Privacy Policy

Processing of personal data

SANTA LUCIA, S.A., Insurance and Reinsurance Company (hereinafter, “SANTA LUCIA”) is the owner of the website www.santalucia.impulsa.es and responsible for the processing of personal data provided by interested parties through this website in compliance with Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016 (hereinafter, “RGPD”) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and the guarantee of digital rights.

The use of this website is subject to this Privacy Policy, the Legal Notice and the Cookies Policy. Please read them carefully before providing your personal data.

As an interested party, you are informed and consent to the processing of the data provided while browsing the Website and those generated as a result of its use, and those that you provide through the different web forms by SANTA LUCIA for the purposes indicated in the section For what purposes do we process your personal data and with what legitimacy? and in accordance with this Privacy Policy.

However, if you do not accept the terms of this agreement, you should not use the services provided by SANTA LUCIA.

The interested party will be responsible, in any case, for the veracity of the data provided, and SANTA LUCIA reserves the right to exclude from registered services any interested party who has provided false data, without prejudice to other actions that may be appropriate by law. In the event that the interested party makes personal data belonging to third parties available to SANTA LUCIA, he must be duly authorized to do so, and guarantees that he has informed the third party of all aspects contained in this Privacy Policy and obtained your consent to provide us with your data for the processing purpose in question. All of this, prior to the provision of the third party's data.

In this regard, it is expressly stated that SANTA LUCIA ensures full compliance with Law 34/2002, on Information Society Services and Electronic Commerce and the GDPR, recognizing that it has adopted or will adopt all technical and organizational security measures that are mandatory in accordance with the provisions of current legislation, in order to guarantee maximum security and confidentiality of communications.

Children under 18 years of age may not use the services available through the Website without the prior authorization of their parents, guardians or legal representatives, who will be solely responsible for all acts performed through the Website or the App by the minors in their care, including the completion of forms with the personal data of such minors and the marking, if appropriate, of the boxes that accompany them. In this regard, and to the extent that SANTA LUCIA does not have the capacity to control whether or not the interested parties are under 18 years of age, it should be parents and guardians who enable the necessary mechanisms to prevent minors from accessing the Website and/or providing personal data without their supervision, and SANTA LUCIA does not admit any responsibility in this regard.

SANTA LUCIA may modify this Privacy Policy when necessary. If changes are made, we will communicate this to you through the website or by other means, so that you can learn about the new Privacy conditions.

Information on data protection

Who is responsible for the processing of your personal data?

The information and/or personal data you provide to us will be responsible for:

Identity: SANTA LUCÍA, S.A. Insurance and Reinsurance Company. with N.I.F. A 28039790
Postal address: Plaza de España, 15, 28008, Madrid, Spain.

To ensure adequate management in the processing of your data, SANTA LUCÍA has appointed a Data Protection Delegate, whom you can contact for any necessary management at the following address: dpo@santalucia.es

How do we obtain your personal data?

SAINT LUCIA obtains your personal data from the following sources:

Provided voluntarily by the interested party by completing the forms on this Website as a result of their interactions with the products and services offered.
As a result of your browsing through this Website.
On the occasion of the development, processing and maintenance of the legal relationship, consultation,
request or request for any service.
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For what purposes do we process your personal data and with what legitimacy? What categories of personal data do we use?

1. Contact, management and processing of inquiries and requests from interested parties on the website.

Description of the purpose: The personal data of interested parties who contact SAINT LUCIA, through any of the contact channels made available through this website for the purpose of receiving inquiries and/or requests from interested parties (for example, Contact Form, Download of reports), will be processed for the purpose of maintaining contact between the parties, carrying out the requested management of the interested parties, processing their requests or inquiries, providing service to the interested party through channels enabled to this is done through our website.
Data processed for this purpose: identification and contact data and other types of data; exclusively in the event that the interested party provides them through the free text fields made available in the forms available on the web. In any case, SAINT LUCIA informs you that it will only treat this category for the specific purpose of the consultation carried out.
Basis of legitimation: the execution of the legal relationship established between the interested party and SAINT LUCIA, that is, in the management of the request itself, in maintaining contact between both parties and, where appropriate, in the provision of the service that the interested party has requested, as well as, if necessary, the requested consent.

2. Sending the newsletter.

Description of the purpose: Send the newsletter with general and promotional information that may be of interest to you by electronic means (email, SMS and other electronic communication) regarding updated information and any of the services that Santalucía sells, only if you have given your consent.
Data processed for this purpose: identification and contact data.
Basis of legitimacy: The consent we have requested from you.

