Privacy Policy atHome Insurance


at atHome Assurance we respect and protect your privacy and believe that transparency is the key to good governance of personal data.

This Privacy policy explains what data we collect about you and how we use it, as well as the rights you have and how you can exercise them. We undertake to implement all appropriate means to preserve the confidentiality and integrity of your personal data.

I. Who are we?

    1. Contact details Data Controller
atHome Assurance Sàrl is a brokerage company, registered with the RCS of Luxembourg under number B 249624. It is approved as a broker with the Commissariat aux Assurances de Luxembourg under number 2022CM001 and appears in the "Register of authorized brokerage companies in the Grand Duchy of Luxembourg".

atHome Assurance Sàrl collects your personal data on its own behalf, as data controller.

    2. Contact details Group Data Protection Officer
Email: privacy@athome.eu
Post: 5, rue Charles Darwin L-1433 Luxembourg, Grand Duchy of Luxembourg

II. What personal data do we collect?

Only personal data strictly necessary for the achievement of the purposes mentioned below will be processed. In the context of our activities, and depending on your particular situation and in the context of your life and/or capitalization insurance, we may process the following data:

  • Identification data (surname, first name, gender, date of birth, nationality, etc.);
  • Contact data (email address, mobile and/or landline telephone number, postal address, etc.);
  • Marital status.
  • Financial data and patrimonial information (list of movable and immovable assets, etc.)
  • Data related to the profession (functions performed);
  • Household composition (e.g. number of children, etc.);
  • Information regarding connection, geolocation and/or browsing data (for example, the location data, the device identification, etc.);
  • Commercial information (for example, if you want to receive communications or newsletter by email from the Group);
  • Information about your preferences;
  • And any other information you spontaneously provide to us.
We may also use data obtained from external sources, in particular in the following cases:

  • The data obtained by the financial partner (bank, financial manager, family office) who contacts the "broker" with a view to collaborating on your file and this in complete transparency with you;
  • Updating data (e.g. concerning the composition of your family, your address, your expired identity document, etc.)
In some cases, we may use personal data relating to people other than you, for example:
  • your ascendants, your children, your partner, the beneficiary(ies) of your life insurance.
  • your employees, your legal/statutory representatives, your shareholders/partners.
If you provide us with such data, you undertake to inform the persons concerned.

We will not collect or process any special category of Personal Data. In case of request by Insurance Companies, such special categories of personal data will exclusively be collected and used to the extend necessary for allowing us to ensure the proper performance of our services with the Insurances companies. In that case, we will provide you a specific document to sign.

Remember that, when we ask you to fill in your personal data to give you access to any functionality or service of the website etc., we will mark certain fields as compulsory, since this is information that we need to be able to provide the service or give you access to the functionality in question. Please consider that, if you decide not to make such data available to us, you may be unable to complete your user registration or may not be able to enjoy those services or functionalities.


III. How do we use your personal data?

1. For what purposes and on what legal basis do we use personal data?

We will first use your personal information to perform our contractual obligations to you or in order to take steps at the request of the data subject prior to entering into a contract, including to provide you with the services expected as part of our role as an insurance intermediary, such:

    →allow you to contact us via our contact, complaint forms or to make an appointment with our insurance broker/advisor.
    →determine your requirements and needs (and in the context of life insurance-based investment products, your full investor profile).
    →submit to you documentation relating to the products for which you have requested our assistance and assist you in the management, conclusion and execution of a life insurance contracts.
    →provide you the customer support services through different channels.
We may also use your personal data to comply with our legal obligations, in particular with regard to:

  • prevention of money laundering and terrorist financing;
  • insurance distribution;
  • our tax accounting obligations.
Based on our legitimate interest, we may process your information in order to:

  • manage our customers and have a global view of customers (for example by compiling statistics of our customers in order to know who they are and to know them better, performing surveys to improve the quality of our services etc.).
  • prevent abuse, fraud, and infringement.
  • ensure the security of the company's property and people, as well as networks and IT systems
  • establish, exercise, defend and preserve the rights of the company or the persons it may represent, for example in disputes.
  • propose you by email similar goods or services that you have contracted with atHome Assurance that could be of your interests.
  • Usability and quality analysis. - We consider that we have a legitimate interest in analyzing the usability and degree of user satisfaction as we understand that the processing of this data is also beneficial to you because the purpose is to improve the user and customer experience and to offer a higher quality service.
Based on your consent, we may process your information to:

  • receive communications regarding products and services that we offer in atHome Assurance - if the advertising does not refer to similar goods or services you have already contracted with us or received from us by email and other electronic mail and to be able to make recommendations based on your interaction with us.
  • receive communications from the entities within the group (atHome Group S.a.r.l., atHome Finance S.a.r.l., atHome Assurance S.a.r.l and Taxx S.a.r.l.) With your consent, you will receive by email, communications regarding insurance products, real estate services, finance services and Taxx services which could be interesting for you.
  • To provide you with and assist you in any services of interest to you that are offered by entities of the group such as atHome Group S.a.r.l, atHome Assurance S.a.r.l and Taxx S.a.r.l. In this case, if you have given your prior consent, our Brokers will share some of your personal information with the relevant group department or entity in order to provide you with these services.
  • receive the newsletter from the Group if you have subscribed to it.
Remember that you can withdraw your consent at any time and free of charge through the indications we provide you with in each communication.

