Privacy Policy
1. Introduction
This Privacy Policy contains information on the data processing activities carried out by the companies of the Ferrer&Ojeda Group in Spain (hereinafter, Ferrer&Ojeda) for the provision of its insurance mediation services (including brokerage and distribution services) and reinsurance, advisory services and other services (hereinafter, the Services).
We recommend that you read this Privacy Policy carefully and, if you have any questions related to it, you may contact Ferrer&Ojeda at the addresses indicated in the “Ferrer&Ojeda Contact Details” section of this Privacy Policy.
2. Who is responsible for your information?
This Privacy Policy refers to Ferrer&Ojeda Asociados Correduría de Seguros SL and the companies of the Ferrer&Ojeda Group (you may consult a list of the companies that make up the Ferrer&Ojeda Group in the Legal Notice at www.ferrerojeda.com). Any reference to “we”, “us”, “our”, or “Ferrer&Ojeda” in this Privacy Policy refers to the companies of the Ferrer&Ojeda Group.
We inform you that your data may be processed by Ferrer&Ojeda Asociados, Correduría de Seguros, S.L., with registered office in Barcelona, Calle Tamarit 155-159, Postal Code: 08015, as well as by the brokerages that make up the Ferrer & Ojeda Group (you may consult a list of the companies that make up the Group on the website www.ferrerojeda.com, in the Legal Notice section).
3. What personal data does Ferrer&Ojeda process?
Ferrer&Ojeda processes only the data or personal information necessary for the fulfillment of its legitimate purposes. By virtue of the provision of its services, Ferrer&Ojeda processes the personal data of its clients or prospective clients (hereinafter, the “Data Subject” or “Data Subjects”) in order to comply with its legal and contractual obligations and to satisfy its legitimate interests.
The personal data that Ferrer&Ojeda may process from Data Subjects (hereinafter, “Personal Data”) are as follows:
- Identification and contact data, such as name and surname, age, gender, date of birth, nationality, marital status, ID/Passport, email, postal address, telephone number.
- Information on remuneration, pensions and current benefits schemes.
- Bank details.
- Health data.
- Data on insurance contracts and claims related thereto.
- Information on complaints and claims related to Ferrer&Ojeda’s activities.
- Voice data for call recording.
- Browsing data on Ferrer&Ojeda’s website or use of Ferrer&Ojeda applications.
Likewise, Ferrer&Ojeda may process, for analysis and segmentation purposes, basic identification and contact data (name, surname, address, telephone and email) obtained from publicly accessible sources, in order to supplement the information provided by the data subject. This processing is limited to strictly necessary data to determine the potential status of self-employed workers, with the sole purpose of offering insurance products tailored to their needs.
4. Source of personal data
The source of the Personal Data accessed by Ferrer&Ojeda may be the Data Subject themselves or third parties. In particular, Ferrer&Ojeda collects Personal Data in different ways, as detailed below:
a. From the data subject themselves. When a person is interested in contracting Ferrer&Ojeda’s services, the necessary information is requested to respond to their request. When a data subject provides personal information, it is used for the purposes for which it was provided and as indicated in this policy.
The data subject must provide the personal information necessary to fulfill our obligations in relation to the services we provide.
When the data subject provides personal information to Ferrer&Ojeda about third parties (for example, information about their spouse, civil partner, children, dependents or emergency contacts), where applicable, they must previously provide such persons with the relevant information regarding the processing of their data by Ferrer&Ojeda.
In the event of any change in your personal information, in particular changes related to your contact details, bank account details, insurance policy details or any other information that may affect the management and administration of your insurance policy and/or the services provided by Ferrer&Ojeda, you must notify this for the proper provision of services.
b. Call recording: telephone calls you have with Ferrer&Ojeda may be recorded for quality control purposes. In addition, certain telephone conversations will be recorded for the purpose of verifying and recording requests, transactions and other agreements with the client. In cases where the call is recorded, you will be informed in advance.