3. Registration for CHALLENGES. Programs-projects for accelerating innovative projects - InsurTech.

Description of the purpose: The personal data of interested parties who contact SAINT LUCIA through this form will be processed for the purpose of studying their enrollment in the different programs and projects enabled by the Company, maintaining contact between the parties.
Data processed for this purpose: identification and contact data, personal characteristics and other types of data; exclusively in the event that the interested party provides them through the free text fields made available in the available form. In any case, SAINT LUCIA informs you that it will only treat this category for the proper purpose of enrollment and subsequent development of the program.
Basis of legitimation: the execution of the legal relationship established between the interested party and SAINT LUCIA, that is, in the maintenance of contact between both parties and, in this case, in the subsequent development of the program or project, as well as the consent granted to be part of the process.

The interested party may object at any time to the processing of their data for different purposes using the channels enabled for this purpose by SAINT LUCIA, as detailed in the section What are your rights over your personal data when you provide us with data?
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SAINT LUCIA informs you that it will only process personal data whose legitimate basis is consent in cases where the interested party has consented to them, through the methods of obtaining consent made available by SAINT LUCIA.

In addition, interested parties are informed that when data is collected through forms made available to them, it will be necessary to provide at least those data marked with asterisks, (*), considered as necessary. Otherwise, SAINT LUCIA will not be able to manage the service or the query made.

To which recipients will your data be communicated?

In relation to data processing for the purposes indicated above, data may be communicated to the following recipients, only if necessary:

To Public Organizations and Administrations (for example, if necessary for the fulfillment of legal obligations).
Competent national or international authorities, including judicial bodies, regulatory and supervisory bodies, and State Security Forces and Bodies.

Additionally, please note that for the provision of the services made available through this Website, the intervention of third party service providers (for example, hosting and web infrastructure) is necessary, who will process your personal data under our responsibility, on our behalf and following our instructions.
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What is the storage period?

Personal data will be kept for as long as necessary to fulfill the purpose for which they were collected and to determine the possible responsibilities that may arise from that purpose and from the processing of the data until your consent is revoked or any of the rights established in current data protection regulations are exercised.

In any case, the interested party can request detailed information on the data retention periods applied in SAINT LUCIA at the address arcolopd@santalucia.es

What measures do we take to protect your personal data?

In response to SAINT LUCIA's concern to guarantee the security and confidentiality of its data, the security levels required for the protection of personal data have been adopted and the technical means at its disposal have been installed to prevent the loss, misuse, alteration, unauthorized access and theft of personal data provided through the website. In any case, you should keep in mind that internet security measures are not impregnable.

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What are your rights when you provide us with your data?

SAINT LUCIA informs you that you have the right to obtain confirmation as to whether we are processing personal data that concerns you or not.
In the same way, SAINT LUCIA informs you that you have the following rights over your personal data:

Access your data: You have the right to access your data to know what personal data we are processing that concerns you.
Request the rectification or deletion of your data: Under certain circumstances, you have the right to rectify those personal data that you consider to be inaccurate and that concern you, and that are subject to processing by SAINT LUCIA, as well as the right to request the deletion of your data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
Request the limitation of the processing of your data: Under certain circumstances, you have the right to request us to restrict the processing of your data, in which case we inform you that we will only keep the data for which you have requested limitation of processing for the exercise or defense of claims.
To the portability of your data: Under certain circumstances, you have the right to receive the personal data that concern you, and that you have provided to us, in a structured format for common use and machine reading, as well as to have them transmitted by SAINT LUCIA to another data controller.
Oppose the processing of your data: Under certain circumstances and for reasons related to your particular situation, you have the right to object to the processing of your data, in which case, we would stop processing them unless we must continue to do so for compelling legitimate reasons or for the exercise or defense of possible claims.

We also remind you that you have the right to object, at any time, to the sending of advertising for services, as well as to withdraw any of the consents you may have given for the processing of your data, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

The only commercial communications that will be made by email will be those that have been expressly consented to or authorized by the recipients in accordance with Law 34/2002, of July 11, on Information Society Services and Electronic Commerce, except as provided for in article 21.2 of Law 34/2002, on Information Society Services and Electronic Commerce in the wording given by the second Final Provision of the General Telecommunications Act, that is, when there is a contractual relationship preview.

SAINT LUCIA informs you that you can exercise your rights over your personal data through any of the following ways:

In writing addressed to SANTA LUCÍA S.A., Insurance and Reinsurance Company, at the postal address Plaza de España, 15 28008 Madrid for the attention of the Privacy Department.
Email address: arcolopd@santalucia.es

SAINT LUCIA will provide you with the information within a maximum period of one month from the receipt of the request. This deadline may be extended by two months if necessary, taking into account the complexity and number of requests.

In case of reasonable doubts when identifying the interested party, additional information may be requested, including a copy of their national ID, NIE, Passport or equivalent document on both sides.

If you do not agree with the way in which your information is used or with our response to the exercise of any of these rights, you can contact the competent Data Protection Supervisory Authority if you believe that we have committed a breach. However, in the first instance, you may file a complaint with the Data Protection Officer at the address provided above.

For additional information about your rights, visit the website of the Spanish Data Protection Agency (https://www.aepd.es/).

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September 2024