Privacy Policy

AXA PARTNERS is committed to maintaining the privacy of the personal data obtained in the course of its business activity and consequently complying with the applicable legislation on Personal Data Protection, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("General Data Protection Regulation" or "GDPR").

AXA PARTNERS, in the context of the provision of its products and services, needs to collect some personal data from its customers. In this sense, this Privacy Policy aims to help its customers understand the personal data we collect, how and why we use it, to whom we disclose it and how we protect their privacy when providing our products and services

We will only process personal data that is appropriate and relevant, limited to what is necessary in relation to the purposes for which it is collected, and your data will be processed lawfully, transparently and collected for determined, explicit and legitimate purposes as detailed in this policy.

  

1-Data controllers

References in this Privacy Policy to "AXA PARTNERS", "AXA", "we", "us" or "our" mean the following entities:

·  INTER PARTNER ASSISTANCE S.A – Portugal Branch, permanent representation at Avenida da Liberdade 38, 7th floor, 1269-069 Lisbon, Registration/ Legal Person 980055563, CRC Lisbon. ASF Registration 1056  www.asf.com.pt. This entity provides the following services:  travel and home assistance services and legal protection.

  · AXA FRANCE IARD – Branch in Portugal, permanent representation at Avenida da Liberdade 38, 7th floor, 1269-069 Lisbon, Registration/Legal Person 980628121 CRC Lisboa. ASF Registration 1204  www.asf.com.pt. This entity provides the following types of services: provision of coverage related to credit protection insurance.

  · AXA FRANCE VIE – Branch in Portugal, permanent representation at Avenida da Liberdade 38, 7th floor, 1269-069 Lisbon, Registration / Legal Person 980628156 CRC Lisboa. ASF Registration 1203  www.asf.com.pt. This entity provides the following types of service: provision of coverage related to credit protection insurance.

  · AXA ASSISTANCE – SERVIÇOS PORTUGAL S.A, registered/Legal Person 502297336 CRC Lisboa. This entity provides the following types of services: car assistance, medical assistance, home.

 

Each entity will act as a Data Controller (as defined in the GDPR), to the extent that it individually defines the purposes and means of the processing in relation to data processing operations related to the provision of its insurance products and services.

  

2-Purposes of the Processing

AXA PARTNERS collects and processes the data for the following purposes, and on the following legal grounds:

 

· Supply of products and services, namely when you take out insurance. In certain situations, it will be necessary to process your health data. In this case, before we process this type of data, we will collect your consent to do so.

 

The legal basis applicable to the processing of your personal data is the performance of a contract to which the data subject is a party, and the fulfilment of legal obligations to which we are bound.

 

Regarding the processing of your health data, the applicable legal basis is your consent. This consent may be revoked at any time, without, however, making the processing of personal data carried out on the basis of this consent unlawful until the date on which it is revoked. In this case, failure to provide your consent will prevent us from providing you with the service you wish to hire.

 

· Claims Management

 In certain situations, it will be necessary to process your health data. In this case, before we process this type of data, we will collect your consent to do so.

The legal basis applicable to the processing of your personal data is the performance of a contract to which the data subject is a party and the fulfilment of legal obligations to which we are bound.

Regarding the processing of your health data, the applicable legal basis is your consent. This consent may be revoked at any time, without, however, making the processing of personal data carried out on the basis of this consent unlawful until the date on which it is revoked. In this case, failure to provide your consent will prevent us from analyzing the claim, and following up on it.

 

· Conducting satisfaction surveys

 In this case, the applicable legal basis is the legitimate interest of AXA PARTNERS in knowing the opinion of its Clients and, in this sense, seeking to improve and adapt its services to their needs.

 

· Complaints management

 In this case, the applicable legal basis is the legitimate interest of AXA PARTNERS in providing you with a personalized and quality service, as well as managing the complaints submitted.

 

· Recording of calls for the purpose of monitoring the quality of the service and proof of communications relating to the contractual relationship.

