1        Data controller

UADB “INVL Life” (Registration code 305859887)

Gynėjų g. 14

LT-01109

Vilnius

Lietuva

2        Contact information for the data protection officer

INVL Life data protection officer contact is following:

Data Protection Officer

“INVL Life”, UADB Estonian branch

Keemia 4, Tallinn 10616, Eesti

[email protected]

In Baltics you can contact INVL Life customer service in each country with regard to data protection issues.

INVL Life, Customer Service

Estonia:

Keemia 4, Tallinn 10616, Eesti,  +372 681 2300

Latvia:

Elizabetes iela 10B-1, Rīga, LV-1010, Latvia, +371 675 03333

Lithuania:

Gynėjų g. 14, LT-01109 Vilnius, Lietuva, +370 8 700 55 959

3        Purpose and legal basis for the processing of personal data

The purpose of the processing of personal data is claims processing based on INVL Life insurance contracts.

The legal basis for the processing of personal data is the implementation of the agreement between INVL Life and the customer and the fulfilment of the legal obligation of INVL Life. Personal data may also be processed in order to fulfil the legitimate interests of INVL Life.

4        Categories of data subjects

• INVL Life insurance contract policyholders, the insured and insurance benefit recipients.

5        Disclosure of data

We may disclose personal data to authorities and other parties referred to law regulating insurance activities or other regulations, mainly to the following:

• Authorities
  • Personal data may be disclosed to authorities, for example, the tax authorities and enforcement offices, when required by law.
• Other insurance companies
  • Personal data may be disclosed to another insurance company in reinsurance situations.
• The Estonian insurance companies high risk persons register

If we decide to sell, buy, merge or otherwise reorganize our businesses, this may involve us disclosing and/or transferring personal data to prospective or actual buyers and their advisers, or receiving personal data from sellers and their advisers.

6        Transfer of personal data outside the European Union or the European Economic Area

We primarily process data within the EU and the EEA. If data is transferred outside the EU and the EEA (for example, in such a way that the data is processed or stored on servers located in these countries) to countries for which the European Commission has not issued a decision of adequacy of data protection, we will take care of the data protection, for example, by utilising standard contractual clauses approved by the European Commission. Sensitive data is not transferred outside the EU and the EEA. Transferred data is processed only on behalf of INVL Life.

7        Retention period for personal data

The customer’s data is retained for 13 years after the end of the most recent contract or payment of the most recent out payment. Data related to taxation and reporting obligations (incl. obligations resulting from international FATCA/CRS agreements) are stored for 10 years after the end of each tax year.

8        Categories of personal data

We process personal data only to the extent necessary and as required by law. The data we process depends on what person or customer category you belong to.

• Data related to insurance claims applications
  • For example, information provided in the insurance claims application and supporting documents.
• Data related to the insurance claims decision
  • For example, the insurance claims decision, amount of insurance benefit, data related to the payment, health and tax data.

9        Rights of the data subjects

You have the right to access your personal data processed by INVL Life, the right to rectify the data and, when the conditions are fulfilled, the right to erase the data, the right to restrict or object to the processing of personal data, as well as the right to transfer the data elsewhere and the right to make a complaint to the appeal body. To learn more about your rights and how to use them, please see INVL Life privacy policy.