Please read the following carefully to understand our use of the personal data collected via this website.

This Data Protection Notice is intended to ensure that you are aware of what personal data Intesa Sanpaolo Life dac (Intesa, we, us, our), a company under Irish law authorised for insurance activity and regulated by the Central Bank of Ireland, Irish company registry number No. 284248, with registered office at 1st Floor, International House, 3, Harbourmaster Place IFSC - Dublin, D01 K8F1, Ireland collects from you via this website, and how we use that data as a data controller.

 

Queries or Complaints

If you are unhappy with the way we have handled your personal information and wish to complain or if you simply want further information about the way your personal data will be used, please contact us at:

 

Data Protection Officer
Intesa Sanpaolo Life dac
1st Floor, International House
3 Harbourmaster Place, IFSC
Dublin D01 K8F1
Ireland

or

E-mail: dpo@intesasanpaololife.ie

 

Please read the following carefully to understand our use of your personal data.

 

Scope

This Data Protection Notice (together with our Cookie Policy  applies to any information about you collected, maintained, transmitted, stored, retained, or otherwise used (i.e. processed) by Intesa through our website (www.intesasanpaololife.ie), for example when you use our online feedback/queries facility in the Contact Us section of the Website.

This Data Protection Notice sets out the basis on which we gather, use, process and disclose any of the personal data we collect from you. We will use your personal data only for the purposes and in the manner set forth below which describes the steps we take to ensure our processing of your personal data is in compliance with the General Data Protection Regulation ((EU) 2016/679) (GDPR) and any implementing legislation (Data Protection Legislation).

 

Changes to this Data Protection Notice

This Data Protection Notice was updated in May 2018. Like any business, ours will change over time and so will the way we use and protect your personal data. So we may need to make changes to this Data Protection Notice although this will not reduce your rights or the level of protection we apply to your personal data. The most up to date Data Protection Notice will always be published on our Website.

 

What is Personal Data?

“Personal Data” is defined as any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

 

What Personal Data Do We Collect via this Website?

We collect and hold some or all of the following types of personal data in relation to you:

• contact/identifying details including your name, address, email address and telephone number;

• the Internet Protocol (IP) addresses or domain names of computers used by users who connect to our website;

• the Uniform Resource Identifier (URI) record of the requested resources;

• the time of the request;

• the method employed in submitting the request to the server;

• the size of the file obtained in reply;

• the code number indicating the status of the reply given by the server (successful, error, etc.) and other parameters relating to the user's operating system and computer environment;

• records of your email communications with us;

• information regarding your Internet usage such as your preferences and interests, which we may obtain from third parties such as Google and through the use of cookies.

 

Cookies

We also obtain information about your general internet usage by using tracking technologies such as cookies on our Website.

 

What are IP Addresses?

When your web browser or e-mail application requests a web page or e-mail from another computer on the Internet, it automatically gives that computer the address where it should send the information. This is called your computer's "IP address." (IP stands for "Internet protocol.") For most users accessing the Internet from a dial-up Internet service provider (ISP), the IP address will be different every time you log on. The computer systems and software programs being used while our website is being accessed, acquire for the sole duration of the connection, your IP address.

 

We receive IP addresses from all users because this information is automatically reported by your browser each time you view a web page. We do not store IP addresses in a central database. They are just recorded in log files so they are not associated with an account.

 

Purpose and Legal Basis for Processing

We will hold, process and disclose personal data provided by you for the following purposes:

Category of Personal Data	Purpose for Processing	Legal Basis for Processing
Name, address, email address and telephone number. Information in relation to your complaints you have submitted. Records of your email communications with us. Information collected via cookies.	Investigate and respond to queries/complaints from personnel, customers, business partners, and regulators; Ensure that content on our Website is presented in the most effective manner for you and for your computer; To respond to your requests for information, feedback and other communication or correspondence you may submit to us; To measure your interest in and improve our products, services and website; and To notify you about changes to the Website, our services, products or policies;	This use of your data is necessary for our legitimate interest in managing our business including administrative, customer service or adverse events experienced in relation to our products, provided our legitimate interests are not overridden by your interest.   PLEASE NOTE THAT YOU HAVE A RIGHT TO OBJECT TO PROCESSING OF YOUR PERSONAL DATA WHERE THAT PROCESSING IS CARRIED ON FOR OUR LEGITIMATE INTEREST.
As Above	Comply with our regulatory, legal and industry requirements; Exercising our right to defend, respond or conduct legal proceedings or investigate product complaints.	This use of your data is necessary in order for us to comply with any legal or regulatory obligations.

