Privacy Policy

Latest Update: 25^th June 2021

Introduction

Indeez (‘we’ or ‘us’, and ‘ours’) is committed to respecting your privacy and we recognize the need for appropriate protection and management of your Personal Data. This Privacy Policy explains how we use Personal Data that we collect about individuals (‘you’ or ‘your’) in relation to our services and on our website (‘Indeez.eu’ and all sub domains) and mobile applications (‘app’). 

This Privacy Policy applies to all users creating an account on our website or app as well as to all visitors while browsing our website or app and any individuals using our services or making a claim without creating any account.

Please take the time to read this policy carefully. If you have any questions or comments, please contact us as indicated in the ‘Contact us’ section below.

Who is Indeez ?

Our full name is Indeez SAS, listed on the Paris Trade and Companies Register under number 888 048 659 and registered as insurance broker in the French ORIAS Register, under number 20006983, to operate in France and in the European Union under the freedom to provide services. In the UK, we are deemed authorised and regulated by the Financial Conduct Authority (FCA). Indeez is listed on the financial services register and its FCA number is 938582.

Indeez’ services mainly relate to intermediary activities towards independent workers and digital platforms and businesses that work with self-employed workers (‘the Platforms’). It includes acting as insurance intermediary and taking care of proposing, distributing and managing insurance products. 

We take our obligations under data protection laws seriously, including the security of your Personal Data. We use technical, organisational and physical security measures to protect your Personal Data. We also provide training to our staff to help us comply with data protection laws.

What is Personal Data?

‘Personal Data’ is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information, employment information and financial information.

How do we collect Personal Data?

We collect Personal Data directly from you, including from any application forms you complete, any correspondence you have with us, when you use our website or app, and from the device you use when visiting our website or app. 

We may also collect Personal Data about you from other sources, such as:

• publicly accessible sources;
• the Platforms, insurance brokers, and other business partners we work with;
• third party providers (claims handlers, credit reference agencies, screening providers, etc.); and
• regulators, government agencies and databases.

What Personal Data do we collect and when?

For all users

During website visit: cookies, internet protocol (IP) address, your login data, browser type and version, language setting, time-zone setting and location, browser plug-in types and versions, operating system and platform and other technology devices you use to access our website or apps, including usage data of our website, apps or services. For further information regarding cookies and similar technologies, please see our Cookies Policy. 

To contact us: Name, Email address, Organization

To apply for job offers: Name, Address, Email address, Phone number, Resume

For users creating an Indeez account

During registration: First Name, Last Name, Username & password, Date and place of birth, Country of residence, Email address, Phone number and if relevant, Occupation, Platform name and Platform ID.

For users subscribing an insurance policy

During insurance policy subscription: First Name, Last Name, Date and place of birth, Address, Email address, Phone number, Occupation, Choice of cover and additional Personal Data required to obtain an estimate and conclude the insurance policy (depending on the policy subscribed)  

During payment: Billing address, Crediting and debiting and other details of products or services you have purchased from us, including payment card information

For users making a claim (with or without an Indeez account) 

During claims management: First Name, Last Name, Date and place of birth, Country of residence, Email address, Phone number, Platform name and Platform ID, Claims details (such as place and date of the incident), Information relevant to  the Claims which may include but is not limited to:

• health data such as diagnosis, doctor/hospital certificate, test results, medical expenses
• national insurance number (only if included in health documents – see above)
• identity documents
• police reports
• photos and videos of the incident representing people images and properties
• financial data and bank details
• Any other relevant information including details of your claims history.

Sensitive Personal Data (Special Category or Criminal Offence Data)

Sometimes we may need to collect more sensitive information about you. This may be the case to provide you with your insurance cover, administer your policy, handle your claims and manage any complaints. 

Special Category Data includes information relating to your health, genetic or biometric data, sexual orientation, sex life, racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership. Criminal Offence data includes any information relating to convictions, criminal activity, allegations, offences, investigations, proceedings and sentences, as well as information relating to the absence of any convictions. 

For example, we may collect:

• Health data – including details of any health conditions, test results, diagnosis, and treatment
• Criminal data – details of any convictions or the fact that you have no convictions

We may also collect your national insurance number, but only to the extent it is included in the health documentation we need to collect as mentioned above.

How do we use your Personal Data?

The main purposes for which Indeez uses your Personal Data are described below, as well as the legal basis we rely on to do so, in accordance with data protection laws.

