Privacy is a core concern of Foyer Group. We undertake to protect and process your personal data in strict compliance with regulations and with complete transparency.
This privacy statement will give you confidence when you visit our website www.foyer.lu and use the services offered there.
Whose personal data is processed?
The personal data of the following can be processed by Foyer Group ( Foyer Assurances SA, Foyer Vie SA, Raiffeisen Vie SA, Foyer Santé SA, Foyer Arag SA, Foyer International SA ):
- All individual customers,
- All other people involved in processing linked to a
transaction as representatives, partners, suppliers, administrators, employees,
legal representatives or any other guarantor or contact person.
This statement does not concern legal entities.
What data is covered by this statement?
All information directly or indirectly relating to an identified or identifiable person.
This particularly concerns in the context of your relations with Foyer
data, surname, first name, home address, email address, telephone number, etc.
necessary for the standard conclusion of insurance policies taken out: value of
your real estate, salary, etc.
concerning personal characteristics such as age, sex, lifestyle, consumption,
data (GPS, route) in connection with specific insurance policies
data as part of the calculation of a score to be applied to an insurance
premium for a specific product
In accordance with the regulations, we do not collect data relating to the specific category set out in article 9 of Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data except in connection with the exceptions set out under point 2.a to obtain the person’s consent, the exception set out under point 2.b relating to the processing of data in relation to the contractual execution in respect of social protection and point 2.g relating to the pursuit of a public interest. Unless there is a legal basis or legal exceptions, these data include the health data for the precontractual and contractual purposes of the data controllers as well as for compensation for personal injury claims by the data controllers in the pursuit of a public interest.
Why do we need to process
your personal data?
We undertake only to process the data required for the intended purposes
of the process (minimisation and proportionality of the data).
More generally, we will use your personal data:
- In connection
with the pre-contractual steps taken by Foyer Group
- In the context
of contractual performance, the management of insurance contracts and claims
- In the
framework of our compliance with the legal and regulatory provisions to which
we are bound and subject
- In connection
with data processing for which we have obtained your explicit consent
- In connection with data processing linked to the
preservation of legitimate interests such as the prevention of and fight
- Our customer service management
- The management of the commercial relationship
- The management of disputes and debt collection
- Claims management
- The management of the commercial prospect based:
- , on the legitimate interests of the data controllers informing
you of similar or complementary products or services to the set of needs for
which a commercial relationship exists,
on your consent to receive customised offers and information and/or to
be informed about innovations, tax benefits and news relating to insurance; you
may withdraw consent to direct marketing at any time in accordance with the
procedures set out under point 9 relating to exercising your rights.
Sharing personal data with Foyer agencies
FOYER shares personal data with its network of agencies and subcontractors in compliance with the provisions of professional secrecy pursuant to article 300 of the Law of 7 December 2015 on the insurance sector and obligations relating to the sub-contracting of personal data processing set out in article 28 of the GDPR.
Passing data to third parties
may pass your personal data onto its service providers, suppliers and brokers
when managing insurance policies.
capacity as insurer, in certain circumstances, the Group may provide certain
personal data to other insurers, reinsurers, insurance or reinsurance brokers
and other intermediaries and agents, lawyers, experts/technical advisors, repairer
, medical consultants, auditors, IT service providers, business partners,
government and mediation authorities located in the Grand Duchy of Luxembourg
Your data may
be passed on to public or regulatory authorities or courts.
personal data may be stored on cloud servers managed by a third-party hosts in
relation to certain products, in accordance with the stipulations contained in
the general or specific terms and conditions of the products concerned. You are
informed of this transfer when you take out this product, for which you have
accepted the terms and conditions.
The Group will not pass on your data for any commercial purposes without
your prior consent.
may transfer your personal data outside the European Union, provided it
ensures, before the transfer, that the entities outside the European Union
offer an adequate level of protection, in accordance with European legislation.
may also be required to transfer your personal data to third parties if the
Group considers that such a transfer is necessary for technical reasons (for
example, for hosting services by a third party or the execution of a contract)
or to protect its legal interests.
may communicate your personal data if required to do so by law or if the Group
considers in good faith that such disclosure is reasonably necessary in order
to comply with a legal procedure (for example, a mandate, a subpoena or any
other legal decision) or to protect the rights, assets or personal safety of
the Group, our customers or the public.
Foyer Group implements all appropriate technical and organisational measures to ensure a level of security suited to the risk posed by the processing concerned.
Foyer Group companies keep your personal data
- For as long as needed for the purpose for which the data was collected or for which it was used for additional processing
- As long as required to comply with applicable legal obligations
- As long as required to comply with legal prescription periods.
Right of access, deletion, correction, objection, limitation and portability
As a data subject,
have the right to access your data as well as information about the purpose of
the processing for which your data is collected, the categories of data
concerned, the recipients of your data and their retention period.
have the right to correct, delete or block your personal data if it is incorrect,
incomplete or processed for purposes not provided for by the pre-contractual,
contractual or legal measures or those granted by you.
- You have the right to object, except for legitimate and compelling reasons.
- You have the right to limit or restrict the processing of your personal data under the conditions provided by the regulations.
- You have the right to the portability of your personal data,that is to say the provision of personal ata about you stored in a structured format (as of 25 May 2018 under the terms and conditions defined).
You have the option to withdraw your consent at any time by modifying
your personal preferences in your account or completing our form available on
You have the right to access, change, correct, delete, limit as well as
obtain and reuse your personal data and to oppose the processing of your
personal data within the legal limits.
To exercise your rights,
- you can complete the
form available on our website attached
to a copy of your identity card by email to the following address email@example.com
- alternatively, send us a complaint by post to the Customer
Service or directly to the Data Protection Office, Foyer Group, 12 rue Léon
Laval, L-3372 Leudelange. Postal address: L-2986 Luxembourg.
for claiming rights to your personal data
order to correctly identify your complaint and to be able to respond to it as
possible, please send us your complete, dated and signed application
accompanied by a copy of your identity card. You can lodge a complaint with the
supervisory authority: The National Data Protection Authority (CNPD) 15,
Boulevard du Jazz, L-4370 Belvaux.
General Policy relating to the Protection of Personal Data: Foyer Group
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