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Privacy policy

PRIVACY POLICY OF ZAVAROVALNICA TRIGLAV, D.D.

Respect for the privacy of individuals, including the protection of personal data, is essential for us. We are committed to data protection and to ensuring security and confidentiality. We therefore invite you to learn more about the processing of your personal data in Zavarovalnica Triglav, d.d.

Basic information about us as the personal data controller

Controller:

Zavarovalnica Triglav, d.d.

Registered office:

Miklošičeva cesta 19, 1000 Ljubljana

Tax number:

80040306

Registration number:

5063345

Share capital:

EUR 73,701,391.79

Management Board:

Andrej Slapar

Phone:

01 474 72 00

Fax:

01 432 63 02

Web address:

https://www.triglav.si, https://www.triglav.eu

E-mail address:

info@triglav.si

Company register entry number

Ljubljana District Court,
reg. no. 1/10687/00

Activities of Zavarovalnica Triglav, d.d., in accordance with the applicable standard classification of activities

Life insurance
Non-life insurance
Reinsurance Pension funding
Activities of insurance agents and brokers
Other activities auxiliary to insurance and pension funding

Activities of the Triglav Group

Insurance and reinsurance
Management of investment funds and financial assets

Collection and use of personal data

We collect and further process your data in accordance with the regulations governing the protection of personal data.

1.1 When do we collect your personal data?

We collect your personal data from you when:

  • you use our website,
  • you use our web or mobile applications,
  • you request an offer to conclude insurance,
  • you conclude insurance with Zavarovalnica Triglav, d.d.,
  • you ask for information,
  • you give a compliment or complaint,
  • you report an insured event or loss event,
  • you report insurance fraud,
  • you subscribe to receive notifications from Zavarovalnica Triglav, d.d.,
  • you are a user of other services provided by Zavarovalnica Triglav, d.d.,
  • you are a participant in prize competition (co)organized by Zavarovalnica Triglav, d.d.,
  • there are other examples provided by this policy.

Information on the processing of personal data relating to the conclusion and implementation of insurance policies concluded with Zavarovalnica Triglav, d.d., is provided in the section Insurance and personal data.

1.2 When visiting the website

Our websites (*.triglav.si, *.triglav.eu, ocistimogore.si, triglavtek.si) are publicly available and are intended for use and information to the general public, as well as for the use of other functionalities.

Visitors to the websites of Zavarovalnica Triglav, d.d., can always voluntarily decide when and how they wish to contact Zavarovalnica Triglav, d.d. (by telephone, e-mail, apps or online forms). Visitors to the websites also decide which free interactive tools (e.g. informative calculations) they will use.

Zavarovalnica Triglav, d.d., uses the information relating to the visit to the website or use of the mobile application for the following purposes:

  • to monitor and analyse the performance of web and mobile applications,
  • for technical maintenance and development of websites and services of Zavarovalnica Triglav, d.d.,
  • for notification about the services and products of Zavarovalnica Triglav, d.d. and other important information (operations, tenders, events, etc.),
  • to manage relations with existing customers and provide selected services,
  • and for other purposes listed in this Privacy Policy.

When visiting the website, mobile application or web application of Zavarovalnica Triglav, d.d., the server automatically collects details of your visit, such as:

  • IP address,
  • URL of the website from which you accessed our website,
  • browser settings and information about the operating system of your computer or mobile device,
  • content accessed on the website or application of Zavarovalnica Triglav, d.d.,
  • date of access and duration of visit to the website or application of Zavarovalnica Triglav, d.d.

You will also find the term "cookies" on websites, mobile applications, web applications and other digital solutions, and you can learn more about them on the link Use of cookies which is an integral part of this policy.
Cookies are small text files that most websites store on user's devices that access the Internet to identify the individual devices that users have used to access. The visitor or user of the website may store, restrict or disable cookies. Cookies are intended to make websites more user-friendly by recording individual's interests, preferences and experiences, and improving the efficiency of information search, while not identifying a specific individual.

2.3 When filling in web forms

As a rule, the web forms provide personal information needed by Zavarovalnica Triglav, d.d., in order to provide you with the information, assistance or service you need.

The following web forms are available through the website of Zavarovalnica Triglav, d.d., in which we may collect and process data in addition to the data referred to in the previous point of this privacy policy, as listed below:

Area

Data about the individual in addition to the data from the previous point

Purpose of data processing

Media

E-mail address for notification when an individual can be identified from it

Providing information in accordance with the interests expressed

Career path

E-mail address for notification when an individual can be identified from it, and the country and area of work, if chosen by the individual

Providing information in line with the interests expressed related to calls for employment

Conclusion of insurance

Name and surname, e-mail address, tax number, date of birth and other identification data: e.g. policy number (for existing customers). More information on the protection of personal data can be found in General terms of use of the digital office called i.triglav and web/mobile business with Zavarovalnica Triglav, d.d.

