INFORMATION UNDER ITALIAN LEGISLATIVE DECREE N.196/03

Protection of personal data

Pursuant to Art. 13 of Legislative Decree n. 196/2003 (“Privacy Code”) we hereby inform you that all personal data supplied by you or otherwise acquired in the course of our business activity may be utilised in compliance with the aforesaid legislation and relevant confidentiality restrictions.

1.(a) Any personal data will be utilised for corporate purposes connected with or instrumental to corporate activity, such as:
mediation with insurance or reinsurance companies performed in your best interests following receipt of written or verbal instructions from you;
any operations prior to the drafting of any agreement carried out on your orders;
performance of any contractually agreed service or operation;
fulfilment of legal obligations deriving from the execution or management of agreement entered into with our assistance and regarding coverage of insurance risks;
compliance with any rule or provision issued by any authority or watchdog in the insurance field;
any operation or management transaction required for the execution of the agreement.

The use of data for the above-mentioned purposes may also involve so-called “sensitive data”, i.e. personal data which may reveal racial or ethnic background, religious affiliations, ideology or other beliefs, political orientation, membership of parties, union organizations, associations or organizations of a religious, philosophical, political or union kind, as well as personal data that may reveal details of state of health and sexual life.

1. (b) Personal data will also be used for the following purposes:
- monitoring the development of customer relations and/or related risks;
- operational and strategic marketing.

2. Means of data use will ensure appropriate data safety and confidentiality and may also be performed with the help of electronic or other automated devices capable of storing, managing and transmitting such data.

3. Please also be informed that any personal data supplied by you to us or otherwise acquired in the course of our business activity is not subject to disclosure, but may be communicated (for the purposes set out in point 1.(a) above) to the following:
insurance agents, including but not limited to: insurers, agents, co-insurers, reinsurers, experts, legal counsel, specific associations (ANIA – Italian Association of Insurance Companies) and syndicates of the insurance industry, IVASS (insurance watchdog institution), Ministry of Industry, Commerce and Craft;
companies, entities, consortiums and persons providing processing services or any activity connected therewith or instrumental to or supporting our corporate activity, or any activity required for the execution of any operations or services requested by you or which you may request in the future;
persons entitled to access your personal data under any provision of the Law or EU legislation;
any persons to whom the transfer of your personal data is necessary or in any way useful for the execution of our company’s business activities;
other companies belonging to our group.

4. Any data supplied by you or in any way referable to you may be disclosed by us to any company we represent in Italy (both EU companies, in particular British companies, and non-EU companies) under the terms and conditions set forth in Articles 42 and 43 of the Privacy Law, if such transfer is required for the execution of any obligation deriving from the agreement to which you are a party or to fulfil, before conclusion of the agreement, specific requests on your part, as well as for the conclusion or performance of any agreement entered into in your favour.

5. The supply of personal data is generally facultative, except for any case in which it is required under any provision of the law (such as rules and regulations on money laundering, Central accident registry, Department of motor vehicles) or for the execution of the insurance contract.

In the event of legislative or contractual obligations to supply personal data, your refusal to supply the relevant data may be in violation of the rules establishing such obligation (including sanctions imposed against you), and in any such case our company may not perform any operation that presupposes the use of the aforesaid data, with direct consequences in the coverage procedure of any risks referable to you, any consequence or damage being at your charge.
The provision of sensitive data concerning a person’s state of health is mandatory for the conclusion of some types of insurance policies (such as health care, life, permanent disability from illness) and for the management of some kinds of insured events, and your refusal to provide it therefore makes entering into and executing any such contracts impossible.
Any refusal to supply data which is useful for the execution of our business but not among that required or strictly instrumental to the performance of our contractual relationship may prevent the execution of any such further activity but will not interfere with the existing contractual relationship.

6. We hereby also inform you that, with respect to the use of data as explained above, you are entitled to:
(i) be informed upon request as to the existence of any personal data regarding you, even in the case of it not yet having been recorded, and its communication to you in an intelligible form;
(ii) obtain information as to:
a) the source of the personal data;
b) the goals and means of data usage;
c) the logics applied in the case of usage carried out via electronic means;
d) the identification data of the data controller, of the data supervisor and of the representative appointed pursuant to Article 5, paragraph 2;
e) the persons or categories of persons to whom personal data may be communicated or who may become aware of the same in their capacity as designated representatives in the territory of the State, persons in charge or agents;
(iii) to be informed of:
a) the updating, correction or (in the case of your being interested) supplementation of the data;
b) the cancellation, transformation into an anonymous form or blocking of any data used in breach of law, including that data for which storage is not required in relation to the goals for which it was  originally collected or subsequently processed;
c) certification that the transactions covered in points a) and b) above have been brought to the knowledge (also with respect to their content) of those persons to whom such data have been communicated or disclosed, except for any situation in which the above is impossible or would require a use of means clearly disproportionate to the protected right;
(iv) oppose, in whole or in part:
a) (for legitimate reasons) the use of any personal data regarding you, even if such data is relevant to the aim of the collection;
b) the use of any personal data regarding you for the purposes of sending you any advertising materials or direct marketing or for the execution of market research or commercial information.

7. Personal data are stored at the headquarters of the Firm in the premises of MAG-JLT with registered offices in Naples.
Legal representative: Pierluca Impronta
Please address any correspondence concerning issues of privacy to: rosalba.impronta@magjlt.com