Privacy Policy and General Data Protection Regulation (GDPR)

The GDPR came into effect on 25th of May 2018 and replaced previous Data Protection Laws in the European Union.

The reason for this change is to give people more control over how their personal data is being used.

At RedClick, we take Data Protection seriously and recognise that as a prospective or existing customer, you may have some queries on what the GDPR is and how it impacts your relationship with us.

We are committed to ensuring you have all the information you need to further understand how and why we process and store your personal data. 

For more information on how we process your data, please read our General Data Protection Notice.

RedClick has a Data Protection Officer available to answer any data queries, concerns and data subject right requests. You can submit a request here.

 

Web users Privacy Policy 

1. Identification and contact details of the Data Controller

Generali Seguros y Reaseguros, S.A.U, with its registered address at Paseo de las Doce Estrellas, 4, 28042 Madrid, Spain, registered as a branch in Ireland as Generali Seguros y Reaseguros, S.A.U., Ireland Branch (trading  as RedClick and Generali) with registered office at  5 Town Hall Place, Farnham Street, Cavan, Co. Cavan, Ireland, H12V9F5, with VAT number IE9952754S, and telephone 1890 89 1890 (hereinafter "RedClick" or the "Insurer") is the controller of the processing of personal data of users who access RedClick’s website. This Privacy Policy provides information on how the Insurer will use personal data and the rights under the General Data Protection Regulation ("GDPR") of users within the website.

RedClick has a Data Protection Officer appointed before the Data Protection Commission, who can be contacted at the following address DataProtectionOfficer@RedClick.ie. If you have any questions regarding the processing of your personal data, please contact the Data Protection Officer at the aforementioned address. 

The Website is operated by Scream Ltd, t/a WIN|WIN of Unit 3, Argyle Square, Morehampton Road, Dublin 4, D04 DC64 Ireland, which may process your information on behalf of RedClick for the purposes therein.

2. General information: description of the information contained in the Privacy Policy

In this Privacy Policy you will find tables identifying each of the different services offered by RedClick. These informative tables will detail:

The purposes of the processing of your personal data, i.e. the reason why RedClick processes your personal data.

The legal basis that allow the processing of data by the Insurer for each of the purposes indicated.

The possible communication of your data to third parties, as well as the reason for such communication. For these purposes, we do not transfer your personal data to third parties except when there is a legal obligation to do so (Tax Authorities, Judges and Courts, Security Forces and Bodies...), or when we expressly indicate it in the table that appears below. On the other hand, RedClick data processors may have access to your personal data, i.e. service providers that have access to your personal data for the performance of their services. Service providers who access your personal data are generally providing services relating to information systems, technology, telecommunications, cloud computing and network security, profiling for statistical-actuarial purposes, private investigation, anti-fraud, finance and billing, professional services where necessary (including experts, lawyers, garages or doctors), or customer services. The table below will indicate those other areas where RedClick service providers may have access to your data from time to time. You can request more detailed information about the recipients of your data by sending an e-mail to the address DataProtectionOfficer@RedClick.ie, indicating the specific processing activity about whose recipients you would like information.

The existence of potential international data transfers. For these purposes, many of our processing activities require the transfer of data internationally to technological service providers or entities of the group to which RedClick belongs, located in the United States, United Kingdom and India, for which the pertinent Standard Contractual Clauses apply. You can request more detailed information regarding the international transfers of your data or the guarantees applied by sending an e-mail to DataProtectionOfficer@RedClick.ie indicating the specific processing activity about which you would like to receive information about the guarantees applying.

The retention period of the data you provide us with. For this purpose, we keep your personal data for the duration of the contractual relationship, or for a longer period if you have given us your consent. Subsequently, your data will remain blocked to deal with judicial, administrative or tax claims, during the statute of limitations period determined by the applicable regulations. 