Ensuring the performance of underwriting

Notification of loss

Contact phone number and e-mail address and other identification data: e.g. name, policy number (for existing customers) and other loss data in accordance with the loss notification forms published on the website. More information on the protection of personal data can be found in General terms of use of the digital office called i.triglav and web/mobile business with Zavarovalnica Triglav, d.d.

Provision of assistance related to the performance of insurance contracts

Agent’s order

First and last name, e-mail address, telephone, desired location and date of the visit, wishes

Provision of information regarding the insurance offered by Zavarovalnica Triglav, d.d.

Insurance fraud and reporting suspicion of fraud

Contact details of the person reporting (name and surname, address, phone number, e-mail address), details of the legal and natural persons involved, a description of the reasons for the suspicion of fraud and the manner in which the fraud was implemented, the way fraud is established, the value assessment of the damage, and a description of what this assessment is based on, evidence

Detection, handling, monitoring, investigation and insurance fraud deterrence

Complaints and compliments

Contact details of the sender (name and surname, address, postal code, post office, telephone, e-mail address), the contents of the attachment (if attached by an individual), the type of message (compliment/complaint), the content of the message

Handling, monitoring of complaints and compliments, and improving the quality of services

Online forms for exercise of rights on privacy protection

Name and surname, e-mail address, content of the request

The exercise of the rights of individuals with regard to the protection of personal data

E-test for the workshop Young driver

Name, surname, address, date of birth, contact details (e-mail), year of driving test passed, gender, e-test code, course date, course time

Provision of assistance related to the performance of insurance contracts

Customer satisfaction survey

Code, method of reporting loss, date of loss, estimate of likelihood of making a recommendation and other data from the survey form

Implementation of insurance contracts and improvement of services

Give your opinion

E-mail address, the content of the opinion and any other information when an individual provides it

Providing information and assistance to customers or individuals

Entries for digital events in Triglav Lab

Name, surname, e-mail address, mobile number, event type, questions for the trainer

Event execution based on individual’s registration for an event in Triglav Lab

E-news to receive free useful advice, information and the latest benefits

E-mail address for notification when an individual can be identified from it, and selected news topics

Providing information in accordance with the interests expressed

2.4 When using web applications

If you are a user of the Zavarovalnica Triglav’s web applications, we may collect other personal data about you, either to provide access to information relating to insurance contracts concluded or to provide other services to which you subscribe as an existing customer for the purpose of applying discounts and other benefits.

Zavarovalnica Triglav, d.d., manages the following web applications and collects data in them as follows:

The web application "i.triglav" and the web application "i.triglav for business users" are intended for existing customers who have non-life or life insurance with Zavarovalnica Triglav, d.d., or health insurance with Triglav, Zdravstvena zavarovalnica, d.d or life insurance with Skupna pokojninska družba, d.d.

Within the web application i.triglav we process the following personal data:

  • registration data (first and last name, e-mail address, password),
  • information at registration (fist name, last name, e-mail address, password, tax number, information on the digital certificate, the health insurance card number in the case of health insurance, address details, mobile number),
  • data on insurance policies (non-life, life and health insurance), data on the agent orders, data on status and structure of insurance and other investment savings, informative calculation of the value of the insurance policy of investment or pension insurance, data on forms and applications for reporting data and claims relating to insurance policies, data on payments by insurance policy, data on reported losses,
  • information on the use of the web application (IP address, last login date, name of mobile phone, machine or browser operating system version, duration of visit, list of pages visited, movement trace, recent visit list).

You can learn how to use the web application "i.triglav" in Terms of use.

The Purchase portal web service is an application that ensures the execution of the tenders by Zavarovalnica Triglav, d.d. We provide information on open tenders and bidding opportunities on the website. The web service is intended for companies and sole proprietors who want to cooperate with Zavarovalnica Triglav. As part of the purchase portal, Zavarovalnica Triglav, d.d., processes the following data:

  • registration data (first and last name, e-mail address, department, telephone, password, company tax number, company registration number),
  • login information (e-mail address, password),
  • data for the purposes of participating in selected tenders (specification, amount of transaction value, name of company representative, bid attachments, representative telephone number, history, time and reason for changes),
  • information on the use of the web application (IP address, last login date, name of mobile phone, machine or browser operating system version, duration of visit, list of pages visited, movement trace, recent visit list).