Category of Personal Data
Name, address, email address and telephone number. Information in relation to your complaints you have submitted. Records of your email communications with us. Information collected via cookies.
Purpose for Processing
Investigate and respond to queries/complaints from personnel, customers, business partners, and regulators; Ensure that content on our Website is presented in the most effective manner for you and for your computer; To respond to your requests for information, feedback and other communication or correspondence you may submit to us; To measure your interest in and improve our products, services and website; and To notify you about changes to the Website, our services, products or policies;
Legal Basis for Processing
This use of your data is necessary for our legitimate interest in managing our business including administrative, customer service or adverse events experienced in relation to our products, provided our legitimate interests are not overridden by your interest.   PLEASE NOTE THAT YOU HAVE A RIGHT TO OBJECT TO PROCESSING OF YOUR PERSONAL DATA WHERE THAT PROCESSING IS CARRIED ON FOR OUR LEGITIMATE INTEREST.

 

Category of Personal Data
Name, address, email address and telephone number. Information in relation to your complaints you have submitted. Records of your email communications with us. Information collected via cookies.
Purpose for Processing
Comply with our regulatory, legal and industry requirements; Exercising our right to defend, respond or conduct legal proceedings or investigate product complaints.
Legal Basis for Processing
This use of your data is necessary in order for us to comply with any legal or regulatory obligations.

The provision of your personal data is not a statutory or contractual requirement and you may refuse to disclose same. However, please note that if you do not provide us with your personal data we will not be able to process your request.

 

Recipients of Your Personal Data

Typically, we disclose your personal data to members of our corporate group including, without limitation, for the following reasons: in order to, run global processes, carry out group wide reporting or take decisions about the business, the Website and/or our products.

It will also be necessary from time to time for us to disclose your personal data to third parties or agents, including without limitation to the following:

• Contractors, service providers and other third parties we use to support our business and carry our specific services on our behalf;

• Courts, governmental departments and/or agencies and regulatory bodies to whom we are obliged or required to disclose information;

• Legal practitioners.

We will inform you in advance if we intend to further process or disclose your personal data for a purpose other than the purposes set out in this Data Protection Notice. We take all reasonable steps, as required by law, to ensure the safety, privacy and integrity of such data and information and, where appropriate, enter into contracts with such third parties to protect the privacy and integrity of such data and any information supplied.

 

Transfer of Personal Data to a third country or an international organisation outside the European Union

Without prejudice to the provisions of specific legislation, your Personal Data is processed by the company within the territory of the European Union and are not disclosed.

If necessary, for technical or operational reasons, the company reserves the right to transfer your personal information to countries outside the European Union for which there are decisions of ‘adequacy’ of the European Commission, which is based on adequate guarantees or specific waivers provided for by the Regulation.

Please contact us if you wish to obtain information concerning such safeguards at dpo@intesasanpaololife.ie.

 

Data Retention

We will store your personal data only for as long as necessary for the purposes of providing access to our Website and related services to you; as required by law, and for the exercise or defense of any legal claims.

We will keep your information for the longer of the period required in order to meet our legal or regulatory responsibilities, and the period envisaged within our records retention policy (see for example the retention period in our Cookie Policy).

 

Your Data Rights

As a data subject, you may exercise toward the data controller at any time the rights provided for in the Regulations listed below, by sending a request in writing to the e-mail address dpo@intesasanpaololife.ie or by postal mail to Intesa Sanpaolo Life dac, 1st Floor, International House, 3 Harbourmaster Place, IFSC - Dublin, K8F1 - D01, Ireland.

In the same way, you may revoke at any time the consent expressed regarding personal data processing for one or more specific purposes indicated in this Statement.

Any communication and actions taken by the company against the exercise of the rights listed below, will be made free of charge. However, if your requests are manifestly unfounded or excessive, especially for their repetitive nature, the company may charge you a fee, taking into account the administrative costs incurred, or refuse to comply with your requests.

