Last update: 10/09/2018
The information collected by any Cbp Group subsidiary on its websites falls into two categories:
- information voluntarily provided by visitors,
- tracking information collected when users browse the site.
Any information collected on a Cbp Group website to identify you is considered personal data and will be processed in accordance with this policy.
1. Cbp Group’s commitment
Cbp Group formally undertakes, on behalf of itself and all its subsidiaries, to protect the privacy of its employees, the insureds whose insurance contracts are managed by Cbp Group on behalf of its insurance partners, and the Internet users who visit Cbp Group’s websites.
Cbp Group is also committed to ensuring the confidentiality of your personal data that it collects, uses and communicates to its insurance partners for the proper management of your insurance contracts.
2. Identity of the controller
Cbp France, a simplified joint stock company with a capital of 62,035 euros whose registered office is located at 3 rue Victor Schoelcher, 44800 SAINT-HERBLAIN, FRANCE, registered with the NANTES Trade and Companies Register under number 863 800 868, an insurance brokerage company registered with the ORIAS under number 07 009 030, acts as a controller of your personal data or as a processor on the behalf of an insurer responsible for the processing of your personal data.
Cbp Group, as well as each of its subsidiaries, applies the following principles:
- your data is used for explicit, legitimate and necessary purposes to manage your loan insurance or individual pension contracts;
- your data are not stored for longer than is necessary for the operations for which they were collected.
Cbp Group complies with the standards and applies the legal and regulatory provisions in force in each European country where one of its subsidiaries operates.
3. Contact details of the Data Protection Officer
You can contact the Cbp France Data Protection Officer:
- by post: Cbp France – Data Protection Officer – 3, rue Victor Schoelcher – 44800 SAINT-HERBLAIN – FRANCE
- by email: email@example.com
4. Purposes of the processing
The personal data collected through our website are used for the following purposes:
- the management of our relationship with you, whether you are a visitor, a job candidate, an applicant or policyholder of an insurance contract, an insured or a beneficiary of an insurance contract;
- claims and litigation management;
- recruitment management;
- corporate communication.
5. Recipients of personal data
If you apply for a job offer or in the event of a spontaneous application, your personal data are exclusively intended for the Human Resources department of the Cbp Group subsidiary concerned.
In other cases, your personal data are exclusively intended for the management and marketing/communication services of Cbp France, its service providers and subcontractors in charge of the computerised processing of these data, and the Insurer on whose behalf Cbp France collects them.
In the normal course of providing our services, the personal data collected may be used within Cbp France for research and statistical purposes; in this case, they are aggregated or anonymised.
Cbp France subcontracts services on its behalf to other companies, such as sending postal mail. These companies may have access to some of your personal data, such as addresses, necessary for the performance of their services, but are not authorised to use them for purposes other than those referred to in the context of processing of contracted services whose purpose is precisely defined.
Cbp France may retain and has the right to disclose without your prior consent any information about you or your use of our websites if it has reason to believe that such action is necessary to:
- protect and defend the rights, property or safety of Cbp France, its employees, other users of our websites, or the public ;
- enforce the terms and conditions that apply to the use of our websites;
- respond to complaints alleging infringement of third party rights as a result of the content of a website; or
- satisfy any law, regulation, legal process or government request.
6. Transfer of personal data to a third country
Your personal data may be processed by Cbp France’s service providers and subcontractors.
The service providers and subcontractors concerned are located exclusively on the territory of the European Union and have contractually undertaken to process personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.
7. Retention periods
If you contact us via our website, apply for a job offer or in the event of a spontaneous application, your personal data is stored by Cbp France for 24 months after the date on which you provided it to us.
If you subscribe to an insurance contract with an insurance partner of Cbp France, your personal data is stored by Cbp France for:
- 10 years after the end date of your contract, for a loan insurance contract,
- 30 years after the end date of your contract, for an individual pension contract.
8. Rights of data subjects
In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, you have the following rights:
- request access to your personal data,
- request the rectification of these data in case of error,
- request the erasure of these data (“right to be forgotten”),
- request the restriction of processing of these data,
- object for legitimate reasons to the processing of these data,
- receive these data in a structured, commonly used and machine-readable format, in order to transmit them to another controller (“right to data portability”).
You can set guidelines for the retention, erasure and disclosure of your personal data after your death.
For France, you can exercise these rights by contacting:
- by post: Cbp France – Service Réclamations – 3, rue Victor Schoelcher – 44800 SAINT-HERBLAIN – FRANCE
by email : cbp.protectiondesdonnees@cbp-
9. Complaint to a supervisory authority
You have the right to file a complaint directly with the supervisory authority of the country in which the Cbp Group subsidiary with which you interact operates.
For France, it is the Commission Nationale Informatique et Libertés:
- By post, by writing to : CNIL, 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07 – FRANCE
- By phone: +33 (0)1 53 73 22 22.
10. Provision of data and possible consequences of not providing them
Cbp France is legally required to verify that your data are accurate and complete and to update them if necessary. Cbp France may ask you to check or complete your file.
The mandatory or optional nature of your replies and the possible consequences for the Member and the Insured of a failure to reply are specified when they are collected.
11. Data security
Cbp Group implements appropriate technical and organisational measures to ensure the security of personal data collected and stored. Your personal data are thus protected against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or unauthorised access.
In addition, it is the responsibility of each user to take all appropriate measures to protect his or her own data (including IDs and passwords) and equipment used from contamination by malicious software.
12. Cbp Group’s policy towards minors
In order to use this website and its services you must be at least 18 years old and have the legal authorization to contractually commit yourself according to the legislation in force. Cbp Group does not intentionally collect personal data from Internet users under the age of 18. Should such data nevertheless be collected, it would be purely accidental and unintentional. Cbp Group encourages parents to discuss Internet use with their children and to monitor any personal data they may disclose via the Internet.
13. Policy updates
If you no longer wish to receive information from our services, please let us know by sending an email to firstname.lastname@example.org
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