2.5 When using mobile applications

For those who love the latest technologies, we also offer free mobile applications:

i.triglav mobile app

for an overview of own insurance policies, collected discounts and benefits

Asistenca mobile app

to report an assistance or loss case

Drajv mobile app

to monitor the way users drive and provide benefits in insurance, and participation in prize competitions

Triglav vreme mobile app

to monitor weather forecasts, radar images and weather charts, warnings from the Slovenian Environment Agency, water conditions, data on ski resorts, mountain conditions and web cameras

More information on the processing of personal data in mobile applications can be found in Terms of use, and the terms of Drajv mobile app can be found here.

We collect the following personal data about mobile app users:

  • basic information on the entity: the policyholder, the insured, the payer, the user or any other entity involved in any way with us,
  • information on the vehicle or other subject of insurance,
  • data on the mobile device (if used) or other electronic device you are using,
  • telemetry application data (e.g. DRAJV) and data from other mobile applications of Zavarovalnica Triglav (e.g. Triglav Vreme, etc.),
  • information obtained in the context of customer relationship management (reporting of assistance and reporting of loss through Triglav Asistenca).

We also store cookies that can uniquely identify an application installed on your device and it's use.

We use personal data obtained through mobile applications for the purpose of:

  • providing access to data and information relating to insurance contracts concluded,
  • providing an additional communication channel to report an assistance or loss case,
  • enforcement, collection and monitoring of benefits and discounts,
  • providing information in connection with the portal Vse bo: v redu and other web content of Zavarovalnica Triglav, d.d.,
  • providing technical assistance to users,
  • the implementation of cloud and other mobile app analytics,
  • development and upgrading of service functionality,
  • improvement of user experience,
  • analyzing user trends,
  • the assessment of the level of safety resulting from the acquisition of benefits in an insurance premium,
  • and carrying out data processing in accordance with the given consent.

Processing location data of the mobile application user

To enable the proper operation of the DRAJV, Triglav Vreme and Triglav Asistenca apps and to ensure that all the functionality of the above mobile applications is fully operational, we process the location data of the user acquired from their mobile device. We process location data in such a way that users cannot be identified. However, in cases where processing location data is essential for the operation of (some) application functionalities, processing is part of the General terms for application use: in such cases, the General terms inform users what data we will be processing, for what purpose and how long, and on the possibility of passing on this location data to a third party due to the implementation of a value-added service (e.g. processing the coordinates of the customer's location within car assistance in order to determine the location of the user asking for road assistance). In the "location services" settings of the mobile device, the user can edit the use of location data each time they are connected to the network or for any communication transmission, which may prevent the use of the entire application or some of its functionalities, in so far as they require location information for their operation.

2.6 When using e-mail

Individuals may also send an e-mail to the Zavarovalnica Triglav, d.d., through the e-mail addresses published on the website www.triglav.si. In this case, you decide on a voluntary basis which personal data you want to give us. Zavarovalnica Triglav, d.d., will further process your e-mail address and e-mail in accordance with the content of your e-mail message and taking into account the type and nature of the relationship.

2.8 When using phones

You can also contact Zavarovalnica Triglav d.d. by phone, and you may also be contacted by the employee of Zavarovalnica Triglav d.d., or by representatives of processing contractors of Zavarovalnica Triglav d.d., if you have expressed a wish to have contact in this way or have agreed to make a telephone call.

In the case of recording a telephone conversation, you will be specially informed about this before the start of the telephone conversation or via the answering machine. The recordings are stored and processed in order to provide evidence of business communication, more precisely in order to establish the facts and circumstances of the cases and information provided by the customers in accordance with the provisions of the law governing electronic communications.

2.9 When performing video surveillance at the entrance to the business premises of the Central and Regional Units of Zavarovalnica Triglav, d.d.

In order to protect the people and assets of Zavarovalnica Triglav, d.d., we perform recording of the entrance to the business premises of the Central and Regional Units of Zavarovalnica Triglav, d.d. In such a case, you will be notified by means of a special notice published in a prominent place. With regard to recording, we collect the following data: an individual's image recording, the date and time of entry or exit from the place where video surveillance is carried out.

2.10 When recording at events organized by Zavarovalnica Triglav, d.d.

We strengthen the Triglav brand by organizing a wide range of sporting, cultural and socially responsible events (Planica, Triglav run, Let’s clean up mountains, etc.), where we can also process the personal data of the participants.