The Company shall respond to requests of the data subjects regarding the rights mentioned in this Section as soon as possible, as soon as it has received the pertinent request and, in any case, within one month of receiving it. This term may be extended by two months, if necessary, considering the complexity and number of requests.

 

1. Right of access

You may obtain confirmation from the Company of whether or not your Personal Data is being processed and, if so, obtain access to your Personal Data and information provided under Article 15 of the Regulation, including, but not limited to: the purpose of the processing and the categories of Personal Data processed.
When Personal Data is transferred to a third country or to an international organisation, you have the right to be informed of the existence of adequate safeguards for the transfer.

If required, the company may provide a copy of the Personal Data regarding you being processed. For any additional copies the company may charge you a reasonable cost-based fee. If the request is submitted by electronic means, and unless indicated otherwise, the information will be provided by the company in a commonly used electronic format.

 

2. Right to Rectification

You may obtain from the Company the rectification of any inaccurate Personal Data we hold about you, and you also have the right to have incomplete data completed, including by means of supplemental Statement.

 

3. Right to Erasure

You can obtain the cancellation of your Personal Data on one of the grounds outlined in Article 17 of the Regulation, including, without limitation, when Personal Data is no longer needed for the purposes for which it was collected or otherwise processed or when the consent on which your Personal Data was processed is withdrawn, and there is no other legal basis for processing.

Please note that the company cannot proceed with the cancellation of your Personal Data if its processing is necessary, for example, to fulfil a legal requirement, for reasons of public interest, or to establish, exercise or defend a legal claim.

 

4. Right to Restriction of Processing

You have the right to ask us to restric the processing of your Personal Data when using one of the hypotheses provided for by Article 18 of the Regulation, including, for example: in the face of a dispute about the accuracy of your Personal Data being processed or if your personal details are necessary to establish, exercise or defend a legal claim, although the company has no more need for the processing.

 

5. Right to data portability

If your Personal Data is processed based on consent or is necessary for the execution of a contract or contractual measures and processing is done by automated means, you can, pursuant to Article 20 of the Regulation:

• request to receive the Personal Data you provide in a structured format, commonly used and readable by automated device (example: computers and/or tablet);

• transmit your Personal Data received by you to another processor or controller without hindrance from the Company.

You can also request that your Personal Data is transmitted by the company directly to another processor or controller, if technically feasible for the company. In this case, you are responsible for providing us with exact details of the new data processor to which you wish to transfer your Personal Data, providing us with a written authorisation.

 

6. Right to Object

You may object at any time to the processing of your personal data when the processing is carried out for the execution of a task in the public interest or in the pursuit of our legitimate interest (including profiling).

If you decide to exercise your right of objection described herein, the company will refrain from further processing of your Personal Data, unless there are legitimate grounds for processing (prevailing reasons regarding the interests, rights and freedoms of the person concerned), or processing is necessary for the establishment, exercise or defense in a court of law.

If, however, your Personal Data is processed for the purpose of marketing, you have the right to object at any time to that processing, including profiling, to the extent that it is connected to such marketing.

 

7. Right to submit a complaint to the competent data protection authority

Notwithstanding your right to take any other administrative or judicial action if you believe that your Personal Data by the data controller is processed in violation of the rules and/or the applicable legislation, you have the right under Article 77 of the Regulation to lodge a complaint the competent Authority, in particular in the Member State of your residence, place of work or place of an alleged infringement.

 

Safeguarding your Personal Data

The security and confidentiality of your personal data is extremely important to us. As no data transmission over the internet can be guaranteed as 100% secure, we cannot ensure or warrant the security of any information that you transmit to us and you transfer the personal data at your own risk. We endeavor to use and keep under review appropriate technical and organisational measures (including staff training and awareness) in order to protect against unauthorised or unlawful processing of your personal data, including unauthorised destruction, alteration or disclosure or access.

 

Links to other Websites

Our Website may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those websites.

This Information notice tells you about cookies in general, how we use cookies, why we use them, and how this allows us to improve our service to you. For changing your preferences or withdrawn the consent you expressed with regard to cookies, please click here.

What are Cookies?

Cookies are small text files which are downloaded onto the user's computer or device when visiting a website. They are used for various purposes, so as to allow, for example, the efficient navigation between webpages, to remember favourite websites and, generally, to improve the user's browsing experience.

