Privacy Policy
1. Introduction
This Privacy Policy contains information on the data processing 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 can 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 (a list of the companies that make up the Ferrer&Ojeda Group can be found in the Legal Notice at www.ferrerojeda.com). Any reference to “we”, “us”, “our”, or “Ferrer&Ojeda” in this privacy policy is a reference to the companies of the Ferrer&Ojeda Group.
The Ferrer&Ojeda entity responsible for processing your data for the purposes of data protection regulations will be the Ferrer&Ojeda entity that originally collects information from or about you. These entities may provide other privacy policies of their own when personal information is first collected by that Ferrer&Ojeda entity, for example, when you or the company you work for hires us to provide a service.
Ferrer&Ojeda also provides services to its customers as a processor. Where this is the case, we will process your personal information in accordance with our legal obligations and contractual commitments to our customers, who in these cases will remain the primary data controller.
3. What personal data does Ferrer&Ojeda process?
Ferrer&Ojeda only processes personal data or 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 customers or prospective customers (hereinafter, “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 the Interested Parties (hereinafter, “Personal Data”) are the following:
Identification and contact data, such as name and surname, age, gender, date of birth, nationality, marital status, ID card/passport, email, postal address, telephone number.
Information on their current compensation, pensions and benefits.
Bank details.
Health details
Details on insurance contracts and related claims.
Information on complaints and claims related to Ferrer&Ojeda’s activities.
Voice details for call recording.
Data from browsing the Ferrer&Ojeda website or from the use of Ferrer&Ojeda applications.
4. Origin of personal data
The origin of the Personal Data accessed by Ferrer&Ojeda may be the Data Subject or third parties. In particular, Ferrer&Ojeda collects Personal Data in the following ways:
a. From the data subject him/herself, when a person requests services from Ferrer&Ojeda he/she is asked for the information necessary to respond to his/her request. When a visitor provides personal information, it is used for the purposes for which it was provided, as indicated at the point of collection or as is evident in the context of the collection. For example, providing an insurance quote, creating a profile on a website or application, submitting a complaint or inquiry, attending a Ferrer&Ojeda event, or applying for a position at Ferrer&Ojeda.
The data subject must provide personal information that is necessary to fulfill our obligations in connection with the services we provide to you, including legal and regulatory obligations. When you do not provide the necessary information requested by Ferrer&Ojeda, it may not be possible to provide you with the services.
When the data subject provides personal information to Ferrer&Ojeda about third parties (for example, information about your spouse, civil partner, children, dependents or emergency contacts), where applicable, you must provide these persons in advance with timely information about the processing of their data by Ferrer&Ojeda.
In the event of any changes to 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 us for the proper provision of services.
The data subject must provide personal information that is necessary to fulfill our obligations in connection with the services we provide to you, including legal and regulatory obligations. When you do not provide the necessary information requested by Ferrer&Ojeda, it may not be possible to provide you with the services.
When the data subject provides personal information to Ferrer&Ojeda about third parties (for example, information about your spouse, civil partner, children, dependents or emergency contacts), where applicable, you must provide these persons in advance with timely information about the processing of their data by Ferrer&Ojeda.
In the event of any changes to 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 us for the proper provision of services.
b. Call recording: telephone calls you make to Ferrer&Ojeda may be recorded for quality control and training purposes for Ferrer&Ojeda’s customer service employees. In addition, some phone conversations will be recorded for the purpose of verification and recording of requests, transactions and other agreements with the customer. Prior notice shall be provided if the call is recorded.
Recorded conversations and any personal information on the recording will be stored in such a way that they are not accessible by unauthorized persons. Ferrer&Ojeda has adopted technical and organizational measures to prevent the manipulation of the recordings and to guarantee the security of the information.
Recorded conversations and any personal information on the recording will be stored in such a way that they are not accessible by unauthorized persons. Ferrer&Ojeda has adopted technical and organizational measures to prevent the manipulation of the recordings and to guarantee the security of the information.
c. Ferrer&Ojeda may also collect personal information about you from other third parties, such as your employer, insurers, policyholders, reinsurers, medical professionals, government agencies, claimants, and other providers of professional advisory services. This information may be obtained prior to and/or during the provision of services.
Ferrer&Ojeda can provide you with more information about the data processing performed for each of its services, along with the purpose and specific legal basis for collecting the information, in privacy notices specific to the services in question.