The first processing of personal data usually takes place when a participant applies if registration for the event is required. When making registration forms, we therefore make sure that we request only those data that we really need from the participants for the event itself. When registering for an event, an individual can also fill in the form "Consent to the processing of personal data" - i.e. the images on which they are depicted, which means a photograph and/or a video. The processing of images containing an individual's image is carried out on the basis of the individual's consent – we are all the more careful when a minor under 15 years of age is in the recording (in this case we ask that consent for the processing of personal data be given by his or her legal representative or guardian). We need consent for making a recording, as well as for publishing it on websites, social networks, printed media etc. Without consent, only those photographs on which the person is not identifiable are published, so they cannot be recognized, for example: blurred photograph, shot in the back, detail of closed hands, etc.

We act differently in the case of mass visits or major events. Any individual who attends a major or public event (as a performer or as a spectator) should be aware that at such an event it is more likely they will be recorded. At such events, we can record and publish a recording of the event as such or record a reportage that includes the images of the individual, making sure that the individual is not the central motive of the recording. Before holding such an event, we always publish a notice that the event will be recorded. If you want the published photo, in which you are the main motif of the shot, to be removed, or if you do not want to appear in the frame or with a statement you do not want to participate in the video, please let us know in advance or as soon as possible at info@triglav.si. For the purpose of publishing the photo gallery of the event or video contribution and the subsequent promotion of the event, Zavarovalnica Triglav processes the photos or videos in databases which are established and maintained in accordance with the regulations governing the protection of personal data and keeps them for five years from their creation.

2.11 At the prize competitions

When you participate in one of the prize competitions organized by Zavarovalnica Triglav, d.d., or in which it participates as a sponsor, and you have provided your personal data as part of your application to participate in the competition or event, Zavarovalnica Triglav, d.d., may process your data as a sole controller of personal data collections or as a joint controller of the personal data collection with the organizer or other persons with whom it is involved in the performance of the prize competition or event.

We process your personal data primarily for the purpose of the prize competition or event and for the award of prizes, and in accordance with any consent given separately when applying to participate in the prize competition or at an individual event. They are retained until the completion of each prize competition or event, or 10 years in case of receipt of the prize, and in case of consent to its cancellation.

Zavarovalnica Triglav, d.d., may process your personal data for other purposes, provided that it is bound by law.

If you received a prize in the competition exceeding EUR 42 or you received several prizes from Zavarovalnica Triglav, d.d. in one year with a total value of more than EUR 84, the Company also processes your data for the purpose of personal income tax prepayment and transmits it to the relevant tax office in accordance with the obligations of the Personal Income Tax Act. The information provided shall be kept by the Company in accordance with the law for 10 years.

2.12 Use of data for marketing purposes

If you have given the appropriate consent at the time of concluding the insurance or at the time of entering into the prize competition or at the event or otherwise, Zavarovalnica Triglav, d.d., may also process your personal data for the following purposes:

Purpose

What does the consent given mean and what benefits does it offer to you?

What data are we processing based on your consent?

For segmented (direct) marketing, including the creation of a profile that we perform for marketing our products and services and for marketing the products and services of the companies of the Triglav Group

If you give your consent, we will be able to make offers tailored to your needs, requirements and interests or to your profile. On the basis of recognized character properties, interests, habits, needs, demands and wishes, we will be able to devote special attention to offering you only what you really need. We will be able to keep you regularly informed of your personalized offers, services and innovations of the companies of the Triglav Group, with the headquarters in the Republic of Slovenia, which are engaged in insurance activities and/or financial services (these include Zavarovalnica Triglav, d.d., Triglav, Zdravstvena zavarovalnica, d.d., Skupna pokojninska družba, d.d., Triglav Skladi, družba za upravljanje, d.o.o. – a complete, updated list of companies is published on the Triglav Group's website, www.triglav.eu). With this consent, we will also be able to agree on the visit of our agent who will present the above offers to you.

If you give us your your consent for segmented (direct) marketing, including profile design, we will be able to process the following data from you: first name, last name, address, tax number, birth date, e-mail address, phone number, mobile phone number, if you submit the data. In accordance with the Insurance Act, we may also process gender data for marketing purposes. Additionally, for marketing purposes, we may also process, on the basis of consent, data on your age and/or the extent of insurance and/or the duration of insurance to ensure that, in accordance with the requirements of the Insurance Act, we take into account the requirements and needs of our customers in relation to the distribution of insurance products according to the type of insurance product we market.

To provide your information to companies in the Triglav Group established in the Republic of Slovenia, engaged in insurance and/or financial services for the purpose of informing with personalized offers

With your consent, we will be able to share your personal data from the collections we keep, including profiles already created, with other companies that are in the Triglav Group and have a registered office in the Republic of Slovenia and are engaged in insurance activities and/or financial services (these include Zavarovalnica Triglav, d.d., Triglav, Zdravstvena zavarovalnica, d.d., Skupna pokojninska družba, d.d., Triglav Skladi, družba za upravljanje, d.o.o. – a complete, updated list of companies is published on the website of the Triglav Group, www.triglav.eu), so that they can also design and inform you about their tailor-made offers.