We may not use your Personal Data for new purposes which are as yet unforeseen in this Privacy Notice except on the basis of an applicable statutory permission or your valid consent. In any event, prior to using Personal Data for other purposes, we will inform you about such change to this Privacy Notice and in case of consent-based activities, we will offer you the chance to decline participation in these changes.

2. Do we use your personal data to make automated decisions?

We do not use your data for profiling purposes or to make automated decisions. If we decide in the future to do so, we will inform you in advance and explain the logic behind such decision-making and the significance and intended consequences of such processing.

IV. Why is it necessary to provide us with your personal data?

If you refuse to provide us with the data requested in connection with certain services (such as, for example, assistance in concluding a life insurance contract or in the event of a claim), we may be unable to fulfil our role as an intermediary or to comply with your requests.

V. Where and how do we transfer your personal data?

1. Who has access to your personal data and to whom is it transferred?

In order to protect your privacy, the people who are authorized to access your data are precisely determined according to their tasks.

In order to achieve the purposes detailed above (see point 3.1), we are however required to communicate certain information to third parties:

  • insurance companies with which you wish to receive a proposal or with whom you wish to conclude a contract.
  • for the proper performance of our intermediary missions, your data may be transmitted to and/or processed by our IT subcontractors.
  • in order to comply with our legal obligations, your data may be transmitted to the authorities and our regulator.
  • in the event of a dispute, your data may be transmitted to our lawyers and used to defend our case in court.
  • If this is necessary to pursue the purposes mentioned above, your personal data may also be communicated or made available to other entities within the group of which at Home Assurance is a member for internal administrative purposes.
2. Where do we transfer your personal data?

Under no circumstances will we transfer your personal data outside the EEA.

VI. How long will your personal data be kept?

We will keep your data for as long as:

  • it is necessary for the achievement of the purposes detailed above.
  • a legal obligation imposes such retention (e.g., retention of accounting records, insurance regulations etc.).
  • the applicable limitation periods will not have elapsed, in order to ensure that we have the necessary information to protect ourselves from any legal action.
  • For customer support services, we will process your data for the time necessary to meet your request or application.
  • ForAnalysis of usability and quality, we will process your data occasionally for the time during which we proceed to carry out a specific quality action or survey or until we anonymize your browsing data.
  • We will process your data until you unsubscribe or cancel your subscription the communications.

VII. What are your rights and how can you exercise them?

We undertake to keep your personal data confidential and to ensure that you may exercise your rights. Bearing that in mind, you may exercise your rights free of charge by writing us an e-mail to our e-mail address (privacy@athome.eu), simply informing us of the reason for your request and the right that you wish to exercise. If we consider this necessary to be able to identify you, we may request you to provide a copy of a document evidencing your identity.

Below is a brief description of these rights.

Right of access - You may, at any time, obtain confirmation as to whether or not personal data concerning you are being processed and, where applicable, access to such data.

Right to rectification - You may, at any time, by sending us a written request, obtain the rectification of personal data concerning you that is inaccurate. You can, in the same way, request that incomplete data be completed.

Right to erasure - You may, at any time, by sending us a written request, obtain the erasure of your personal data.

Right to restriction of processing - Where restriction of processing is granted, personal data may only be processed with the consent of the data subject, or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for important reasons of public interest.

Right to object - You have the right to object, at any time and by sending us a written request, on grounds relating to your particular situation, to the processing of your personal data based on the legitimate interests we pursue. We will no longer process this personal data unless it is demonstrated that there are compelling legitimate grounds for the processing that override your interests and rights and freedoms, or for the establishment, exercise, or defense of legal claims. When your personal data is processed for direct marketing purposes, you have the right to object to this processing at any time.

Right to portability - You have the right, by sending us a written request, to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, and to transmit this data to another controller.

Right to withdraw consent - Where processing is based on your consent, you have the right to withdraw consent at any time by sending us a written request. The withdrawal of your consent will not affect the lawfulness of the processing based on the consent made before the withdrawal of it.

Right to lodge a complaint - We make our best efforts to ensure compliance with our legal data protection obligations and to respond as quickly as possible to any complaint addressed to us in this regard. In the event that you are not satisfied with the response received, you have the possibility to lodge a complaint with the Data Protection Authority.

National Commission for Data Protection
15, boulevard du Jazz
L-4730 Esch-sur-Alzette
Phone: (+352) 26 10 60 -1
https://cnpd.public.lu/fr/support/contact.html

VIII. Data Security

atHome Insurance undertakes to ensure the protection and security of Personal Data, in order to ensure the confidentiality of Your Personal Data and prevent Your Personal Data from being distorted, damaged, destroyed or disclosed to unauthorized parties or used in an unlawful manner.

atHome Insurance maintains adequate physical, electronic, and procedural safeguards to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration, and destruction. As part of those safeguards, atHome Insurance employs sophisticated technology designed to protect Personal Data during its processing and prevent processing errors or unauthorized acts of third parties.

IX. Information on cookies

We use cookies to facilitate your browsing in the Platform, understand how you interact with us and, in certain cases, to be able to show you advertisements in accordance with your browsing habits.

Please read our Cookies Policy to understand with greater detail the cookies that we use, their purpose, how to manage your preferences, as well as other information of interest.

X. Changes of the privacy notice

We may amend the information contained in this Privacy Policy when we consider this appropriate.

We suggest you review this Privacy Policy from time to time in case minor changes are made or we make any interactive improvement, taking the opportunity that you will always find it as a permanent point of information on our Website and our App.