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Appendix 2

Legal Basis for Treatment

 

Activity

Type of information collected (*)

Basis for using information

People to whom we may disclose information

Beneficiaries and policyholders

Evaluate insurance proposals, assess risks and accept policies

  • Risk location
  • Personal risk information
  • Gender;
  • Date of birth,
  • profession, registration number in class entity, position;
  • Health data
  • Criminal records
  • Processes that are part;
  • Marital status;
  • ITIN, name, address, e-mail, telephone;

 

  • Develop steps to conclude a contract
  • Legitimate interests (to determine the probable risk profile and the appropriate level, cost and coverage to be granted, if applicable)
  • Consent
  • Legal / regulatory obligation
  • Other insurers / reinsurers Technical analysis service providers;
  • Other Chubb entities;
  • Other insurers;
  • Reinsurers  and reinsurance brokers.

Creating records in our systems

  • Name, address, ID number, marital status, profession
  • Contact information
  • Personal risk information
  • Policy information
  • Bank data
  • Income information, in cases of rental insurance.
  • Execution of a contract
  • Legitimate interests. (to ensure that we have accurate records of all policyholders we cover)
  • Legal or regulatory obligation
  • Assistance service providers hired by the insurance company;
  • Brokers who intermediated the contracting of the policy;
  • Digital signature services

Manage renewals

  • Registration data
  • Date of Birth, profession, number of registration in class entity
  • Graduation Date
  • Contact information
  • Policy information
  • Personal risk information
  • Gender,
  • Health data
  • Criminal records
  • Marital status
  • Position,
  • Spouse data and children's data.
  • Execution of a contract
  • Legitimate interests  (to decide on renewing the policy for a new period and, if so, on what terms)
  • Consent

 

  • Assistance service providers
  • Marketing agencies (email only and in some of our channels);
  • Other Chubb entities;
  • Other insurers;
  • Reinsurers and reinsurance brokers;
  • Intermediaries, such as insurance brokers.
  • Technical analysis service providers.

Provide care, assistance and support to customers

  • Registration data
  • Date of birth, profession
  • Dependent data (when needed) 
  • Contact elements
  • Policy information;
  • Execution of a contract
  • Conditional consent
  • Support service providers

 

Receiving prizes and payments

  • Contact elements
  • Bank data
  • Execution of a contract
  • Banks
  • Premium collection service providers

Commercialization (marketing)

  • Contact information

 

  • Legitimate interests (to provide information to policyholders about insurance products or services that may be of interest to them)
  • Consent
  • Service providers
  • Marketing Agencies

Comply with legal and regulatory obligations

  • Registration Data and Dependent Data 
  • Date of Birth, profession, registration number in class entity
  • Health data
  • Policy and claims data
  • Contact information
  • Policy information
  • Personal risk information
  • Financial information
  • Legal or regulatory obligation.

Activity

Type of information collected (*)

Basis for using information

People to whom we may disclose information

Claimants

Claims reports and claims expectations

  • Registration data
  • Contact information
  • Policy and insured object information
  • Claims elements  

 

  • Execution of a contract
  • Legitimate interests(claimants third parties) (to keep accurate records of all claims received and the identity of the injured parties)  
  • Insurance brokers;
  • External claims managers;
  • Assistance service providers;
  • Service providers;
  • Reinsurers and reinsurance brokers.

Assess the claim

  • Elements of claims
  • Health data
  • Data on criminal convictions
  • Execution of a contract
  • Legitimate interests (to assess the circumstances of claims)
  • Consent
  • Exemptions under local law
  • Declaring, exercising or defending a right in a judicial process  
  • External claims managers
  • Experts
  • Lawyers
  • Reinsurers;
  • Brokers.

Monitor and detect fraud

  • Claims elements
  • Data to prevent and combat fraud
  • Execution of a contract
  • Legitimate interests (to monitor, evaluate and ultimately prevent fraud)
  • Consent
  • Exemptions under local law
  • Declaring, exercising or defending a right in a judicial process  

 

  • Service providers;
  • Anti-fraud databases
  • Lawyers  

Paying compensation for claims

  • Financial information
  • Execution of a contract
  • Legitimate interests (claimants third parties) (to pay damages claims to injured third parties who are entitled to them)  
  • Banks
  • Lawyers
  • Brokers

 

Comply with legal and regulatory obligations

  • Policy information
  • Claims elements
  • Data to prevent and combat fraud
  • Financial information  
  • Legal or regulatory obligation
  • Public authorities and regulatory bodies (for example, Federal Revenue, Central Bank, SUSEP)
  • Police authorities
  • Judicial Branch

Activity

Type of information collected (*)

Basis for using information

People to whom we may disclose information

Business partners and visitors

Manage relationships

  • Contact information

 

  • Legitimate interests (to maintain a customer and partner relationship management platform)
  • Consent  
  • Service providers  

Administer contracts

  • Contact information
  • Execution of a contract
 

Commercialization (marketing)

  • Contact information
  • Legitimate interests (to communicate with business partners about events, services or products that may be of interest to your industry)
  • Consent
  • Service providers

Organize events and welcome office visitors

  • Registration Data and;
  • Contact information
  • Images by surveillance cameras
  • Legitimate interests (organizing and hosting events that may be of interest to business partners and surveillance to seek security on our premises)
  • Consent  

Activity

Type of information collected (*)

Basis for using information

People to whom we may disclose information

Applicable to all

Portfolio Transfer

  • All (when relevant to the transfer of the portfolio)

 

  • Legitimate interests (structure our activity properly)
  • Legal or regulatory obligation (transfer of portfolio under the terms of the applicable law and regulation)    
  • Buyer
  • Professional consultants;
  • Lawyers;
  • Regulatory body.

Corporate reorganization of Chubb companies

  • All
  • Legitimate interests (structure our activity properly)
  • Legal or regulatory obligation (insurance transfer under the terms of the applicable law)
  • Consent
  • Buyer;
  • Other Chubb entities;
  • Professional consultants;
  • Lawyers;
  • Regulatory body.

Telephone call recording

  • Contact information
  • Claim details
  • Other information shared in the context of the call  
  • Consent
  • Legal or regulatory obligation;
  • Legitimate interests (staff training, proof of intention to take out insurance, assistance in resolving complaints, improving customer service or detecting fraud)    
  • Service providers;
  • Regulatory bodies
  • Judicial Branch;
  • Public authorities
  • Lawyers;
  • Other Chubb entities.

(*) Other information may eventually be collected depending on the specific case.

Updated July 2020