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SAFETYWING CUSTOMER PRIVACY POLICY

UPDATED ON SEPTEMBER 1, 2023

1. Introduction

At SafetyWing, we take the safe and confidential handling of your personal data
seriously, and we want you to understand how we are doing this and make you
fully aware of your rights.

We have drafted our Privacy Policy to be simple, clear, and concise, so that we
accurately describe how we are collecting and using the personal data we
collect.

Building a global social safety net is a lot of work, and requires us to collect
some personal data from our customers. Through our Data Privacy controls, we
take good care of all the personal data we collect.

The overall approach we follow at SafetyWing is that:

 * We only process Personal Data when there is a valid reason (“lawfulness”).
 * We are always transparent about our intentions with personal data
   (“transparency”).
 * We only collect what we need and as much as we need, not a letter more
   (“purpose limitation” and “data minimisation”).
 * We only keep data as long as we need it, then it is deleted (“storage
   limitation”).
 * We keep all personal data secure.
 * We make every effort to respect your data rights.

While we have put care and attention into making this policy as clear as
possible, it's ok to have questions and we are here to help. Feel free to reach
out to our customer support team or Data Protection Officer (dpo@safetywing.com)
and they will be more than happy to help.



2. Why do we need your data anyway? (Purpose of processing)

That's a good question. Well, for a few reasons actually.

We want to provide you with the best service possible, answer all your questions
in a specific and useful way, make sure that our products and services are
suitable for you, and ultimately to enter into a contract with you to provide
that service. To do all this, we need your personal data.

3. TL;DR (The short version)

Privacy Policies are not always easy or fun to read, and we get that. So, here's
a brief summary of what you want to know:

 * We only collect the Personal Data that we need to provide you with products
   and services.
 * In most cases, we process your data based on a valid reason (“lawful basis”),
   contractual or legal obligations and therefore we do not need your consent.
 * Personal Data is collected either directly from customers or from related
   third parties.
 * Sensitive data (special categories of Personal Data) might be collected in
   specific situations, and will be handled with extra care.
 * We usually keep the Personal Data of customers for 7 years following the
   expiration of their policies.
 * There are international transfers of personal data, as you would expect from
   a global company like SafetyWing.
 * You have rights!



4. A few definitions to make the reading easier



 * Personal Data: Any information that can identify a natural person (i.e.
   human)
 * (Personal Data) Processing: Collection, recording, organization, structuring,
   storage, adaptation or alteration, retrieval, consultation, use, disclosure
   by transmission, dissemination or otherwise making available, alignment or
   combination, restriction, erasure or destruction of Personal Data.
 * Data Controller: An organization that decides how the personal data it
   collects and holds is used and dictates how other companies or individuals
   (“data processors”) should process personal data.
 * Data Processor: A person (natural or legal) that processes personal data of
   which it has no ownership according to the instructions provided by the Data
   Controller.
 * Special Categories of Personal Data: Personal data revealing sensitive
   information including but not limited to genetic data, biometric data, data
   concerning health or data concerning a natural person's sex life or sexual
   orientation.
 * Lawful basis: A valid, legitimate reason to process Personal Data.



5. Let's start with the what, why, and where

What data do we collect, why do we collect it, and where do we get it from?

We want to make sure that we know our customers well so that we can help them
get the best experience with SafetyWing. To do this, we need to collect a few
details about them, as presented below.

Data type
   Identification details:
 * Full name
 * Gender
 * Address
 * Date of birth
 * Home country, citizenship, nationality
 * Occupation
 * National identifier numbers (including passport number and/or driver's
   license number)
 * Email address and phone number

Why do we need it
   We only use this to identify you and:
 * To open and manage your accounts and relationship with us
 * To verify your age
 * To enhance your experience and our products and services
 * To share relevant marketing about our products and services, news and
   updates, and upcoming events (if you consent to it)
 * To meet our legal and regulatory obligations
 * To enable you to register for an online account
 * To contact you about your account(s)
 * To determine your eligibility for some of our products and services

Data type
   Family details:
 * Marital status
 * Next of kin
 * Dependents

Why do we need it

To understand your circumstances and needs and assess the suitability of
products and services you apply for with us or one of our partners.

Data type

Data on how you interact with us

Why do we need it

To give you the best service and prevent fraud. This can include whether you
have carried out a transaction over the phone or over the internet.

Where do we get it from

We get this data either directly from you or through third parties in cases
where someone else adds you as a dependent or member of a policy that you do not
own.

