Your data is safe with us
At HD 360 Limited we value privacy and data protection. We comply with all relevant Legislations, including Regulation (EU) 2016/679 of the General Data Protection Regulation (also known as «GDPR»), which came into force on May 25, 2018 and affects the protection of all personal data we have in our possession.
What is personal data?
The term Personal Data refers to any element or information that can identify a person’s identity or contact information. This also includes cases where one’s identity can be ascertained even indirectly by reference to a factor that is unique to the physical, physiological, genetic, psychological, economic, cultural or social identity of that individual.
The purpose of this Privacy Policy is to inform you in detail about everything that concerns your personal data and HD Insurance Ltd. If you have any follow up questions, please do not hesitate to contact us.
Which categories of personal data we use?
The main categories of personal data that we use are:
Data to identify you
We may use data such as your name, surname, identification or passport number, telephone number, date of birth, email address, home address, vehicle registration number, vehicle type/model, TAX identification number, for identification purposes.
The above data may also be used for (i) communication purposes - to enable us to contact you for any of the purposes mentioned in this privacy policy (ii) calculation purposes - to calculate the quote from HD Insurance Ltd (the "Insurance Company"), based on the needs of your vehicle and the bundle you choose, always based on a legal ground as well as the privacy policy of the Insurance Company.
At a later stage, additional categories of personal data may be processed, for instance, photographic material, so as to determine and calculate the cost of any damage, wear or repair, in relation to your vehicle.
Browsing data
Your browsing data will also be processed. For example, we will use your IP address and place cookies on your browser, to offer you a better online experience on our website. More information is provided in our cookies policy.
How do we collect personal data?
Clients obtaining a quote
In order for you to get a quote for the purposes mentioned below, you need to provide us with some information that belongs to the personal data category, such as your name, address, contact details and details about your vehicle. We only ask for the personal data that is absolutely necessary. Without it, the quote cannot be priced correctly.
The collection of your personal data is done for the purpose of calculating the offer and to assist you in submitting an application, based on the services you are interested, for:
- Insurance and Road Tax
- Service and Tyres
- Repairs
- Acquiring a consumer credit (loan marketplace) from the National Bank of Greece.
By completing the above fields in the quote process, and by voluntarily communicating your personal data to us, you accept the collection and processing of your personal data by HD 360 Limited and HD Insurance Ltd respectively.
HD 360 as an intermediary with the Bank:
In addition, we may act as an intermediary for consumer credit (loan marketplace). Through our recently developed website / platform located we will assist you in applying for consumer loans and transferring the amount from the bank directly to the merchant. This service is being offered to you by HD 360 Limited, through our Greek Branch.
If you are interested in obtaining a loan via the abovementioned service, we will direct you to the cooperating credit institution, National Bank of Greece (the “Bank”) and we will only notify the Bank that we have a prospective customer for a specific loan amount without disclosing to the Bank any of your personal details. The Bank will send us the link, to which only you will have access by filling in the credentials of your e-banking in order to complete the loan application. This link belongs to the credit institution and as HD 360 we will not have access to it. Once the Bank evaluates the loan application, it will inform us anonymously about the results.
In carrying out the above-mentioned service, we will not transfer or process your personal data in any other way, other than for the purposes mentioned herein. If you would like to know more on details about how the Bank collects and/or process your personal data, please refer to the Bank’s Privacy Policy.
Other ways in which we may obtain your personal data:
- Whenever you may provide us with such data – for example during a telephone conversation with us
- We may collect your personal data from any platforms accessible by the public
- When we process data to calculate the cost of any damage, wear or repair of your vehicle, we may obtain through or transfer data to our trusted partners that provide us with valuations in relation to the damage, wear or repaid, experts and consultants.
Our goal is to offer you a quote, through the Insurance Company, based on the needs and necessities of your vehicle, to assist you in the application process and to improve our services and for this purpose the collection of the above personal data is absolutely necessary.
How do we process personal data?
We process personal data in accordance with the relevant laws and regulations. We will process your personal data only if:
- you have consented to processing for one or more purposes
- processing is necessary for the proper implementation of a contract to which you are a party or for actions that need to be taken at your request prior to the conclusion of a contract
- processing is necessary to comply with a legal obligation we may have
- processing is necessary to safeguard your vital interest or someone else’s
- processing is necessary for the performance of a duty performed for the public interest or in the exercise of public authority entrusted to us
- processing is necessary for the purposes of the company’s legitimate interests, except in cases where your fundamental rights and freedoms override those interests - in such cases, the protection of your personal data will supersede the company’s legitimate interests.
Calculation of quote
To be able calculate your offer/quote, through the Insurance Company, we evaluate the data and personal data you give us. This data is necessary to be able to calculate the quote we will offer you, through the Insurance Company, based on the insurance coverage you need.
Communication purposes
In addition, we need your personal information so that we can communicate with you when necessary. Also, in case you file a complaint we will have to contact you to obtain all the relevant information to enable us to assess your complaint or request. Furthermore, if you have obtained a quote from us we may contact you within a period of eighteen (18) months.