Ferrer&Ojeda can provide you with more information about the data processing performed for each of its services, along with the purpose and specific legal basis for collecting the information, in privacy notices specific to the services in question.
d. Social networks: the interested party may interact with Ferrer&Ojeda through social network services or through features such as plugins or applications on Ferrer&Ojeda’s websites that integrate with social networks. In these cases, depending on the social network and user profile settings, Ferrer&Ojeda may have access to certain information from your social network account (e.g., name, email address, photo, gender, birthday, posts or “likes” you send).
If you post information when you interact with websites through social networks, plugins or other applications, depending on your privacy settings, this information may be made public on the Internet. You can control the information you share through the privacy settings available on some social networking sites.
If you post information when you interact with websites through social networks, plugins or other applications, depending on your privacy settings, this information may be made public on the Internet. You can control the information you share through the privacy settings available on some social networking sites.
e. Mobile Devices: If you access our websites on your cell phone or mobile device, Ferrer&Ojeda may collect your unique device identifier and the IP address of your mobile device, as well as information about your device’s operating system, mobile carrier and location information.
5. Purposes of processing
Ferrer&Ojeda processes Personal Data in accordance with the purposes described below:
a. To fulfill the contractual obligations in relation to the insurance policies brokered by Ferrer&Ojeda on the basis of which the Data Subject may be the beneficiary, insured person 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. To carry out analysis, studies, evaluation, marketing, promotion, information and offers on products and services marketed by Ferrer&Ojeda, specifically insurance, insurance mediation and consulting products or services;
c. In relation to the navigation data obtained through the Ferrer&Ojeda website, by means of “Cookies” or similar, Ferrer&Ojeda proceeds to its processing to improve the experience of the users of its website; for example, the last search criteria of users are analyzed to present them with offers of mediation services that we believe may be of interest to them;
For more information, you can consult our complete Cookies Policy at http://www.ferrerojeda.com/ under the section at the bottom of the page.
d. Sending commercial communications, in relation to the products and services marketed by Ferrer&Ojeda (especially in insurance, mediation and consulting) not only by mail, telephone or fax, but also by SMS, instant messaging applications, social networks, email, or any other electronic or telematic means available at any time, in the terms provided in Article 21 of Law 34/2002, of Information Society Services and other applicable regulations;
Ferrer&Ojeda reminds you that, at all times, the Data Subject has the right not to receive information and advertising, particularly by electronic and/or telematic means, or by mail. Therefore, if the Customer would like to unsubscribe and stop receiving commercial communications and advertising by electronic, telematic or any other available means, he/she may do so by sending an e-mail to the following e-mail address: dpo@ferrerojeda.com, indicating his/her identification data and expressing his/her opposition to receiving commercial communications by electronic means
Ferrer&Ojeda reminds you that, at all times, the Data Subject has the right not to receive information and advertising, particularly by electronic and/or telematic means, or by mail. Therefore, if the Customer would like to unsubscribe and stop receiving commercial communications and advertising by electronic, telematic or any other available means, he/she may do so by sending an e-mail to the following e-mail address: dpo@ferrerojeda.com, indicating his/her identification data and expressing his/her opposition to receiving commercial communications by electronic means
e. Comply with the legal and regulatory obligations required of Ferrer&Ojeda.
f. Carry out processing that is necessary for the formulation, exercise or defense of claims, and the satisfaction of other legitimate interests of Ferrer&Ojeda, but ensuring that the rights and freedoms of the Data Subjects are not affected;
g. Collect information about customers and their insurance policies, including, for example, names, insurance lines, effective dates, as well as information about insurance companies that provide coverage to its customers or that provide quotes for Ferrer&Ojeda’s customers. This information is hosted in one or several databases of Ferrer&Ojeda and its group of companies. In this case and in relation to the aforementioned information, Ferrer&Ojeda may use or disclose such information to companies belonging to the Ferrer&Ojeda Group.
6. Legal basis for processing
All processing of personal data by Ferrer&Ojeda is justified by a “lawful basis”. In most cases, the processing will be justified on one of the following legal bases:
a. Execution of the contract concluded with the data subject or implementation of precontractual measures: when Ferrer&Ojeda offers its services or enters into a contract with the Data Subject to provide the services, it collects and uses personal data necessary to carry out the provision of the services, process your acceptance of the offer and fulfill the obligations assumed in the contract with you.