Recorded conversations and any personal information about the recording will be stored in such a way that they are not accessible to unauthorized persons. Ferrer&Ojeda has adopted technical and organizational measures to prevent manipulation of recordings and to ensure the security of the information.
c. Ferrer&Ojeda may also collect personal information about the data subject from other third parties, such as policyholders, reinsurers and claimants. This information may be obtained before and/or during the provision of services.
d. Mobile devices: If you access our websites on your mobile phone or device, Ferrer&Ojeda may collect your unique device identifier and the IP address of your mobile device through cookies.
e. In addition, for certain internal analysis activities, Ferrer&Ojeda may obtain information from publicly accessible sources (for example, official registries or bulletins) in order to identify clients more likely to develop self-employed activity. Under no circumstances are private databases accessed, nor are non-public sources used.
5. Purposes of processing
Ferrer&Ojeda processes Personal Data in accordance with the purposes described below:
a. To fulfill contractual obligations in relation to insurance policies intermediated by Ferrer&Ojeda under which the Data Subject may be a beneficiary, insured and/or policyholder depending on the circumstances, as well as to fulfill any other purposes related to the provision of mediation services or any other service that may be provided by Ferrer&Ojeda.
b. Sending commercial communications in relation to products and services marketed by Ferrer&Ojeda (especially in insurance, mediation and consulting), not only by postal mail but also by SMS, instant messaging applications, email or any other electronic or telematic means available at any given time, under the terms provided in Article 21 of Law 34/2002 on Information Society Services and other applicable regulations.
Ferrer&Ojeda reminds you that, at any time, the Data Subject has the right not to receive information and advertising by electronic means or by post. Therefore, if the Client wishes to unsubscribe and stop receiving commercial communications and advertising, they may indicate this by sending an email to: dpo@ferrerojeda.com, indicating their identifying details and expressing their opposition to receiving commercial communications by electronic means.
c. To comply with legal and regulatory obligations applicable to Ferrer&Ojeda.
d. To carry out those processing activities necessary for the formulation, exercise or defense of claims, and the satisfaction of other legitimate interests of Ferrer&Ojeda, ensuring that the rights and freedoms of Data Subjects are not affected.
e. To carry out analysis using artificial intelligence tools to identify clients who may have the status of self-employed workers, in order to adapt and offer insurance products in line with their needs (for example, disability insurance). This processing does not involve automated individual decisions with legal effects, nor does it significantly affect the rights of data subjects.
6. Legal basis for processing
All processing of personal data by Ferrer&Ojeda is justified by a “legal basis”.
a. Performance of a contract entered into with the data subject or application of pre-contractual measures: when Ferrer&Ojeda offers its services or enters into a contract with the data subject to provide services, it collects and uses the personal data necessary to carry out the provision of services, process acceptance of the offer and comply with the obligations assumed in the contract.
b. Compliance with legal and regulatory obligations: Ferrer&Ojeda may process personal data of the data subject to comply with certain obligations imposed by applicable legislation, such as the implementation of due diligence measures for the prevention of money laundering and terrorist financing established by Law 10/2010 of April 28. Likewise, data may also be processed for the communication of information to authorities, regulators or government bodies that require it.
c. Satisfaction of legitimate interests of Ferrer&Ojeda: the collection and use of certain categories of personal data may be based on Ferrer&Ojeda’s legitimate interest in preventing fraud, offering products and services that may be of interest to the client or user, or conducting market research to improve its products and services. When relying on this legal basis, Ferrer&Ojeda will take appropriate measures to ensure that processing does not infringe the rights and freedoms granted to the data subject under applicable data protection regulations.
d. Satisfaction of Ferrer&Ojeda’s legitimate interest in improving the quality of its insurance offering by segmenting clients based on relevant characteristics to tailor products to their real needs. In any case, the potential impact on the rights and freedoms of data subjects has been assessed and deemed limited, as only public sources are used and the result does not produce negative legal effects.
e. Consent of the data subject: where necessary, Ferrer&Ojeda will request the data subject’s consent to collect and use personal information.
7. Recipients of personal data
In order to fulfill the purposes set out above, Ferrer&Ojeda may share the personal information of Data Subjects with third parties.
