To contact the Data Controller write to: fabrizio.tedeschi@bmimarine.it

We wish to inform you that European Regulation no. 679 of 27 April 2016 (the “General Data Protection Regulation” – hereinafter, EU Regulation 2016/679 – also known by the English acronym GDPR) provides for the protection of natural persons with regard to the processing of personal data. According to the aforementioned regulation, such processing will be based on fundamental principles, such as, for example, correctness, lawfulness, transparency and protection of your privacy and your rights. Pursuant to art. 13 of the aforementioned regulation, therefore, we provide you with the following  information:

DATA CONTROLLER
The Data Controller is the insurance broker BMI MARINE MGA Srl, in the person of its legal representative, who can be contacted at the email address bmimarinemga@legalmail.it (hereinafter, “BMI” or the “Controller”).

DATA PROTECTION OFFICER
The Data Protection Officer can be contacted at the email address bmimarinemga@legalmail.it

LEGAL BASIS FOR PROCESSING
The legal basis for processing is identified in the contract to which the Customer is a party, in the national and community legislation in force as well as in the voluntary consent given by the Customer.

OBJECT OF THE TREATMENT
The owner processes the personal identification data (for example, name, surname, company name, address, telephone, e-mail, bank and payment details) communicated by the Customer at the time of the conclusion of the contract. The personal data requested are strictly connected and instrumental to the management of relationships with the Customer (for example, data is collected for the acquisition of preliminary information to the conclusion of a contract, for the execution of operations on the basis of the obligations deriving from a contract, etc.).

Generally, data defined as “special” by art. 9 of EU Regulation 679/2016 are not processed, such as, for example, data relating to the health conditions of the Customer. However, it may happen that, in relation to specific services or products requested by the Customer, BMI MARINE MGA SRL needs to know “special” data, because from them it is possible to deduce information necessary to provide the requested service or product and the possible adhesion of the Customer to insurance contracts with insurance companies (for example, the request for “special” data by BMI MARINE MGA SRL – especially data on the health status of the Customer – occurs when taking out insurance policies on people – temporary life insurance policies in the event of death, accident, sickness and/or reimbursement of medical expenses, or in the management of claims). “Special” data may also be processed where they are voluntarily communicated by the Customer.

PURPOSE OF THE PROCESSING
The data provided by you will be processed for the following purposes:

purposes carried out in the interest of the Client, aimed exclusively at carrying out the intermediation activity with insurance and reinsurance companies pursuant to Legislative Decree no. 209/2005 (the “Private Insurance Code”) and related implementing Regulations (including the IVASS Regulation, formerly ISVAP no. 5/2006) and activities strictly connected and instrumental to the execution of the contract and the management of relationships with Clients (for example, providing the services and/or benefits and/or insurance products requested; preparing estimates; preparing and stipulating insurance policies; collecting insurance premiums; settling claims; archiving and administratively/accountingly managing the data for the settlement of commissions; carrying out an analysis of new insurance markets; disseminating technical circulars, such as those concerning risk prevention; etc.);
to fulfill obligations established by laws, regulations and community legislation as well as by provisions issued by Authorities authorised to do so and by Supervisory and Control Bodies (for example, anti-money laundering legislation, IVASS provisions, etc.);
to send the Customer information or advertising material regarding products or services of BMI MARINE MGA SRL, also through the use of automated communication systems, for example, e-mail, sms, messaging applications – whatsapp, telegram, etc. – and fax (advertising);
to carry out market research and/or verify the level of customer satisfaction with the products and services of BMI MARINE MGA SRL also through market research companies.

5bis PROFILING

Your data may be used to send you promotional messages regarding any new offers and services of the Company, related to your needs and expectations. Specifically, you may receive: mail, email, text messages, phone calls, messages via the main messaging applications (Whatsapp, Telegram, etc.).

INFORMATION ON CONSENT TO TREATMENTS
We wish to inform you that the provision of your data for the treatments referred to in point 5, letters a, b, c is mandatory and, in the event of refusal to provide them, we will not be able to proceed with the stipulation of the contract or provide you with any of our services. If you wish the treatments referred to in point 5, letters c, d, and point 5 bis to be carried out, you will have to provide us with your consent. However, the consent may be subsequently revoked.

METHOD OF TREATMENT
In relation to the above-mentioned purposes, the data will be processed both through computer and/or electronic tools and on paper and, in any case, through tools suitable for guaranteeing their security and confidentiality through the adoption of adequate security measures, as provided for by art. 32 of EU Regulation 679/2016.