Purpose Description	Legal basis for Personal Data	Legal basis for Sensitive Data
Register you on the website or app as an Indeez account holder	Performance of a contract with you	Not applicable
Provide our products and services, which includes taking payment, analyzing, administering, improving, and personalizing our products and services	Not applicable
Provide you with access to buy an insurance policy, process your purchase orders and administer the policies you bought with Indeez, including premium collection	Not applicable
Contact you and send you notifications and updates in connection with the services, policies or offerings that you may have registered for	Not applicable
Process and redirect your claims (including status updates and reporting)	Performance of a contract with you (if you have an Indeez account)Consent (if you don’t have an Indeez account)	– Consent
Handle queries, feedback and complaints
Prevent, detect and investigate fraud or other financial crime	Necessary to comply with a legal obligation	Not applicable
Comply with any applicable legal, professional and regulatory obligations, including co-operating with bodies such as the Central Bank of Ireland or the Data Protection Commission	Not applicable
Comply with data subject rights requests under the applicable data protection laws	Not applicable
Provide personalized advertising to you and send you promotional materials in line with your marketing preferences	Our legitimate interests (if you have an Indeez account)Consent (if you don’t have an Indeez account and have not opted out)	Not applicable
Identify and authenticate your access to the parts of our website, apps or services that you are authorized to access	Our legitimate interests	Not applicable
Protect Indeez rights and/or property and establish, defend or enforce our legal rights, or those of third parties, which may include enforcing our terms and conditions	Our legitimate interests	Not applicable
Prevent and detect fraudulent activities and ensure the technical functionality and security of the platform and services	Our legitimate interests	Not applicable
Buy, sell, transfer or dispose of any part of our business	Our legitimate interests	Not applicable
For recruiting and human resources administration purposes (for candidates only)	Consent	Not applicable

Who do we share your Personal Data with?

We may sometimes need to share your Personal Data with other parties in relation to the purposes outlined above. 

This may include sharing your Personal Data with:

1. Insurers and Reinsurers who will build and underwrite your insurance policy
2. Business partners such as Platforms, other insurance intermediaries and 3rd party claim companies who will re-direct, check eligibility and handle your claim and/or complaint
3. Credit reference agencies
4. Our payment portal Stripe
5. Our IT service providers (including hosting provider)
6. Government agencies such as the police or the courts – for example based on legal requirements and/or for fraud prevention and detection
7. Regulatory bodies such as the Central Bank of Ireland or the Data Protection Commission, or the relevant ombudsman in case of a complaint against our products or services 
8. Those who you consent to represent you (family, friends, lawyers, etc.) within the limits of their powers or role, or within the scope of authorization granted by you
9. Third parties who provide services for us such as legal advisors, medical experts, technical experts, accountants, auditors

Please note there might be some 3rd party links on our website or app. Clicking on those links will transfer you to their website where different cookies and privacy policies will apply. Indeez does not control these external websites.

How long do we keep your Personal Data for ?

We keep your Personal Data for as long as it is necessary for the purposes set out in this Privacy Policy, and for as long as required to comply with our legal, regulatory, tax or accounting obligations or needs. The specific period for which we retain your Personal Data will depend on the data and the purposes for which we hold it. In some circumstances, you can request that we delete your Personal Data as provided in the section “Your rights” below.

Cookies and other similar technologies

For details regarding how we use cookies and other similar technologies, please see our Cookies Policy.

International Data Transfers

Your Personal Data may be transferred outside the European Union. When we transfer data outside of the European Union, we make sure that the transfer complies with data protection laws to protect your Personal Data and your data protection rights. In some cases, for example where data is transferred to the UK, there are already adequate levels of data protection in place. For other transfers, we may put in place other safeguards such as contractual obligations to protect your Personal Data.

Indeez makes the following transfers outside of the European Union:

Purpose of Transfer	Recipient	Location	Adequacy decision/safeguards
Your Personal Data is accessed by the UK Indeez team	Indeez SAS34 Lime Street, London, EC3M 7AT, England	UK	Adequacy decision
Your Personal Data is accessed by eBaoTech International for policy subscription and claims handling	eBaoTech International Pte. Ltd16 Raffles Quay #27-01, Hong Leong Building, Singapore 04858	Singapore	Standard Contractual Clauses

Marketing and Opting Out

We may use your Personal Data to send you information about our products and services that we think may be of interest to you. This includes information on the Indeez website or app, or by direct marketing (E-mail, phone call or SMS, social networking channels etc.). We use information we hold about you to help us identify, tailor and package our products and services, and offer discounts that may be of interest to you.

