Privacy Notice for Insured Persons

In accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) – hereinafter referred to as GDPR.

Insurance company ZDROWIE S.A. provides information required by the provisions of GDPR in regards to personal data processing. Prior to giving a consent to process your personal data, please read the information below. 

Data Administrator

The administrator of your personal data is Towarzystwo Ubezpieczeń ZDROWIE S.A. with its registered office in Gdynia, ul. Śląska 17 (hereinafter referred to as: TU ZDROWIE SA)

Contact details

TU ZDROWIE SA can be contacted by email: biuro@tuzdrowie.pl, via contact form on www.tuzdrowie.pl, by phone: 58 888 2 999 or in writing by traditional mail to the address of the registered office of TU ZDROWIE SA.

TU ZDROWIE SA appointed an Inspector of Data Protection, who can be contacted by email: iod@tuzdrowie.pl, by phone: 58 888 2 999 or in writing by traditional mail to the administrator’s address.

The Inspector of Data Protection can be contacted in all matters regarding processing of personal data and/or exercising your legal rights related to personal data processing.

Purpose and Legal Basis for Processing

Your personal data may be processed:

1. to carry out a medical insurance agreement – the legal basis for processing is the necessity to process data to carry out the agreement, and a consent to process information about the state of your health
2. to conduct direct marketing activities of TU ZDROWIE SA own products and services, including for analysis and profiling purposes – the legal basis for processing is the necessity to process data for the purposes of the legitimate interest pursued by TU ZDROWIE SA; the legitimate interest of TU ZDROWIE SA is to conduct direct marketing activities of its own services,
3. to fulfil obligations by TU ZDROWIE SA in relation to prevention of money laundering and terrorist financing – the  legal basis for processing is the necessity to process data for compliance with legal obligation to prevent money laundering and terrorist financing which the administrator is subject to,
4. to fulfil obligations by TU ZDROWIE SA in relation to reporting FATCA/CRS - the legal basis for processing is the necessity to process data for compliance with legal obligation to fulfil international taxation obligations and to implement FATCA legislation, and to comply with the legal provision on automatic exchange of tax information with other countries to which TU ZDROWIE SA is subject to;
5. in the event of legal redress related to your health insurance agreement - the legal basis for processing is the necessity to process data for the purposes of the legitimate interest pursued by TU ZDROWIE SA; the legitimate interest of TU ZDROWIE SA is ability to seek redress,
6. should the need to act against insurance crimes occur - the legal basis for processing is the necessity to process data for the purposes of the legitimate interest pursued by TU ZDROWIE SA; the legitimate interest of TU ZDROWIE SA is possibility to act against and investigate crimes committed against the Insurance Company,
7. risk reinsurance – the legal basis for processing is the necessity to process data for the purposes of the legitimate interest pursued by TU ZDROWIE SA; the legitimate interest of TU ZDROWIE SA is to decrease the insurance risk related with the agreement signed by you or for you.
8. to carry out an agreement concluded by TU ZDROWIE SA - the legal basis for processing is the necessity to process data to carry out the agreement and the administrator's legitimate interest.

Source of Personal Data

TU ZDROWIE S.A. receives personal data such as:

1. name, surname, PESEL/ passport number, date of birth, gender, the kinship with the main Insured Person if necessary, mobile phone number and the Insured Person’s e-mail address to carry out the insurance agreement;
2. information on performed medical services and circumstances of their performance from medical provider/s or medical facilities provided in order to account for the medical services and to create damage registers required by the Polish law.

Data Storage Period

Your personal data will be stored for the limitation period that applies to contractual claims regarding health insurance agreements, or until expiry of data storing obligation under legal provisions, in particular obligation to store accounting records regarding insurance agreements, obligation to store data under the legal provisions regarding prevention of money laundering and terrorist financing; legal provisions on fulfilling international taxation obligations, and in relation to implementation of FATCA legislation, and legal provisions on automatic exchange of tax information with other countries.

TU ZDROWIE SA will cease to process your data to perform direct marketing activities, including profiling and analysing, if you raise an objection against processing your data for such purposes.

Data Receivers

Your personal data may be made available to entities providing medical services, entities providing services connected with the insurance for the persons insured with TU ZDROWIE SA, entities providing medical helpline service and reinsurance undertakings.

Moreover, your data, with the exception of the data on performed medical services, may be made available to entities that process personal data based on TU ZDROWIE SA authorisation. These include IT service providers, entities processing data for the purpose of debt recovery, marketing agencies, or insurance agents, however such entities only process data based on an agreement with TU ZDROWIE SA and solely in accordance with TU ZDROWIE SA instructions.

Your personal data, excluding information on performed medical services, are made available to the policyholders in order to provide proper insurance cover/ calculate premium payable.

Transferring Data Outside EEA

Your personal data will not be transferred to subjects based in third countries outside European Economic Area.

Data Subject Rights

You have the right to access your data and the right to amend it, erase it or restrict its processing.

If the basis of your personal data processing is a legitimate interest of TU ZDROWIE SA, you have the right to object to processing your personal data. 

In particular, you have the right to object to processing your personal data for direct marketing purposes and profiling.

If the basis of your personal data processing is your consent, you have the right to withdraw the consent. Withdrawing your consent does not influence the lawfulness of data processing based on the consent prior to the withdrawal.  

If the basis of your personal data processing is concluding and carrying out the insurance agreement, or your consent, you have the right to transfer your data, i.e. to receive your data from TU ZDROWIE SA in a structured, commonly used and machine-readable format and to pass the data on to another administrator.

You also have the right to lodge a complaint with a supervisory authority responsible for the personal data protection.

In order to exercise your rights, contact TU ZDROWIE SA or the Inspector of Data Protection. The contact details are provided above.

Information on Automated Decision Making Including Profiling

In relation to your personal data processing, an automatic data processing may be applied for profiling purposes, which involves an automated analysis od provided information in order to establish essential elements of the insurance agreement such as premium rate. Algorithms conducting the analysis mentioned above, cannot lead to any type of discrimination and are solely used to adjust the insurance agreement to information being analysed. This is done to provide similar agreement terms for persons in similar situations. In order to provide the most efficient operation TU ZDROWIE SA may make decisions exlusively on the basis of the automated processing of your personal data for the purpose of organising insurance benefits. In such situations TU ZDROWIE SA provides the possibility of human intervention, the possibility to express one's own opinion, as well as the possibility to question a decision in the complaint procedure, the same as in case of making decisions  in a non-automated way.

Information on the Requirement of Providing Personal Data

Providing your personal data in relation to concluding the insurance agreement is necessary to carry out the insurance agreement.

Providing your personal data for the marketing purposes is voluntary.

Agree to the processing of personal data >>