If you give your consent to provide your data to the Triglav Group affiliates, we provide your data from the consent form: name, surname, address, tax number, date of birth, e-mail address, phone number, mobile phone number and purpose or purposes of processing for which you gave your consent, plus gender information.

Certain activities relating to marketing purposes are also carried out in accordance with our legitimate interests; namely:

  • where the primary purpose is business communication in connection with your enquiries, underwriting and performance of insurance contracts and regulatory notification; in such cases, marketing content shall be printed on the back of business documents or added in signature of the sent e-mail,
  • sending offers to potential customers without prior profiling and sending offers with prior profiling where a narrow set of personal data other than a specific type of personal data is used for this purpose (e.g. personal name, address of permanent or temporary residence, phone number, e-mail address and fax number, age, gender, types of insurance contracts concluded, term of expiry).

For more information on legitimate interests, see chapter "Processing of personal data on the basis of legitimate interests".

Phone marketing is also carried out in the Company with the help of our contractual processors. You can learn about short explanations and information about performing phone marketing here.

2.13 Use of data for the implementation of rating programs

The Company shall also process personal data from its filing systems for the purposes of implementing rating programs, i.e. offering various benefits and additional discounts (e.g. Joining the Triglav kit). Joining the rating program is entirely voluntary.

Triglav Kit

In the Triglav Kit program, the following data is collected on the basis of an accession statement:

  • holder details: name and surname, tax number, birth date, contact details (street and number, postal code, postal name, telephone number and e-mail address);
  • member details: name and surname of the holder of the kit, first and last name, date of birth, tax number, member's relationship to the holder (e.g. husband, wife, partner, child, parent, grandparent, brother, sister, grandson, etc.), contact details (street and number, postal code postal name, telephone number and e-mail address);
  • information on the insurance, included in the Triglav Kit,
  • discount level information.
Insurance and personal data

If you have concluded any insurance with Zavarovalnica Triglav, d.d, this can only be done by processing your personal data. We do this with the high care and only to the extent necessary for achieving legitimate purposes of processing personal data, such as insurance, payment of claims for damages, recovery of unpaid premiums, and similar actions where the processing of personal data cannot be avoided.

In the vast majority of cases, we use the data you have given us when concluding insurance or during the course of the insurance business only for this purpose. Depending on the circumstances, we sometimes need to use this data for other insurance-related purposes, but only when we have the appropriate legal basis for this. Such other purposes of processing your insurance data normally result from specific obligations imposed on Zavarovalnica Triglav, d.d., under specific legislation such as the prevention of money laundering and terrorism financing, in the implementation of domestic and international sanction measures, in reporting to insurance supervisory authorities, law enforcement authorities, tax authorities and similar.

Obtaining personal data

We mostly collect personal data from you within the framework of concluding insurance, and in certain cases, depending on the type of insurance, we may also obtain it from other legal and natural persons or state bodies. For example, if you have concluded life insurance, a certain amount of the data may be obtained by the insurance company, according to law, from your personal and your treating physician, healthcare providers, health insurance institution, and similar, at the time of conclusion, during performance or upon payment of the claims. If you have concluded car insurance or caused a car accident, we may collect your data from the police and other bodies that own it. If you have entered into a credit agreement at the bank and the bank has been insured with the insurance company for the event of your default, your data is collected from the creditor bank. If you have concluded insurance through an authorized external insurance agency, we collect your personal data from the agency. In the cases provided for by the Insurance Act, we may also obtain your data from other persons in possession of them if they are required in the performance of insurance and other legal obligations.

Additional information under Articles 13 and 14 of the General data Protection Regulation can be found here.

Processing of personal data of other categories of individuals

If you are not a (potential) customer of Zavarovalnica Triglav, d.d., or a person connected to the insurance (e.g. beneficiary, injured party, witness, recourse payer or their agent), a visitor to our website or a user of our services, you can learn some additional information about the processing of personal data, which are accessible here.