The data will be processed by authorized persons / third parties and by managers (formally identified) who will use tools and media – paper, magnetic, computer or telematic – suitable to guarantee the security and confidentiality. The processing may therefore, as mentioned above, be carried out both through automated tools, computer media, cloud, suitable for storing, managing and transmitting the data electronically and through paper tools duly managed in strictly controlled archives. The databases are stored in protected environments, access to which is under control. Any data processed for market research purposes will be stored in ways that limit the scope of circulation to the strictly necessary, limiting the number of personnel strictly authorized to process the information.

8. COMMUNICATION TO CATEGORIES OF RECIPIENTS
In order to carry out activities related to the insurance sector and all that derives from it, your personal data may be communicated to the following categories of recipients. In particular:

for the purposes referred to in point 5 a) and b)
to other entities in the insurance sector such as, by way of example and not limited to: insurers, co-insurers and reinsurers; agents, sub-agents, producers, insurance brokers and other channels for acquiring insurance contracts (for example banks and SIM);
companies that acquire, record and process data contained in documents or media provided to BMI MARINE MGA SRL by Customers to carry out insurance texts and specifications, agreements, etc.;
assistance and welfare funds; companies that provide insurance services (for example, risk management companies, asset valuation companies, etc.);
consultants, lawyers, experts and car repair shops; service companies entrusted with the management, liquidation and payment of claims;
companies and professional operators that provide electronic data processing and software and IT consultancy services as well as management of information services, in order to enable the execution of operations and/or services requested by the Customer (for example, data transfer services), for archiving procedures, for printing correspondence and for managing incoming and outgoing mail;
associations and consortiums in the insurance sector;
IVASS, CONSAP, UCI, Pension Fund Supervisory Commission, Ministry of Labour and Social Security and other databases to which data communication is mandatory (for example, Financial Information Unit (UIF), Central Accident Register, Civil and Transport Motorisation under concession);
companies responsible for fraud control, debt collection and detection of credit and insolvency risks;
Public Administrations, pursuant to the law; companies responsible for quality certification);
for the purposes referred to in point 5 letter. a), b), c), d) and point 5 bis:
parent companies, subsidiaries and affiliates, even indirectly, pursuant to the current legal provisions, commercial partners for the promotion and development of insurance products and services and market research companies.

Without the interested party’s consent to the communication of data to the aforementioned subjects and to the related processing, the quality of the service offered to the Customer and consequently of the product or service offered could be compromised, as BMI MARINE MGA SRL will be able to carry out only those operations and services that do not require the communication of personal data to third parties, i.e. transmission of expiry notices, insurance consultancy, transmission of claim receipts.

It is understood that your data will not be transferred to third parties and will not be disclosed for purposes other than those indicated above.

9. DATA TRANSFER
For the same purposes as in point 6, personal data may be transferred outside the national territory, to countries with adequate guarantees based on the parameters of the European Commission (art. 45 of EU Regulation 679/2016) BMI MARINE MGA SRL will verify the adequacy of the country receiving the data, in order to ensure the necessary guarantees to the interested party.

In other cases, the transfer will always be permitted with the prior consent of the interested party and with the prior authorization of the Supervisory Authority. BMI MARINE MGA SRL will in any case provide a dedicated information notice to the interested party. The list of foreign companies with which BMI MARINE MGA SRL has signed reciprocal agreements is available upon request of the interested party.

DATA RETENTION
Your data will be retained for 10 years from the termination of the relationship if related to pre-contractual, contractual and legal obligations. Personal data may also be processed for a longer period, where an act interrupting and/or suspending the prescription occurs which justifies the extension of data retention. The data provided by the Customer processed for marketing purposes will be retained for a period not exceeding 24 months or until the customer requests to revoke his/her consent to the pursuit of the aforementioned purposes.

After this period, the data will be deleted and/or made anonymous so as not to allow, even indirectly or by connecting other databases, the identification of the interested parties.

COMPLAINTS
As an interested party, you will have the right to lodge a complaint with the Supervisory Authority. In any case, wishing to resolve the problems encountered by our Customers quickly and in the best possible way, we invite you to lodge a complaint directly with the Owner, by sending an email to bmimarinemga@legalmail.it or by registered letter addressed to BMI MARINE MGA SRL, Piazza Piccapietra, 83/63 16121, Genoa (GE)

RIGHTS OF THE INTERESTED
PARTY As an interested party, you will have the right to ask the Data Controller for access to your personal data, the rectification of inaccurate personal data and their integration, or the deletion of data (so-called “right to be forgotten”), the limitation of processing or the right to object to data processing. Finally, you will have the right to request data portability (the rights referred to in Articles 15 to 22 of EU Regulation 2016/679).