In this regard, the processing of certain categories of personal data, such as information relating to your health, may be necessary for the purposes of entering into and managing certain insurance contracts, for the purpose of advising, arranging, underwriting or administering insurance, assessing and administering claims or exercising our rights or obligations in relation to the services.
In this regard, the processing of certain categories of personal data, such as information relating to your health, may be necessary for the purposes of entering into and managing certain insurance contracts, for the purpose of advising, arranging, underwriting or administering insurance, assessing and administering claims or exercising our rights or obligations in relation to the services.
b. Compliance with legal and regulatory obligations: the collection and use of certain personal information is necessary to comply with legal and regulatory obligations, such as accounting or tax obligations. In particular, the brokerage companies of the Ferrer&Ojeda Group are registered in the Registry of Insurance and Reinsurance Distributors of the Directorate General for Insurance and Pension Funds, as can be verified on the website of that body: http://www.dgsfp.mineco.es/es/Distribuidores/PUI/Paginas/pui.aspx and must provide these services in accordance with the relevant regulations.
c. Satisfaction of legitimate interests of Ferrer&Ojeda: the collection and use of some categories of personal data is necessary for Ferrer&Ojeda to pursue legitimate business interests, e.g. for fraud prevention, for certain operations of its business, to offer products and services that may be of interest to the customer or user, or to conduct market research for the improvement of its products and services in general. Where Ferrer&Ojeda relies on this legal basis for the processing of your personal information, it will take appropriate steps to ensure that the processing does not infringe the rights and freedoms conferred on the data subject by the applicable data protection legislation.
d. Consent of the data subject: when necessary, Ferrer&Ojeda will request the consent of the data subject to collect and use personal information. Such consent may be necessary for various purposes in order to assess the risks associated with an insurance policy. Ferrer&Ojeda may share this information with other insurance market participants and third parties as necessary to provide, administer and manage the services it offers to you, such as insurers and policyholders, reinsurers, brokers and research agencies.
When Ferrer&Ojeda requests your consent to collect and use the information, you are not obliged to give your consent and, in any case, you may choose to withdraw your consent later at any time. However, if you refuse to provide information that Ferrer&Ojeda may require to provide the services, it may not be possible to provide you the services.
When you agree to receive services from Ferrer&Ojeda, your information may or may need to be disclosed to the insurance company with which your insurance policy is taken out. You should consult the relevant insurance company’s privacy notice for more information about their data protection practices.
When Ferrer&Ojeda requests your consent to collect and use the information, you are not obliged to give your consent and, in any case, you may choose to withdraw your consent later at any time. However, if you refuse to provide information that Ferrer&Ojeda may require to provide the services, it may not be possible to provide you the services.
When you agree to receive services from Ferrer&Ojeda, your information may or may need to be disclosed to the insurance company with which your insurance policy is taken out. You should consult the relevant insurance company’s privacy notice for more information about their data protection practices.
7. Recipients of personal data
In order to fulfill the purposes set out above, Ferrer&Ojeda may share Stakeholders’ personal information with third parties. In particular, Ferrer&Ojeda is a global organization with transnational business processes, management structures and technical systems, so it is possible that, based on the identified purposes, Ferrer&Ojeda may share Personal Data with third parties located in countries outside the European Economic Area that may not offer an equivalent level of privacy protection, such as the United States of America. Thus, Ferrer&Ojeda may share your Personal Data with:
a. Companies of the Ferrer&Ojeda group (within the meaning of Article 42 of the Code of Commerce), for the aforementioned purposes.
b. Insurance companies with which the Interested Party decides to take out insurance policies mediated by Ferrer&Ojeda, as well as medical offices and centers, appraisers and reinsurers in order to assess and delimit the insured risk, as well as to initiate and maintain the contractual insurance relationship and process the claims covered by the insurance policies.
c. External collaborators and service providers contracted by Ferrer&Ojeda to perform functions related to its business. This category may include banks, insurance companies, other insurance brokers, suppliers that provide services to Ferrer&Ojeda including computer maintenance services, e-mail, hosting, housing;
d. Judicial Authorities and other relevant public and regulatory bodies to comply with applicable laws and regulatory monitoring and reporting obligations, to respond to requests from public agencies or administration and to cooperate with law enforcement or for other lawful reasons;
e. Legal or technical advisors, when necessary to exercise or defend legal and insurance claims, or other claims of a similar nature;
8. International transfers
Ferrer&Ojeda is an organization that operates worldwide and globally and may transfer certain personal information about you to other countries to be processed for the purposes described in this Policy. In particular, Ferrer&Ojeda may make such transfers to provide, administer and manage the services provided to you and to improve the efficiency of business operations. Ferrer&Ojeda will take appropriate steps to ensure that such transfers comply with all applicable data protection laws and regulations and provide adequate protection for the rights and freedoms conferred on individuals under such laws.