More precisely, we will obtain data directly from you via:

 * Registration & Purchase
   * When you sign up for the first time and make your first purchase. That's
     when we initially collect most of your personal data.
   * When you update your personal data online or you request that we make
     changes. We process your personal data by updating them to be accurate.
 * Phone communications
   * When you speak to us on the phone, we may record the call for training and
     quality purposes.
 * Website and application use
   * When using our websites, and any digital or mobile app we may offer now or
     in the future.
 * Written communication
   * When you reach out to us through our customer support chat services, the
     conversation is stored in our records. When you send us emails, we store
     those in our records as well.
   * When we use information that you've made public, such as social media
     content or when you interact with our social media profiles.
 * Data collected from third partiesThere are also times when personal data will
   come from a third party. For example:
   * If you are signing up as a joint account with someone else, and you are not
     the main policy holder, we will collect your personal data when the policy
     holder signs you up.
   * When a nominated representative signs you up. Since the signup will be
     about you, we will collect your personal data.

6. You may be wondering on what grounds we are collecting Personal Data
(“Lawfulness of processing”)

We collect your data for a few reasons, and most of them do not require us to
get consent from you. This means that a) we do not need to bother you with
giving us consent and b) we really need this data to provide our Products and
Services.

According to data privacy frameworks, personal data can only be collected where
there are valid reasons. In the absence of any other legal reason (lawful
basis), we need to obtain your consent to process your data. These are the
grounds on which we are collecting data from you (“lawful bases”):

Lawful basis

Consent

Less frequently used
Description

This is when we ask you to confirm whether you are ok for us to process your
personal data, for a specific purpose.

Lawful basis

Explicit Consent

Less frequently used
Description

This is when we process any of your sensitive information (special categories of
personal data), where we explicitly obtain your consent for the processing.

Lawful basis

Contract

More frequently used
Description

This is when we need to process your personal data so that we can execute our
contract with you to provide you the service. Unless we process the data, a
contract cannot exist.

In this circumstance, your consent is not required.

Lawful basis

Legal Obligation

More frequently used
Description

This is when we need to process your personal data in order to comply with the
law. Again, in this circumstance, no consent is required.

Lawful basis

Legitimate Interest

More frequently used
Description

This is when processing is necessary for our legitimate interests or the
legitimate interests of a third party, i.e., valid reasons. No consent is
required from you here either.

7. Does SafetyWing need sensitive personal data? (“Processing of Special
Categories of Personal Data”)

At SafetyWing, sensitive data usually means health data such as medical history,
claims information, vaccination history, and any other information relevant to
your coverage, policy or claim. If we need to collect or process any sensitive
data, you can rest assured that we will let you know about this in advance. Not
only will you know, but you will also be asked whether you approve of SafetyWing
processing any personal data (“explicit consent”).

In the event that you submit information to us which involves any sensitive
data, thereby granting us access to sensitive data, we will ask for your consent
to process the data, and will also handle them with additional security, as this
is what the laws require us to do.

8. What about personal data regarding children?

Although we don’t offer products directly to children, we may happen to become
recipients of such data when you inquire about a family policy and you wish for
your children to be covered. When we do collect this information, we will only
ask for the minimal amount of data to enable an accurate quotation for coverage.
Any data, like all the information we store, will be protected and kept secure,
and the only people able to access it will be those who strictly need to in
order to help with your request.

9. What's SafetyWing's role when processing my personal data?

SafetyWing will always be the Data Controller for any personal data collected
from customers. This means that we will be responsible for how your data is
processed, including cases where we need to transfer your data to third parties.

In other words, even when your data is transferred to third parties, we are
still responsible for it.

10. Why does SafetyWing give my Personal Data to third parties?! (“transfers to
third parties & international transfers”)

As the saying goes, it takes a village, and this is very true in building a
global social safety net. In order to provide our Products and Services, we
sometimes need to share your data with third parties, and this sometimes
involves international transfers of data. Let's address two important questions:

 * Where does your personal data travel to?
 * How do we protect your data through this process?

10.1. LET'S START WITH WHERE.

Personal data is shared with the companies we use to provide, promote and
protect our products, and our insurance partners who, in some cases, are the
ones that enable us to provide innovative new products.

In both cases, personal data might be shared internationally, as our vendors
might have data hosted in different locations.

   Some examples of where we share your data to:
 * Our insurance partners
 * The company we are using to perform compliance checks against sanctions
 * The vendors we use to securely store all data, including personal data

10.2. HOW DO YOU PROTECT MY DATA WHEN TRANSFERRED INTERNATIONALLY?

 * First and most importantly, by ensuring that we only work with vendors and
   partners that treat data securely.
 * We review our vendors and partners each year to ensure they maintain strong
   security standards.
 * We only transfer personal data to countries that we have assessed and
   concluded that they have sufficient data protection frameworks.
 * We put the necessary standard contractual clauses (as per Data Privacy
   regulations) in our contracts with third parties to ensure that they will do
   what the data protection law requires to provide us with adequate data
   privacy and security levels.

11. How does SafetyWing make sure my personal data is secure?
   We treat your data like ours. And for this reason we take the security of
   personal data seriously and have the necessary measures in place:
 * We keep all of our data including your personal data collected on secure
   cloud locations (Google Cloud Platform).
 * We ensure that only a limited number of people have access to your personal
   data, on a need-to-know basis.
 * We review our data privacy and security infrastructure frequently, using
   independent audits to ensure that we are keeping up with global regulatory
   requirements and best practices.
 * We have procedures in place in case of a data breach, which include notifying
   the affected users where relevant.