Marketing
With your explicit consent, we will use some of your details for marketing and market research purposes. We will use your details to send you informational material, as well as any information we believe may be of interest to you and our offers for any products we may make available. Any kind of information (email / SMS) sent to you will provide you with the option to stop receiving such information if you ever wish to cease such communication.
Remarketing
With your explicit consent, we will use some of your personal data for remarketing purposes, to display our advertisements relevant to your interests through our trusted partners. In this way we may use your data to provide you with targeted and personalised advertisements. If you have obtained a quote from us, your data will be used for remarketing purposes for a period of eighteen (18) months after the date we provided you with a quote.
What will we do if you give us false information?
If you give us inaccurate, incomplete, or false information, we may cancel our quote.
How long will we keep your personal data?
We will maintain and process your personal data for as long as it is necessary to achieve the purpose for which you originally provided the data.
Clients obtaining a quote
In the case of a quote, we will process your details to calculate the cost of your insurance. If you do not insure your vehicle with us, we will keep your data for eighteen (18) months from the date of the quote.
Clients proceeding with their Application
In case you proceed with your Application and / or you are approved by the Bank, we will maintain and process the data that is necessary for as long as your contract is valid, for our operations and your proper service. Upon the expiration or cancellation of your contract, we will keep your details for as long as required by applicable Laws and Regulations.
How is your personal data processed? What do we process?
We use automated systems to process your personal data. This means that we have systems that automatically collect, organize and evaluate the data you give us. Automated processing allows us to calculate your quote immediately (in real time) so that you do not have to wait for it.
Automated processes are controlled by our analytics department. This means that the department can perform regular checks to ensure that everything is working appropriately.
Who has access to your personal data?
Access to this data is only available to those who need access, with the sole purpose of serving you.
The customer service department will refer to your information if you have any questions and if you need help. This is also the department that will collect your data if you choose to get a quote over the phone.
If you have a complaint, the complaints team will also need access to some of your data to properly evaluate your issue.
The analytics team has access to some of the information about your vehicle to ensure that we evaluate the services we provide and make sure we quote you the right services at the best price.
Finally, if you have given us permission to send you promotional material, some of the data may also be used by our communications and marketing department.
Aside from HD 360 Limited, who else has access to this data?
In general, we avoid disclosing personal data to third parties. However, in some cases this is necessary. Your details may be shared with:
- Other companies within the HD Insurance group for administrative and accounting purposes
- HD Insurance Ltd to calculate the quote and submission of the Application,
- Independent Authority for Public Revenue- IAPR (Ανεξάρτητη Αρχή Δημόσιων Εσόδων -ΑΑΔΕ) for identification of your vehicle
- The valuers/assessors who assist us in calculating the cost of damage, wear or repair.
Will your data be used for commercial purposes?
According to the GDPR, in order to be able to send you any promotional material, you must first give us your consent. Without it, we cannot send you updates about new services or new products or partnerships with affiliated companies. Also, we will not be able to send you the company news or news of the market (e.g. news about uninsured cars, news regarding the road taxes, etc.).
If you opt in to these communications, you have the right to withdraw your consent at any time. Just let us know by emailing us at dpo@hellasdirect.gr or simply «unsubscribe» from the next email you receive. We will immediately stop processing your data for commercial and promotional purposes.
Is your personal data safe?
Absolutely! We use all appropriate technical and organizational measures to ensure the security of your personal data. We have chosen to keep only the data which is absolutely necessary, all of which is encrypted and / or anonymized, either in part or in whole. The security of your data is extremely important to us.
What kind of changes do we make?
At times, we may make changes to our Privacy Policy for the purpose of improving customer service and to comply with relevant legislation. We urge you to visit our site from time to time to keep up-to-date with any changes. However, if we make substantial changes to this Policy, we will notify you through via email to give you the opportunity to review the new terms and conditions in order to decide whether or not you agree with them.
What are your rights in relation to your personal data?
You have the right to information and access, to know which data we process, why and by whom.
The right of rectification if for some reason your data is not valid or incorrect.
The right to restrict processing, as the case may be, to specify what data you want to be processed and which ones you want to restrict.
The right of deletion, aka the right to erasure from our database in some cases, especially if there is no need for us to have your data.
The right of portability, to give you the data we have processed to transfer it to another partner or other company.
The right of objection. If applicable, you are entitled to oppose the processing of your data. However, since some of these data are necessary for us to provide you with insurance, the objection may lead to the termination of your insurance contract.
The right to automated individual decision-making, since you have the right not to be subject to decisions taken solely on the basis of automated processing, including profiling.
The right to withdraw the consent you have given us for the use of your data for commercial purposes.
In order to exercise any of your above mentioned rights, you must send us your request by email at dpo@hellasdirect.gr or by calling us at 212 222 9999. We will evaluate your request within thirty (30) days. If there are objective reasons that do not allow us to meet your request, we will inform you. You can exercise these rights at no cost. If they are often reiterated, we have the right to ask you to pay a management fee of up to €25.
How can you complain about the way your personal data is being processed?
If you disagree with the way we have processed your personal data, you can email the Data Protection Officer at dpo@hellasdirect.gr. Alternatively, call us 212 222 9999.
You can also contact the Personal Data Protection Authority, which is available at www.dpa.gr/en.