Where necessary, your express consent will be requested. This may be included in the section dedicated to “International Transfers”. Accordingly, Ferrer&Ojeda may share your personal data with:
a. Companies within the Ferrer&Ojeda Group (within the meaning of Article 42 of the Spanish Commercial Code), for internal administrative purposes.
b. Insurance companies with which the Data Subject decides to contract policies intermediated by Ferrer&Ojeda, in order to initiate and maintain the contractual insurance relationship and process claims covered by such policies, as well as experts or reinsurers.
c. Judicial authorities and other competent public bodies and regulators to respond to requests from public authorities and to cooperate with law enforcement or for other legal reasons.
d. Legal or technical advisors, when necessary to exercise or defend legal, insurance or similar claims.
8. International transfers
Ferrer&Ojeda is an organization operating internationally and may transfer certain personal information about you to other countries for processing for the purposes described in this Policy.
Ferrer&Ojeda will take appropriate measures to ensure that such transfers comply with all applicable data protection laws and regulations and provide adequate protection for individuals’ rights and freedoms.
In the event of transferring personal data to countries outside the European Economic Area (international data transfers) for the fulfilment of the legitimate purposes described in this Privacy Policy, such transfers may be carried out to countries that offer adequate data protection safeguards. When Ferrer&Ojeda transfers personal data to countries that are not subject to an adequacy decision, such as the United States, it will implement the appropriate safeguards required by applicable data protection legislation (such as certification mechanisms or standard contractual clauses).
Where transfers are made within the Ferrer&Ojeda Group, they are covered by agreements based on the EU standard contractual clauses.
If you wish to obtain more information on whether your information will be communicated to recipients abroad, you may contact Ferrer&Ojeda as indicated in the “Ferrer&Ojeda Contact Details” section.
9. Retention period of personal data
Ferrer&Ojeda processes your personal data for as long as the intermediary contractual relationship remains in force.
Once your contractual relationship has expired, we will retain your data for the periods necessary to comply with applicable legal and contractual obligations. The data will be deleted and subsequently blocked when it is no longer necessary for the purpose for which it was collected. From that moment on, it will remain blocked and will only be made available to Public Authorities, Courts, and Tribunals that may require it, for the limitation periods applicable to any actions that may arise from the formalised contract.
10. Personal data retention period
Ferrer&Ojeda is strongly committed to the security, privacy, and integrity of the Personal Data it processes belonging to its Data Subjects. For this reason, Ferrer&Ojeda implements and applies the highest security standards to ensure that, within Ferrer&Ojeda, Personal Data is processed in a fully secure manner. In particular, Ferrer&Ojeda uses organisational, technical, and administrative measures which, taking into account the state of the art and the nature of the relevant Personal Data, guarantee full protection of its Data Subjects’ Personal Data. These measures also include those designed to address any suspected personal data security breach. For more information about the security measures implemented by Ferrer&Ojeda, you may visit our Security Policy at https://www.ferrerojeda.com
11. Rights of Data Subjects
In accordance with the provisions of data protection regulations, the data subject has the following rights:
a. Right of Access: Any data subject may request Ferrer&Ojeda to confirm whether it is processing their personal data; to provide a copy of such personal data; and to provide any other information about their personal data (what data it holds, what it is used for, to whom it is disclosed, whether it is transferred to third parties and their location, how it is protected, how long it is retained, what rights the data subject has in relation to it, how to lodge a complaint, and where the data was obtained from).
b. Right to Rectification: Data Subjects may request that Ferrer&Ojeda correct and update inaccurate Personal Data, or complete any incomplete personal data.
c. Right to Erasure of Personal Data: Data Subjects may request that Ferrer&Ojeda delete their personal data when: (i) the personal data is no longer necessary for the purposes for which it was collected, (ii) the data subject withdraws their consent (where processing is based on consent), (iii) the data subject exercises their right to object (as defined below), (iv) the personal data has been unlawfully processed, and (v) Ferrer&Ojeda must comply with a legal obligation.
d. Right to Object: Data Subjects may object to any processing of their personal data that is based on the “legitimate interests” of Ferrer&Ojeda, where they consider that specific circumstances exist that may unreasonably affect their fundamental rights and freedoms.