Processing of personal data on the basis of legitimate interests

In certain cases and by category of individuals, personal data in Zavarovalnica Triglav, d.d., is processed on the basis of the following legitimate interests:

  • improvement, development and upgrading of insurance services, systems and products of the Company,
  • technical maintenance of websites and services,
  • customer relationship management and customer satisfaction monitoring (e.g. provision of applications with information on contracts concluded and for the purpose of providing additional discounts and benefits (iTriglav, Triglav Kit), issuing premium vouchers, rewarding customer loyalty with promotional gifts, etc.),
  • equipping of business communication with marketing content,
  • preparation for the sales interview and review of previously concluded insurances,
  • contacting the customer about the renewal or continuation of the insurance,
  • identification of the needs and requirements of the Company's potential and existing customers, including offering new insurance products with new guarantees where such customer needs and requirements are identified during the sales interview,
  • sending offers to all potential customers without prior profiling and sending offers with prior profiling where a narrow set of personal data other than a specific type of personal data is used for this purpose (e.g. personal name, address of permanent or temporary residence, phone number, e-mail address and fax number, age, gender, types of insurance contracts concluded, term of expiry, etc.),
  • ensuring the operation of information systems, network security and information (prevention of events, illegal or malicious acts that threaten accessibility, authenticity, integrity and confidentiality of stored or transferred personal data and the security of related IT services), the prevention of unauthorized access to Company information systems and the response to computer security threats and incidents,
  • for the purpose of protection and insurance of assets and employees of the Company against threats and violence and in similar cases where, without processing personal data, it would not be able to protect and enforce its own legitimate interests and rights, which we enjoy under the law; this includes the implementation of video surveillance at entrances to business premises due to clarification of the circumstances of offences against the employees and assets of the Company, and supervision of access to the Company's business buildings in order to prevent access of unauthorized persons into business premises and in order to ensure house order in business premises of the Company,
  • for the purposes of conclusion, processing and exchange of personal data for reinsurance purposes,
  • for the purpose of carrying out actuarial calculations and accounts and checking the payment of commissions to insurance agents,
  • to investigate suspicions of insurance fraud.

What do we mean by legitimate interests of individuals?

These are your legitimate expectations regarding the processing of your personal data in relation to us. For example, the expectation that we will ensure the operation of the insurance company's information solutions and the security of personal data processing. This is also your expectation that an insurance agent knows which insurance you have already concluded and that, on this basis and based on an assessment of your needs and requirements, they propose appropriate insurance products for you (for example, more in line with your needs and requirements or with additional covers, which are not covered by existing insurance). This includes ensuring your physical security when you visit us in our business premises. Your legitimate expectation is also that we reward you for your loyalty and trust with additional discounts and benefits.

You also rightly expect us to handle your complaints and suggestions by improving our services and preparing them in a way that makes them more customer-friendly and high-quality, and that they provide you with additional functionalities in line with technological progress.

Categories of personal data users

We do not normally transfer your personal data to third parties as part of the provision of insurance. From time to time, the Company is obliged to provide your personal data to certain external users if they prove to have the appropriate legal basis for obtaining your data. Such users are typically different state authorities that require your personal data in the context of the formal procedures they conduct, or individuals, if they request access to the data through a court or if they prove with certainty that you have given them the authority to obtain your data.

Any request from third parties to obtain your personal data shall always be verified to determine whether it comes from an eligible requester and whether they have the appropriate legal basis for obtaining it. In the event that the request for information is incomplete, we will refuse to provide any information from you.

A list of categories of users of your personal data is available here.

Categories of personal data processors

Like most companies, Zavarovalnica Triglav, d.d., engages various contractual processors who perform part of the services for them, for individual parts of the processing of personal data, whereby the company concludes appropriate statutory agreements on the processing of personal data with such contractual data processors, in which it binds them to the same standard of personal data protection as if the company carried out these excluded parts of the processing of personal data itself. At the same time, these contractual processors process the data only for the purpose of providing the contractually defined services for the company and for no other purpose, nor may they use it for their own purposes or for the purposes of third parties.

A list of categories of processors of your personal data is available here.

Data retention

We will retain your data for the period necessary to fulfil the purposes set out in this privacy policy, unless a longer retention period is necessary or permitted by law.

The Insurance Act provides that data on policyholders and insured persons are to be stored 10 years after the termination of the insurance contract, 10 years after the end of the processing of the insurance case in the case of an insurance case, and 10 years after the end of the legal proceedings in the case of a judicial procedure for the recovery of outstanding insurance obligations. Data relating to insurance cases and the assessment of insurance cover and the amount of compensation or insurance cover shall be stored for 10 years after the termination of the processing of the insurance case. If in that period the insured person or injured party has submitted or is reasonably expected to submit a new application for the enforcement of rights arising from the insurance case after the expiry of that period, the period of retention shall be extended, where appropriate, in such a way that the data are kept for 5 years after the processing of the new application has ended or until there is the possibility of submitting a new reasoned application. Upon expiry of the retention period, the data contained in the databases shall be deleted and the documentation shall be destroyed in such a way that its content can no longer be established or can no longer be reused.

