In accordance with Articles 13 and 14 of the General Data Protection Regulation (hereinafter: the Regulation), Zavarovalnica Triglav, d.d. provides you with information regarding the processing of your personal data in the field of telephone marketing.
Provision of insurance agency and marketing services by telephone on behalf of Zavarovalnica Triglav, d.d.
Zavarovalnica Triglav, d.d. (hereinafter: the insurance company) cooperates with business partners who, on behalf of and for the account of the insurance company, provide telephone marketing and insurance agency services. For this purpose, the insurance company concludes a business contract and a personal data processing agreement with each partner. No prior consent from data subjects is required for the processing of personal data for the purpose of telephone marketing of the insurance company’s products and services carried out by our business partners.
Before entering into such cooperation, we assess whether the prospective business partner provides adequate safeguards for personal data protection and define the types of personal data the partner is authorised to process for the purposes of telephone marketing.
The activities of our business partners are monitored closely.
Which personal data is processed and how does the business partner – a telemarketing service provider – obtain it?
When conducting direct marketing by telephone in relation to you, the insurance company's business partner may typically process the following personal data:
- Full name, address and phone number, when this data is published in the Slovenian Telephone Directory (TIS) and there is no indication of a prohibition against commercial calls alongside the telephone number;
- Data that they received directly from you when concluding or executing the insurance contract;
- Data that you provided to them yourself when making calls to a phone number that they received in accordance with the activities mentioned above.
The insurance company does not provide all personal data about clients to business partners for the purpose of telephone marketing. Instead, it provides:
- Data on received withdrawals of consent for direct marketing, submitted by data subjects to the insurance company;
- Data that the contracted processor has already received from you as previously mentioned, but only in connection with prescribed obligations and to the extent determined by the Insurance Act.
Zavarovalnica Triglav, d.d. is part of the Triglav Group and an independent data controller.
Zavarovalnica Triglav, d.d., Miklošičeva cesta 19, Ljubljana, is an independent data controller.
In practice, we have observed that when offering products of other companies within the Triglav Group, such as Triglav, zdravstvena zavarovalnica, d.d., data subjects sometimes mistakenly believe that Triglav, zdravstvena zavarovalnica, d.d. is the sole data controller in these cases as well. This is incorrect. Each individual company within the Triglav Group is an independent data controller and, like Zavarovalnica Triglav, d.d. is bound by data protection regulations. Therefore, if you submit a request to access your personal data that we process, we at the insurance company cannot provide you with data that is processed by other companies within the Triglav Group, as we do not have access to it. For a complete and up-to-date list of the Triglav Group companies, please visit the Triglav Group website at www.triglav.eu.
Right to object to telephone marketing
You have the right to object at any time to the use of your personal data for direct telephone marketing purposes by sending a written request to the following address: Zavarovalnica Triglav, d.d., Miklošičeva cesta 19, 1000 Ljubljana or by e-mail to info@triglav.si or by using the online form available on the Zavarovalnica Triglav, d.d. website: www.triglav.si.
Warning regarding identified unfair commercial practices in telephone marketing
We have been alerted by data subjects and some clients of Zavarovalnica Triglav, d.d. to unfair commercial practices by unknown business entities. Specifically, calls have been made to data subjects from the following telephone numbers: 02 621 98 30, 02 621 96 30, 068 635 652, 064 211 122, 069 644 987, 030 782 009 2, 040 964 607 and 041 919 363. According to the information received, the callers have falsely presented themselves as representatives of Zavarovalnica Triglav, d.d. or representatives of Triglav svetovanje, d.o.o.
Please note that the aforementioned telephone numbers do not belong to Zavarovalnica Triglav, d.d. or its contracted processors.
If you receive a call from any of the listed telephone numbers or if you become aware of any other inappropriate conduct or unfair commercial practice, please inform us immediately by email at info@triglav.si.