It is important to note that where Data Subjects exercise their right to object with respect to Personal Data necessary to satisfy the legitimate interests of Ferrer&Ojeda (as well as to comply with its legal and contractual obligations), Ferrer&Ojeda may be unable to provide its services to such Data Subjects.
In any case, Ferrer&Ojeda may continue processing if it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.
e. Right to Object to Commercial Communications: Data Subjects have the right to object to the use of their personal data for the purpose of sending commercial communications.
f. Right to Restriction of Processing: Any Data Subject may request that Ferrer&Ojeda restrict the processing of their personal data (i.e., store it but not use it) where one of the following conditions applies: (i) the accuracy of the data is contested, allowing Ferrer&Ojeda to verify its accuracy; (ii) the processing is unlawful, but the data subject does not wish the personal data to be erased; (iii) the data is no longer necessary for the purposes for which it was collected, but is required for the establishment, exercise or defense of claims; (iv) the data subject has exercised the right to object, while Ferrer&Ojeda verifies whether its legitimate grounds override those of the data subject.
Ferrer&Ojeda may continue using personal data after a request for restriction (i) where it has the data subject’s consent; (ii) for the establishment, exercise or defense of legal claims; or (iii) to protect the rights of another natural or legal person.
g. Right to Data Portability: Data Subjects have the right to receive from Ferrer&Ojeda their personal data being processed in a structured, commonly used and machine-readable format. They also have the right to request that Ferrer&Ojeda transfer their personal data to another entity.
h. Right Not to be Subject to Automated Individual Decisions: The data subject has the right not to be subject to a decision based solely on automated processing of their data, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless the decision (i) is necessary for entering into, or performance of, a contract between the data subject and the controller; (ii) is authorized by applicable law and provides appropriate safeguards for the rights and freedoms and legitimate interests of the data subject; or (iii) is based on the explicit consent of the data subject.
With regard to the use of artificial intelligence tools, Ferrer&Ojeda informs that data subjects will not be subject to automated individual decisions with legal effects or similarly significant impact. The use of such tools is limited to internal segmentation tasks to improve commercial offerings. Nevertheless, the data subject may at any time exercise their right to object to this type of processing.
i. Right to Withdraw Consent: Any Data Subject may withdraw their consent in relation to any processing of their personal data based on previously given consent. Consent may be withdrawn by contacting Ferrer&Ojeda using the contact details provided in the “Ferrer&Ojeda Contact Details” section of this document.
j. Right to Lodge a Complaint with a Supervisory Authority: Data Subjects have the right to lodge a complaint with the Supervisory Authority, the details of which are provided in the section of this Policy entitled “Supervisory Authority Contact Details”.
Prior to lodging a complaint with the data protection authority, you may contact the Data Protection Officer designated by Ferrer&Ojeda by email at dpo@ferrerojeda.com, or by post at the address provided in the “Ferrer&Ojeda Contact Details” section.
You may exercise your data protection rights by sending a written communication to the addresses indicated in the “Ferrer&Ojeda Contact Details” section.
12. Changes to this privacy policy
Any changes that Ferrer&Ojeda may make in the future to this Privacy Policy will be published on its website. Please check regularly to see updates or changes to our Privacy Policy. In particular, Ferrer&Ojeda may update this Privacy Policy to reflect the incorporation of new technologies or data analysis tools, always ensuring transparency and respect for the rights of data subjects.
13. Ferrer&Ojeda Contact Information
If you have any questions about the practices described in this Privacy Policy, wish to submit a complaint or claim, raise a query to the Data Protection Officer or exercise your data protection rights, you may contact Ferrer&Ojeda by post or email at the following addresses:
Calle Tamarit 155, 08015 Barcelona
dpo@ferrerojeda.com
14. Control authority contact details
If you wish to contact the national Supervisory Authority regarding any of the practices described in this Privacy Policy, you may contact the Spanish Data Protection Agency, whose contact details are as follows:
Spanish Data Protection Agency:
Postal address: Calle Jorge Juan 6, 28001 Madrid
Telephone: (+34) 901 100 099 / 912 663 517
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