We retain your personal data, processed on the basis of your consent and for the purposes defined in the consent, until your consent is withdrawn or until your objection to the processing of data for the purpose of direct marketing. The same applies to the processing of this data in the affiliated companies to which, with your consent, personal data have been transmitted for the same purpose of processing.

Automatic decision making and profiling

We inform you that certain personal data may be processed by automated means where such processing is necessary for the conclusion or performance of an insurance contract with you, where the regulations of the European Union or the Republic of Slovenia so permit, and when appropriate measures are taken to protect your rights and freedoms and on the basis of your explicit consent.

In the case of processing of data with automated means that have legal effects for you or that have a similar effect on you, you have the right to request that a decision based solely on automated processing does not apply to you, by sending the request to info@triglav.si or dpo@triglav.si. In this case, we will ensure that the competent person in the company will reconsider the automated decision.

Privacy protection

10.1 Technical and organizational measures

In Zavarovalnica Triglav, d.d., we implement physical, organizational and technical measures to protect data against loss, theft, unavailability and unauthorized use. We protect your data in accordance with applicable laws and internal regulations governing the protection and insurance of personal data in Zavarovalnica Triglav, d.d., and the area of information security.

All employees of Zavarovalnica Triglav, d.d., contractual processors and other persons, that have your personal consent or other appropriate legal basis for processing the data, are bound to protect the confidentiality of your data and must not disclose the data to unauthorized persons or persons, that do not have the proper basis for processing your personal data. We only grant access to your personal data to those persons who need to know this information so that they can process it on our behalf. These persons are bound by contractual obligations of confidentiality and may be subject to appropriate proceedings in the event of infringements.

We carefully protect business premises where personal data media, hardware and software are located by measures that prevent unauthorized persons from unauthorized access to personal data.

We implement, review and maintain security procedures that correspond the latest state of the art, standards and practices of data protection.

The internal network of the Company is protected from the outside world by a firewall system and other active intrusion prevention and detection systems that correspond to the latest state of the art.

The web and mobile applications of Zavarovalnica Triglav, d.d., are only accessible after registration with individual identification, such as user name and password, personal digital certificate and others. Users shall have access only to the information they need to perform their tasks or to which they have justified access.

10.2 Recommended measures for the protection of privacy and the liability of individuals

We recommend that individuals and all addressees of this policy protect their privacy themselves by the following:

  • Providing accurate and up-to-date information

If you are insured with our insurance company, we ask you to keep us informed of changes in your personal data. We will endeavor to keep your data up to date if we receive your message.

At the same time, we inform you that at the time of concluding or later, you may also give your consent for the completeness, accuracy and timeliness of your personal data. What do you get with your consent? There may be a mistake in the recording of personal data, e.g. incorrect recording of personal name, date of birth, tax number, etc. With your consent, we can ensure that we keep correct and up-to-date information about you, as in doubt we will be able to verify its accuracy and obtain it from official records and public registers, for example, from the Central population Register, without having to burden, call or otherwise contact you.

  • E-mail

Before sending us an unprotected email through your web service provider, keep in mind that its online content may not be protected from unauthorized reading, counterfeiting, etc.

  • Password usage

We recommend that you ensure the security of the passwords or other identifiers you use to log in. Be sure to keep them properly and not disclose them to others.

When you, as a user of our services, identify an abuse of your username and password or other user identifier that you use to access Zavarovalnica Triglav’s web applications, please, contact us as soon as possible at info@triglav.si. Upon receipt of the notification, we will make sure that we disable the continued use of such a password.

If you lose or forget your login information (user password) used to access Zavarovalnica Triglav web applications, you will be able to reset your user password by entering your personal e-mail address you provided as your contact e-mail address. You will receive an email with a link to reset your user password to this email address.

  • Anti-virus protection

We recommend that you have an active software protection against malicious code installed on the device when you access the contents of Zavarovalnica Triglav, d.d. You can also find more information on the dangers on the Internet and the recommendations for protection at https://www.varninainternetu.si/

10.3 Digital social network rules

Zavarovalnica Triglav, d.d., is in contact with individuals and the general public via Facebook, Twitter, YouTube and LinkedIn digital social networks, which makes it important that individuals also learn about the rules of these networks or their privacy policies and privacy settings, which are also available on the following links: Facebook, Twitter, Youtube, LinkedIn.