12. Do I have any rights on the processing of my data (“Data Subjects rights”)?

Of course you do, and we explain everything below.

You can exercise your rights by sending an email to dpo@safetywing.com or
reaching out to our Customer Care team through our website.

We always try to address your request within 1 month of receiving them, and in
the event we will need more time, we will let you know.

12.1. FIRST OF ALL, YOU HAVE THE RIGHT TO KNOW WHAT PERSONAL DATA WE ARE HOLDING
RELATED TO YOU (“RIGHT OF ACCESS”).

When you submit a Subject Access Request, we will tell you what personal data we
have about you, whether these are transferred to third parties, the duration we
intend to keep the data in our records, whether we use your data to perform
automated profiling, and other details explicitly related to you.

Just keep in mind that we cannot execute a request that does not have reasonable
grounds, or one that is regarding a person other than you.

12.2 YOU CAN REQUEST THAT WE UPDATE YOUR PERSONAL DATA IF IT IS NOT ACCURATE
(“RIGHT OF RECTIFICATION”).

Do you believe that personal data we have related to you is not correct? Just
let us know and we will explain the process to update everything to be correct.

12.3. YOU CAN ASK FOR YOUR PERSONAL DATA TO BE DELETED (“RIGHT OF ERASURE”).

You can request that we delete some or all of your data, and we will gladly
comply, to the best of our abilities.

While you have the right to request for your data to be deleted, we also have a
legal obligation to keep the data for a certain period of time (“retention
schedule”). When we receive such a request from you, we will let you know what
data we can delete now, and what data we will need to wait to delete.

12.4. YOU CAN REQUEST THAT WE RESTRICT THE PROCESSING OF YOUR PERSONAL DATA
(“RIGHT TO RESTRICTION OF PROCESSING”).

If you would like us to stop processing your personal data any further
(excluding the storing of your data, as this is still required), you can request
this. We will review your request and if our legal obligations allow us to
execute your request, we will happily do so.

12.5. YOU CAN ASK THAT WE SEND YOUR PERSONAL DATA TO ANOTHER THIRD PARTY (“RIGHT
TO DATA PORTABILITY”).

According to this right, you can ask that we send any of your personal data we
keep in a structured, commonly used and machine-readable format to another Data
Controller.

12.6. YOU HAVE THE RIGHT TO REQUEST THAT WE DO NOT MAKE ANY AUTOMATED DECISIONS
BASED ON YOUR PERSONAL DATA (“RIGHT TO OBJECT TO AUTOMATED INDIVIDUAL
DECISION-MAKING”).

In cases where your personal data are used to make automated decisions, you have
the right to object to it and the process will stop, unless there are other
pressing reasons, which will be communicated to you.

As mentioned above, you can exercise your rights or ask more information about
them by sending an email to dpo@safetywing.com or contacting us through our 24/7
customer care chat through our website.

13. How long do you keep my data for (“Retention schedule”)?

Only for as long as we need to, and not a day more.

   We keep data as long as laws and regulations require us to. Some of the
   factors we take into account to decide on how long to hold your data
   (“retention period”) are:
 * Customer expectations, the nature of your relationship with us, your
   membership status and the types of accounts, products and services you have
   with us.
 * The maximum or minimum retention periods identified by legal or regulatory
   guidance.
 * Our contractual rights and obligations.
 * Forensic requirements, for example, the need to access data no longer
   actively used in order to manage or respond to a complaint or dispute.
 * The risks involved in retention, deletion and removal and cost of
   maintaining, storing, archiving and retrieving data.

   You can see below a more detailed presentation of how long we keep different
   types of data:

Data type
 * Name
 * Title (e.g. Ms, Mr)
 * Sex
 * Address
 * Date of birth
 * Nationality
 * Occupation
 * National identifier numbers, passport numbers, driver's license number
 * Email address and phone number
 * Family details, marital status, next of kin, dependents

How long we keep it for

7 years after the end of our business relationship.

Data type

Call recordings

How long we keep it for

3 years after the end of our business relationship.

Data type
 * Geo-location data
 * How you interact with us

How long we keep it for

1 year after the end of our business relationship.

Data type

Direct marketing preferences

How long we keep it for

Until you tell us you no longer wish to receive marketing.

Data type

Enquiries only

How long we keep it for

Personal Data of people that expressed enquiries without making any purchases
are usually kept for 3 months.

14. Phew, that's it!

So, that was our Privacy Policy. Thank you for reading through all of it!

We really hope that we have answered any questions you might have had, and have
given you enough information to understand both what we do with your personal
data as well as how we do it.

If you still have questions or concerns, please reach out to our Data Protection
Officer by email on dpo@safetywing.com or contact us via our 24/7 live chat.

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