You control our use of your Personal Data for marketing purposes. You can decide what channels we can use and what type of notifications you prefer, if any. You will have the opportunity to select the types of marketing & channels that you would like to receive when you complete registration with us or receive direct marketing. You can change your marketing preferences by “unsubscribing” or “opt out” on the email or at any other time by contacting us at legal@indeez.eu.

We will not use sensitive Personal Data (such as information on your health or criminal record) for marketing purposes.

Your rights

Data protection laws provide you with a number of rights in relation to your Personal Data. In most cases, we are required to respond to any request to exercise your rights within one month. Please note that many of these rights are not absolute or may be subject to exemptions in certain circumstances.

Your rights include:

1. The right to be informed

You have the right to be informed on how we collect and use your Personal Data. This Privacy Policy provides you with such information in accordance with the requirements of data protection laws.

2. The right of access

You have the right to request confirmation as to whether or not we process your Personal Data, and where that is the case, to request:

• a copy of your Personal Data
• other supplementary information explaining how we are using your Personal Data, such as: the purposes for which we process your data, the categories of data processed, to whom we share the data with and if it’s transferred outside the European Union, the criteria for determining our retention periods, a reminder of your rights with respect to your Personal Data and the right to lodge a complaint with a supervisory authority, and where the personal data are not collected from you, where we got it from.

3. The right to rectification

You have the right to ask us to correct or rectify any Personal Data which you believe is inaccurate, incomplete or out of date.

4. The right to erasure

In some circumstances, you have the right to request erasure of your Personal Data, for example if we no longer need it for the purpose for which it has been collected, or if you have withdrawn your consent and there is no other legal ground for the processing. However please note that this is not an absolute right and that we’ll not proceed with erasure in all cases. As an example, we will not delete your Personal Data when we continue to have a legal basis to process it. Additionally, we are not allowed to delete data which is required to comply with our legal, regulatory, tax or accounting obligations, such as for fraud prevention and detection.

5. The right to restrict processing

You may ask us to restrict the processing of your Personal Data in certain circumstances (for example, if you believe your Personal Data is inaccurate or if you have objected to us processing your Personal Data on the grounds of our legitimate interests).

6. The right to object

You can object at any time if you would like us to stop sending you direct marketing. You can also object to some other processing in certain circumstances (such as processing based on our legitimate interests, unless we have overriding compelling grounds to continue the processing). 

7. The right to withdraw consent

If our legal basis for processing your Personal Data is consent, you may withdraw your consent at any time. Please note however that if you do withdraw your consent, it may not be possible for us to continue providing your insurance policy, processing your claim, handling any queries you may have or your job application.

8. The right to data portability

The right to data portability allows you to obtain from us in readable format certain Personal Data (that you provided to us) or ask us to provide that information to a third party of your choice. This applies if such Personal Data is processed by us on the basis of your consent or performance of a contract with you.

9. Rights in relation to automated decision making and profiling

If we undertake automated decision making or profiling using your Personal Data (for example an automated decision that you are not eligible for a policy), you have the right to ask us to review that decision with the input of a human being. 

You can exercise the above rights by writing to us at legal@indeez.eu or at the following address: Indeez SAS, 19 Rue du Rocher, 75008 Paris – France

In some cases, we may ask you to provide us with a copy of a signed identity document or other proof of your identity.

You may also find further information about your rights using the Data Protection Commission (DPC) website: Your data

If you are not happy with how we handle your personal data, please contact us at legal@indeez.eu. You may also choose to make a complaint to the DPC by using the form available here.

To the extent that French data protection laws apply to our processing of your Personal Data, you may also contact the French data protection authority, the CNIL, on the CNIL’s website or by post at “Service des plaintes”, 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07.

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time to comply with the latest rules and regulations and other legal requirements and to adapt it to our use of Personal Data. We will let you know if and when we do, by informing you of the publication of each updated Privacy Policy by a message, banner or pop-up displayed on our website or app or by email.

These changes will come into effect as of the publication of the new policy. Your use of our website or app following the notification of the updated Privacy Policy will constitute recognition of the terms of such policy. If you have any questions about the changes made to our Privacy Policy, please contact us as indicated in the following section.

Contact us

If you would like to contact Indeez in regards to your Personal Data, you can email our Legal Team at: legal@indeez.eu

Or write to us at:

Indeez SAS
19 Rue du Rocher,
75008 Paris – France