In the case of transferring personal data to countries outside the European Economic Area for the fulfillment of the legitimate purposes described in this Privacy Policy, this may be done both to countries that the European Commission (the “EC”) and national data protection authorities consider to offer adequate data protection safeguards, as well as to some countries that are not subject to an adequacy decision. When Ferrer&Ojeda transfers personal data to countries that are not subject to an adequacy decision, such as, for example, the United States, it will implement appropriate safeguards. When transfers are made within the Ferrer&Ojeda group, they are covered by agreements based on EC standard contractual clauses. If transfers are outside Ferrer&Ojeda or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information, either through certification schemes, or EC standard contractual clauses;
If you wish to obtain more information about whether your information will be communicated to recipients abroad, you can contact Ferrer&Ojeda as indicated below in the section “Ferrer&Ojeda contact details”.
9. Retention period of personal data
Ferrer&Ojeda does not retain any personal data about Data Subjects for longer than is necessary to fulfill the purposes for which such personal data is processed, to comply with its legal and regulatory obligations, and to respond to possible claims or legal actions.
10. Personal data security
Ferrer&Ojeda is highly committed to the security, privacy and integrity of the Personal Data it processes from its Stakeholders. For this reason, Ferrer&Ojeda implements and applies the highest security standards to ensure that within Ferrer&Ojeda, Personal Data are processed in a fully secure manner. In particular, Ferrer&Ojeda uses the organizational, technical and administrative measures that, according to the state of the art and the nature of the Personal Data, guarantee a full protection of the Personal Data of its Data Subjects. These also include measures to address any suspected breach of security in Personal Data. For more information about security measures implemented by Ferrer&Ojeda, please visit our Security Policy at https://www.ferrerojeda.com.
11. Rights of Data Subjects
In accordance with the provisions of the regulations on data protection, Data Subjects have 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 them with a copy of such personal data; and to provide them with any other information about their personal data (what data it holds, what it uses them for, to whom it communicates them, whether or not it transfers them to third parties and their location, how it protects them, for how long it keeps them, what rights they have as a Data Subject in relation to them, how they can file a complaint, where their data has been obtained from), provided that this information has not already been provided to them in this Privacy Policy
b. Right of Rectification: Data Subjects may request that Ferrer&Ojeda correct and update their inaccurate Personal Data, or complete Personal Data that is incomplete
c. Right to erasure of personal data: Data Subjects may request Ferrer&Ojeda to erase their personal data when: (i) the personal data are no longer necessary in relation to the purposes for which they were collected; (ii) Data Subjects withdraw their consent (if the data processing is based on consent); (iii) Data Subjects exercise their right to object (as defined below); (iv) the personal data have been unlawfully processed; and (v) Ferrer&Ojeda has to comply with a legal obligation.
d. Right of opposition: Data Subjects may object to any processing of their Personal Data that has as its legal basis the “legitimate interests” of Ferrer&Ojeda, if it considers that there are specific circumstances that could unreasonably affect their fundamental rights and freedoms.
It is important to be aware that in cases where Stakeholders exercise their right to object to those Personal Data that are necessary to satisfy the legitimate interests of Ferrer&Ojeda (as well as to comply with their legal and contractual obligations) Ferrer&Ojeda may be unable to provide its services to such Stakeholders;
In any case, Ferrer&Ojeda may continue the processing if they can demonstrate compelling legitimate grounds for the processing that override the interests, rights and freedoms of the data subject, or for the formulation, exercise or defense of claims.