 

First Party Cookies

First Party Cookies are directly stored by the website (or domain) you visit. These cookies allow website owners to collect analytics data, remember language settings, and perform other useful functions that provide a good user experience. These will be stored in your device by the domain intesasanpaololife.ie.

 

Third Party Cookies

Third Party Cookies are created by domains that are not the website (or domain) that you are visiting. These are usually used for online-advertising purposes and placed on a website through a script or tag. These cookie can be stored in you device by third parties such as google.com for instance.

 

Persistent cookie and session cookies

Some cookies are deleted when you close your browser or shortly after. These are known as session cookies. Other cookies (such as tracking cookies or authentication cookies) remain on your device until they expire, or you delete them from your browser. These are known as persistent cookies and enable us to remember things about you as a returning visitor.

 

Why do we use Cookies?

Intesa Sanpaolo Life dac uses cookies to help make our website work, or make it work more efficiently or to give you a better online experience and track website performance.

To achieve this, we use different categories of cookies.

 

Strictly Necessary Cookies

These cookies are essential and help support security and basic functionality such as page navigation, cookie preferences and access to secure areas of the website. With these cookies for instance we record your consent. We can store cookies on your device if they are strictly necessary for the operation of the website and your consent is not necessary for these type of cookies.

Name	Domain/Provider	Expiry/Duration	Description
laravel_session	Intesasanpaololife.ie	Session	HTTP Cookie This cookie is used internally by the website’s owners, when uploading or renewing website content. It is necessary for the site to function
isplife_gdpr	Intesasanpaololife.ie	6 months	HTTP Cookie This cookie is used internally by the website to keep track of the user’s cookie policy preferences

 

Analytics Cookies

We use cookies for statistical purposes aimed at gathering information, in an anonymous manner, regarding the use of our website by its visitors. Intesa Sanpaolo Life dac may use this information to compile reports and analyses the browsing habits of users so as to improve their browsing experience. For instance, Intesa Sanpaolo Life dac uses Google Analytics to track anonymized usage statistics for the site. We anonymize IP addresses in Google Analytics. Google Analytics is implemented through Google Tag Manager.

Name	Domain/Provider	Expiry/Duration	Description
_ga	Intesasanpaololife.ie	2 Years	HTTP Cookie Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
_gid	Intesasanpaololife.ie	1 day	HTTP Cookie Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
_gat	Intesasanpaololife.ie	1 day	HTTP Cookie Used by Google Analytics to throttle request rate

 

Managing Cookies from Intesa Sanpaolo Life Website

You can manage your cookies directly from Intesa Sanpaolo Life Website, you can change your preferences in any moment or withdrawn your consent for instance, clicking here

 

Managing Cookies from the Browser

Within your browser you can choose whether you wish to accept cookies or not. Different browsers make different controls available to you and so we provide links below to various manufacturers' instructions on how you can do this. Generally, your browser will offer you the choice to accept, refuse or delete cookies at all times, or those from providers that website owners use (Third party Cookies), or those from specific websites (First Party Cookies). If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.

 

• Google Chrome
• Internet Explorer
• Firefox
• Safari
• Safari Mobile

 

This Cookie Policy forms part of our overall Data Protection Notice, therefore more information please refer to our Data Protection Notice.

 

 

Information for Products sold from the 25th May 2018

• Policy statement with regard to natural persons pursuant to articles 13 and 14 of regulation (EU) 679/2016 of the European Parliament and of the Council of 27 april 2016.

• Supplementary information on the processing of personal data relating to the signing of electronic documents with a graphometric signature.

• Policy statement with regard to natural persons pursuant to articles 13 and 14 of regulation (EU) 679/2016 of the European Parliament and of the Council of 27 april 2016’’- For promotional and commercial purposes.

 

* Please be aware that this document is just a translation from the original (Italian) one, provided to you for your convenience only. In case of conflict between the translated document and the original document the latter will prevail.

 

List of Data Controllers\Data Joint Controllers\Data Processors

• List of Data Controllers\ Data Joint Controllers\Data Processors

For all matters relating to the processing of personal data and / or to exercise the rights provided by the applicable data protection regulation to the data subject, please contact us at:

Data Protection Officer
Intesa Sanpaolo Life dac
1st Floor, International House
3 Harbourmaster Place, IFSC
Dublin D01 K8F1,
Ireland

or

E-mail: dpo@intesasanpaololife.ie