, process and complete your requests and/or applications for insurance coverage
• to assess the risk against which you are aiming to be insured
• to verify your identity
• to manage payment of premium where the policyholder is an individual

Claims Processing:
• to handle, defend and prosecute insurance and/or legal claims

Policy Administration:
• to communicate with you
• to handle payments to and from individuals

Renewals:
• to approach you for the renewal of the insurance policy
• to assess the risk against which you are aiming to be insured
• to calculate the appropriate premium
• to manage payment of premium where the policyholder is an individual

Marketing:
• to approach our clients, you, regarding our products and/or services, subject to your prior approval

Other:
• to accommodate your requests regarding the services provided by Fender (customer support)
• to meet our legal and regulatory obligations – including prevention and detections of fraud, money laundering and other financial crimes
• to defend our legal rights

Legal Ground
We collect and process your personal data relying on the following legal grounds:

The performance of the insurance contract
Processing is necessary for the performance of the contract to which you are a party or in order take the appropriate steps as per your request prior to entering into a contract.

Vital interest
Fender may process data in order to protect your vital interests or of another natural person, insured/beneficiary of the insurance policy.

Compliance with Fender’s legal obligations
Processing might be necessary for compliance with a legal obligation to which we are subject and for the defense of our legal rights under the conditions set out by Law.

Data Subjects’ Rights – Your Rights
Subject to Articles 13 to 21 of the GDPR and with regards to the personal data you provide to us, you retain, inter alia, the following rights:

Right to Information
You have the right to know who is processing your data, what data are being processed, for what purpose and for how long the processing takes place.

Right to Access
You have the right to receive confirmation as to whether or not your personal data is being processed, what data are being processed, for what purpose, how long they are stored and to whom they can be disclosed.

Right to Rectification
You have the right to request the correction of inaccurate or irrelevant personal data and to fill in incomplete information.

Right to Erasure (‘right to be forgotten’)
You have the right to request the deletion of your personal data under certain conditions set by the Regulation, such as when the data is no longer necessary, you have withdrawn your consent, the data has been processed illegally, etc.

Right to Restriction of Processing
You have the right to request that the processing of your personal data be restricted when their accuracy is contested, the processing is unlawful, the data are no longer needed by the controller, or you have objections to processing by automated means.

Right to Objection
You have the right to oppose at any time to the processing of your personal data, which is based on the processing being necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or such processing being necessary for the purposes of the legitimate interests pursued by the controller or by a third party, including profiling.

Right to Portability
You have the right to receive the personal data that concern you and that you have provided, in a structured, commonly used and machine-readable format and the right to transmit those data to another company without hindrance from the Company to which the personal data have been provided, where: (a) the processing is based on consent or a contract; and (b) the processing is carried out by automated means. When exercising the right to data portability, you have the right to request the direct transmission of personal data from one controller to another where this is technically feasible.

If you wish to exercise any of your above rights or have any questions, please contact us via email at privacy@fendersa.com . We must respond in writing within one (1) month.

If you believe that the protection of your personal data is threatened in any way, you have the right to lodge a complaint to the Hellenic Data Protection Authority: 1-3 Kifisias Ave., 115 23, Athens, Greece. Detailed information regarding the Authority’s competency and the complaints procedure may be found at www.dpa.gr.

Retention of Data
We shall retain your data, in hard or soft copy format, for as long as it is necessary for the conclusion and performance of the insurance policy and for the handling of any claim arising thereof.

Disclosure of Data
We shall not sell or in any way publish and/or disclose your personal data to any third party, natural or legal person, for commercial, promotional or other purposes unless disclosure of data is required in any of the cases described below.

Disclosure to Third Parties
If disclosure to third parties such as insurance and/or reinsurance companies is necessary for the conclusion and performance of an insurance policy. Information may be disclosed further to other recipients, i.e. intermediaries, surveyors or experts, correspondents, lawyers, doctors, hospitals, diagnostic centers, laboratories, companies providing services of urgent transfer /evacuation/ medevac/ airlift. This Privacy Policy is NOT binding for the aforementioned parties and/or recipients. It is strongly suggested that you read carefully the Privacy Policies issued by those parties.

Disclosure to Third Parties providing services to Fender
If disclosure of data to natural persons or legal entities that provide services to Fender is necessary for the fulfilment of your requests within the scope of the insurance contract, i.e. IT services providers, hosting services, insurance premiums collecting agents. Processing of the disclosed data is made by the above entities within the scope defined by us. We take the necessary steps to ensure that only the minimum data are disclosed in each case depending on the specific purpose and that such data are processed lawfully. For more information you may contact us at privacy@fendersa.com.

Disclosure to our Employees
If said disclosure is necessary to be made to our employees and administration so that you are provided with the requested services.

Further reasons for Disclosure
We may disclose your personal data if this is required:

• by the law and to the competent authorities
• by order of a competent public, administrative or judicial authority
• to protect our legitimate rights and interests and to comply with our legal obligations

Transfer of Data outside the EEA
We may need to transfer your data to insurance market participants or their affiliates or sub-contractors which are located outside of the European Economic Area (EEA). Those transfers shall always be made in compliance with the GDPR provisions.

We will only transfer your personal data, subject to either of the following:

• the country is recognized by the European Commission as providing adequate level of protection
• an agreement regarding the transfer of data is in place and includes appropriate safeguards for the safety of data
  standard protection clauses have been implemented
• you have been informed of the transfer and have provided your consent
• the transfer is necessary for the performance of a contract between you and Fender
• the transfer is necessary for the undertaking of pre-contractual actions subject to your request
• the transfer is necessary for the conclusion and performance of a contract which is concluded in favor of you between us and another natural person or legal entity
• the transfer is necessary for handling and/or defending claims.

Data Protection Officer
In case you have any concerns or questions regarding the handling of your personal data or wish to exercise any of your rights outlined above, please contact our Data Protection Officer using the below details:

Email: privacy@fendersa.com

Tel: +30 2177 317171

Status of this Privacy Policy
Fender reserves the right to modify this Privacy Policy without prior notice. The updated version of the Privacy Policy will be posted at our website www.fendersa.com. We therefore encourage you to review it from time to time to stay informed of how we are using personal data.

This version is dated 25th March 2019.