 

The applicable legal basis is your consent. This consent may be revoked at any time, without, however, making the processing of personal data carried out on the basis of this consent unlawful until the date on which it is revoked. In this case, failure to provide your consent will prevent us from processing your request by telephone, so you must use another means of contact, namely: pt.assistencia@ip-assistance.com (products relating to INTER PARTNER ASSISTANCE S.A and AXA ASSISTANCE) and clp.pt.sinistros@partners.axa   (products relating to AXA FRANCE IARD and AXA FRANCE VIE)

  

3-Personal data processed

 Within the scope of the purposes described in the previous point, we will process the following personal data (example list):

· Name (of the policyholder and any other persons who may benefit from the insurance covers);

· Address and contact details, including email address and phone number;

· Coverage and policy details;

· Data related to the subscribed product, such as policy, profession, data related to the vehicle, taxpayer number, date of birth, citizen card, travel date;

· Information about your health (in these cases the customer will be duly informed of the obligation to provide this data. Applicable when subscribing to insurance products that presuppose the processing of this data);

· Payment details or bank details (for payment of insurance premiums and reimbursements related to the coverage contracted);

· Claims information;

· Information about other Insured Persons and Beneficiaries (when providing data from third parties, when subscribing to insurance products, you must make sure that you have been authorized by them, as well as inform them about how AXA PARTNERS processes personal data, under the terms of this Policy;

· Your opinion of us;

· When you make a complaint;

· Call recording.

 

 4-Automated decision making

 No automated decision-making is carried out for the processing described in this privacy policy

  

5-Data Retention

 AXA PARTNERS will keep personal data for the following periods:

· Provision of its products and services, namely when you take out insurance.

Your data will be kept for this purpose until the end of the legal limitation period for all obligations arising from the insurance contract.

 

· Claims Management

Your data will be kept for this purpose for the duration of all legal obligations arising from the insurance contract

 

· Conducting satisfaction surveys

Your data will be kept for this purpose for 3 years.

 

· Complaints management

Your data will be kept for this purpose for 5 years.

 

· Recording of calls for the purpose of monitoring the quality of the service and proof of communications relating to the contractual relationship.

Your data will be kept for this purpose for the following periods:

· As it comes to the recording of calls as part of the monitoring of the quality of service, the recordings will be kept for a maximum period of 30 days.

· In the case of the recording of calls, for the purposes of proving communications relating to the contractual relationship, the recordings will be kept for the duration of the contractual relationship, or until the fulfilment of all obligations arising from the contract.

 

· Marketing communications

Your data will be kept for this purpose for 4 years or until you withdraw your consent.

 

Without prejudice to the periods indicated herein, the data may be kept for longer periods for the purposes of exercise or defense in the context of administrative or judicial actions. In this case, the personal data will be blocked for as long as the administrative or judicial action lasts, and after this period they will be deleted.

  

6-Recipients of the data

 AXA PARTNERS, within the scope of its activity, may use third parties to provide certain services. Sometimes, the provision of these services implies access, by these entities, to the personal data of the Customers, which have been entrusted to it, and therefore undertakes to restrict this access to the extent necessary and to take appropriate security measures.

 

The subcontracted entities will process the personal data of AXA PARTNERS' Clients, in the name and on behalf of AXA PARTNERS and must also adopt the necessary technical and organisational measures in order to protect the personal data against accidental or unlawful destruction, accidental loss, alteration, dissemination or unauthorised access and against any other form of unlawful processing.  which will be duly enshrined in a contract to be signed between AXA PARTNERS and the third party(ies).

 

Transfers may be made to the following third parties:

· The Reinsurance Company to whom the risk of the policy is assigned

· Service Providers: We may transmit certain data to our third-party service providers (such as legal advisors, experts, independent clinical advisors, taxi companies, trailers) and distributors of our products. In all cases, we will require our service providers to whom personal data is transmitted to ensure compliance with our privacy policy and to use the personal data exclusively for the purposes for which it was collected. The transmission of personal data to service providers is intended to improve the service provided.

· Judicial and administrative authorities to comply with a legal obligation.

· Group Companies: We may share personal data with other Group companies for the purposes best identified in this Privacy Policy.

· Regulators and sectoral associations or public bodies.

 

AXA PARTNERS may also communicate your personal data to judicial or administrative authorities, provided that it is in compliance with a legal obligation and also, without prejudice to the duties and limits provided for in terms of personal data protection and competition, and always subject to the duty of confidentiality, to entities of the associative type, namely the Portuguese Insurance Association,  that legally frame or carry out data collection actions, actions to prevent and combat fraud, market studies or statistical or technical-actuarial studies, as well as companies of the AXA Group, to which it belongs.