It is important to be aware that in cases where Stakeholders exercise their right to object to those Personal Data that are necessary to satisfy the legitimate interests of Ferrer&Ojeda (as well as to comply with their legal and contractual obligations) Ferrer&Ojeda may be unable to provide its services to such Stakeholders;
In any case, Ferrer&Ojeda may continue the processing if they can demonstrate compelling legitimate grounds for the processing that override the interests, rights and freedoms of the data subject, or for the formulation, exercise or defense of claims.
e. Right to oppose the sending of commercial communications: Interested Parties have the right to oppose the use of their personal data for the sending of commercial communications;
f. Right to limitation of processing: Data Subjects may request Ferrer&Ojeda to limit its processing of their personal data (i.e. to retain but not use it) when any of the following conditions are met: (i) its accuracy is contested, to allow Ferrer&Ojeda to verify its accuracy; (ii) the processing is unlawful, but the Data Subject does not wish the personal data to be deleted; (iii) the data is no longer necessary for the purposes for which it was collected, but is necessary for the filing, exercise or defense claims; (iv) Data Subjects have exercised the right to object, while Ferrer&Ojeda verifies whether legitimate grounds override those of the Data Subject.
Ferrer&Ojeda may continue to use your personal data after a request for limitation (i) if you have given your consent; (ii) for the filing, exercise or defense of legal claims; or (iii) to protect the rights of another natural or legal person;
Ferrer&Ojeda may continue to use your personal data after a request for limitation (i) if you have given your consent; (ii) for the filing, exercise or defense of legal claims; or (iii) to protect the rights of another natural or legal person;
g. Right to data portability: in certain circumstances, Data Subjects have the right to receive from Ferrer&Ojeda their personal data being processed in a structured, commonly used, 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: Data Subjects have 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 the conclusion or performance of a contract between the Data Subject and the controller; (ii) is authorized by applicable law and which also provides for appropriate measures to safeguard the rights and freedoms and legitimate interests of the Data Subject; or (iii) is based on the Data Subject’s explicit consent.
i. Right to withdraw consent. Data Subjects may withdraw their consent in relation to any processing of their personal data based on previously granted consent. Consent may be withdrawn by contacting Ferrer&Ojeda using the details provided in the “Ferrer&Ojeda contact details” section of this document.
j. Right to complain to the Control Authority: Data Subjects have the right to file a complaint with the Control Authority, whose details are provided in the section of this Policy: “Data Control Authority”.
Prior to submitting a complaint or claim to the data protection authority, you can contact the Data Protection Officer designated by Ferrer&Ojeda, by e-mail at the address dpo@ferrerojeda.com, or by post at the address provided in the section “Ferrer&Ojeda Contact Details”.
Prior to submitting a complaint or claim to the data protection authority, you can contact the Data Protection Officer designated by Ferrer&Ojeda, by e-mail at the address dpo@ferrerojeda.com, or by post at the address provided in the section “Ferrer&Ojeda Contact Details”.
You may exercise your data protection rights by sending a written communication to the addresses indicated in the section “Ferrer&Ojeda Contact Details”
12. Changes to this privacy policy
Any future changes Ferrer&Ojeda may make to this privacy policy will be posted on its website. Please check back frequently for updates or changes to our privacy policy.
13. Ferrer&Ojeda Contact Information
If you have any questions about the practices described in this Privacy Policy or wish to exercise your data protection rights, you may contact Ferrer&Ojeda by mail or email at the following addresses:
Calle Tamarit 155, 08015 Barcelona
dpo@ferrerojeda.com
However, before Ferrer&Ojeda can provide you with information or facilitate the exercise of your rights, we may need to perform various tasks to verify your identity or other details necessary to be able to respond appropriately to your request. We will contact you within 30 days from the date of your request.
If you wish to submit a complaint or claim or make any other inquiry to the Data Protection Officer designated by Ferrer&Ojeda, you may do so at the following addresses:
Calle Tamarit 155, 08015 Barcelona
dpo@ferrerojeda.com
Calle Tamarit 155, 08015 Barcelona
dpo@ferrerojeda.com
However, before Ferrer&Ojeda can provide you with information or facilitate the exercise of your rights, we may need to perform various tasks to verify your identity or other details necessary to be able to respond appropriately to your request. We will contact you within 30 days from the date of your request.
If you wish to submit a complaint or claim or make any other inquiry to the Data Protection Officer designated by Ferrer&Ojeda, you may do so 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
Phone: (+34) 901 100 099 / 912 663 517
Spanish Data Protection Agency:
Postal address: Calle Jorge Juan 6, 28001 Madrid
Phone: (+34) 901 100 099 / 912 663 517
How can we help you?
Contact us or find the nearest office to your location.