You should also be aware that your post on the world wide web is visible to the general public, so it is very important to take into account the Internet etiquette (the so-called netiquette), namely:

  • express opinions and views in a cultural manner,
  • do not disclose confidential and sensitive personal data,
  • do not disclose data for which you do not have permission to post,
  • do not use logos, signs, trademarks, and other intellectual property rights for which you do not have the owner's approval,
  • do not post messages with malicious, offensive, indecent, vulgar, defamatory, hostile, threatening, obscene or any content that may affect other members of the social network or third parties,
  • do not threaten or intimidate other users.

10.4 Links to other websites, apps and services

The websites and mobile applications of Zavarovalnica Triglav, d.d., may provide links to third party websites or include third party sites and services. Zavarovalnica Triglav, d.d., is not responsible for the protection of privacy or personal data by third parties, application providers, operating system providers, wireless service providers, device manufacturers, etc.

If you choose to visit such a link, we are not responsible for the availability of the selected site, mobile apps or other third party services. We also do not verify and are not directly or indirectly responsible for the use and content of third party websites, their mobile applications or services, the collection and processing of any data from such person's websites, mobile apps or services. In view of the above, we recommend that before using the services or mobile applications of third parties or before entering any personal data into them, that you familiarize yourself with their privacy policies or privacy statements, which are accessible either on their websites or when you access (register) on such a mobile application.

10.5 Children and personal data

We do not intentionally collect personal data from children on our websites and in mobile applications, except for the participation in prize competitions and the acquisition of images on events organized by Zavarovalnica Triglav, d.d., and we always strive to collect personal data from children to a reasonable extent. In Zavarovalnica Triglav, d.d., we take special care with regard to personal data of children under the age of 15, so that we do not collect, use or disclose their personal data and that we do not deliberately attract children to the web and mobile applications of Zavarovalnica Triglav, d.d. We obtain their personal information only through contact details of parents or guardians.

When children under the age of 15 participate in an individual event in our organization, their images are acquired and processed only with the prior written consent of their parents or guardians. For children under the age of 15, their parents or guardians must sign their consent to enter the prize competition. With consent, parents may allow us to process the personal data of the child for the purposes of the delivery of prizes and the publication of the information of the winners. If a child under the age of 15 is awarded a prize, it shall be notified by e-mail, telephone or written notice to the parents or guardians of the child.

We would particularly like to remind you that the digital social networks have a lower age limit for children's participation in their terms of use and privacy policies, which is not the responsibility of Zavarovalnica Triglav, d.d., and it is assumed that all users or persons who like, follow or otherwise monitor the social network are older than 13 years.

In relation to the above and the use of the Internet, and in relation to other information society services, we recommend that you discuss with your child about the safe use of the Internet and mobile devices to avoid disclosing children's personal data on the Internet and in communication with strangers. The following website can also help parents with this: https://safe.si/

The exercise of rights in relation to personal data

If personal data in Zavarovalnica Triglav, d.d., are processed on the basis of consent, the individual may at any time suspend or withdraw their consent to the processing of personal data; the individual may also object to the processing of personal data relating to them for the purpose of direct marketing, or request access, completion, correction, restriction of processing, the transfer or deletion of personal data, or file an objection to the processing of personal data which is processed in relation to them, by sending a written request to: Zavarovalnica Triglav, d.d., Miklošičeva cesta 19, 1000 Ljubljana, or info@triglav.si or through a web form available on the company’s website www.triglav.si. Your cancellation is valid for the future and does not affect the processing of personal data that was carried out before your cancellation.

If you object to the processing of personal data based on our legitimate interests, we will no longer process your personal data unless we demonstrate, in accordance with the General Data Protection Regulation, the necessary legitimate grounds for processing that override your interests, rights and freedoms, or for enforcement, implementation or defence of legal claims.

We would also like to remind you that if you believe that the regulations governing the protection of personal data have been infringed, you have the right to lodge a complaint with the Information Commissioner of the Republic of Slovenia, Dunajska cesta 22, 1000 Ljubljana.

Other information

Any questions regarding this policy, comments and requests for assistance related to the exercise of your rights, related to the processing of your personal data, may be addressed to the Data Protection Officer of Zavarovalnica Triglav, d.d., at the following e-mail address: dpo@triglav.si.

Updating privacy policy

Zavarovalnica Triglav, d.d., reserves the right to update this privacy policy from time to time.

Any changes to this privacy policy shall take effect from the date of publication on the website www.triglav.si or in mobile applications of Zavarovalnica Triglav, d.d.

Zavarovalnica Triglav, d.d., recommends that all individuals to whom this policy applies to regularly check this policy.

The continued use of the websites, mobile applications, or services of Zavarovalnica Triglav, d.d., following published changes to the privacy policy, means that you agree to the changes.

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