  

7-International Data Transfers:

The implementation and provision of certain services by AXA PARTNERS may imply the transfer of your data outside Portugal, namely for the provision of assistance services abroad, but in such case the applicable legal provisions will be observed, namely regarding the determination of the suitability of such country with regard to the protection of personal data and the requirements applicable to such transfers,  namely through Binding Corporate Rules.

 

In view of the above, your data may be communicated to Group entities located outside Portugal or the European Economic Area, and these transfers will be carried out under the binding corporate rules of the AXA Group (Binding Corporate Rules), to which we adhere, and which guarantee an adequate level of protection equivalent to that of the European Union,  which you can consult through the following link: https://www.axa.com/en/commitments/our-commitments (at the bottom of the web page).

 

Your rights

In accordance with data protection legislation, you have the right to:

· Object to the processing of your personal data;

· Request the change of your personal data;

· Request the erasure of your personal data;

· Receive a copy or be transmitted a copy to another company (data portability) (in a machine-readable format) of the personal data you have provided to us.

· File a complaint about the way we process your data with the National Data Protection Commission ("CNPD").

· Withdraw any consent you have given us regarding the use of your data at any time. This includes consenting to receive direct marketing communications.

 

Please note that there are certain limitations and exceptions to these rights that we may apply depending on the circumstances.

 

For requests to exercise these rights (specifying your request) or if you wish to obtain additional information about them, you should use the contacts indicated below taking into account the insurance product contracted:

 

Entity: INTER PARTNER ASSISTACE S.A – Branch in Portugal and AXA ASSISTANCE – Serviços Portugal, S.A,

Address: Avenida da Liberdade nº 38, 7º, 1269-069 Lisbon.

Data Protection Officer: protecaodados@ip-assistance.com

 

Entity: AXA FRANCE VIE – Portugal Branch and AXA FRANCE IARD – Portugal Branch

Address: Avenida da Liberdade nº 38, 7º, 1269-069 Lisbon.

Data Protection Officer: clp.pt.dataprivacy@partners.axa

  

8-Personal Data of Minors

We only present insurance offers or service contracts that involve the collection of personal data from minors under the age of 18, with the express and explicit consent of their parents and legal representatives, and exclusively for the purposes of the execution of these contracts. We will cancel the policy or service contract and refund the premium or refund the payment and delete the personal data when a parent or legal representative informs us that the personal data has been collected without their consent.

However, some information about minors may be collected and used in connection with a claim or provision of the service, when it is relevant to assess the circumstances of the claim or the provision of services and the associated vulnerabilities.

9-Marketing Preferences 

With your consent, we may send you direct marketing communications, and for this purpose, in certain situations, we will share your Personal Data with companies that provide Telemarketing services, which will act under the instructions of AXA PARTNERS. You can cancel this authorization at any time by contacting us by e-mail: clp.pt.dataprivacy@partners.axa or +351 217 993 652 (call to the national fixed network).

 

In addition, we offer you several cancellation options:

· Emails: If you no longer wish to receive emails with commercial information, you may unsubscribe from the link in each email or by contacting us as stated above.

· Text messages/phone contacts/mail: You may unsubscribe by contacting us as mentioned above.

 

Please note that if you request to unsubscribe, it may not be possible to remove your Personal Data from the databases of third parties with which this data has already been shared. Even if you request to unsubscribe from marketing communications, we may still send you administrative communications.

 

10-  Data security

AXA PARTNERS has implemented several security measures, of a technical and organizational nature, in order to protect the personal data made available to it against its dissemination, loss, misuse, alteration, unauthorized processing or access, as well as against any other form of unlawful processing.

 

Notwithstanding the security measures implemented, we point out that as the Internet is an open network, data may circulate on the network without security conditions, even running the risk of being seen and used by unauthorized third parties for this purpose.

 

11-  Changes to this Privacy Policy

We encourage you to periodically check this Privacy Policy to be aware of any changes. Although we reserve the right to modify or supplement this Privacy Policy, we will inform you of any material changes at least 30 days after the change.

 

The practices and policies included in this Privacy Policy supersede all prior notices and statements relating to the same subject matter.

 

Last updated: 05/11/2025