 

3. Necessary, up-to-date and accurate information

You are required to provide us with the data we request through various means of collection, including the digital portals of RedClick, email, webchat, telephone or paper. If you do not provide us with all information requested, we may not be able to send you communications or provide you with the services you have requested. Likewise, by fulfilling and sending the required information, you declare that the information and data you have provided is accurate and true.

So that the information provided is always up to date and contains no errors, you must inform RedClick, as soon as possible, about the changes to and rectifications of your personal data, using the form you will find at the following link.

 

4. Exercising your rights

You can exercise the following rights:

right of access to your personal data to find out if it is being processed, and if so, what exactly is being processed and the specific processing activity that is being carried out, including the purposes, categories of data processed and recipients, among other information;

right of rectification of any inaccurate personal data;

right of erasure of your personal data when, among other reasons, it is no longer necessary for the purposes for which it was collected, and provided that the legitimate basis that enables us to process it, from among those indicated in the second column of the table included in section 5 below, is not a legal obligation;

right to object to the processing of your personal data, provided that the legitimate basis that enables us to process it, from among those indicated in the second column of the table included in section 5, is the legitimate interest of RedClick or a third party. RedClick will stop processing your data unless a compelling or higher legitimate interest for the processing is proven, or in case we may retain the data in blocked form for the exercise or defence of claims;

right to request the restriction of the processing of your personal data where the accuracy, lawfulness or necessity of the data processing is in question, in which case we may retain the blocked data for the exercise or defence of claims;

right to portability of your data, i.e. to receive your personal data in a structured, commonly used and machine-readable format, in order to transmit it to you or to another data controller, provided that the legitimate basis that enables us to process it, from among those indicated in the second column of the table in section 5 below, is the existence of a contractual relationship or your consent;

right not to be subject to automated decisions that may effect on your legal rights, or that significantly affect you and when such decisions are being made;

right to revoke your consent given to RedClick for the processing of your data, provided that the legitimate basis that enables us to process your data, from among those indicated in the second column of the table included in in section 5 below, is your consent.

You can exercise your rights at any time and free of charge through the form you will find at the following link.

In addition, you have the right to lodge a complaint with RedClick or the Data Protection Commission if you believe that there has been a breach of data protection legislation in relation to the processing of your personal data. 

 

5. Detailed information of the processing carried out by service

Purpose of the processing 

Legitimate basis

Recipients

International transfers

To detect and resolve possible incidents and failures in the webs and digital channels that affect web users, preventing them, among others, from completing online transactions, as well as monitoring and hosting web traffic to limit the transmission of documents, links or malicious access 

Legitimate interest of RedClick in ensuring the safe and efficient operation of its websites and in improving the user experience 

Your data may be communicated within the framework of this processing to the parent company of the group to which RedClick belongs. The categories of service providers that may have access to your information are those listed in section 2.

To the US and India by means of the respective Standard Contractual Clauses approved by the European Commission.

Management of published content and interactions with customers and users through RedClick social networks.

RedClick legitimate interest in interacting with its customers and users through social networks. 

Your personal data will not be transferred based on this processing. The categories of service providers that may have access to your information are those listed in section 2. 

 

To the US by means of the respective Standard Contractual Clauses approved by the European Commission, as well as to the United Kingdom by virtue of the applicable.

Adequacy Decision.

 

To assist and reply to the requests received through the different contact channels.

Performance of a contract or pre-contract.

 

6. Confidentiality

The personal data that we may collect through our websites, portals, forms, contact mailboxes, as well as through the various electronic or telephone communications that we maintain with you or your representative will be processed confidentially by RedClick, with RedClick pledging to keep these confidential in accordance with the provisions of applicable law. 

RedClick does not sell or provide third parties with any information for mailing lists or direct marketing companies, nor does it send communications that have not been previously requested or accepted by users.

It is understood that the user who submits a request by email wants it to be addressed and answered by RedClick in the same way, including, where appropriate, the sending of promotional information requested by the user. 

 

7. Recommendations against fraud

In accordance with its Privacy Policy, RedClick wants the users of its website to have control of their personal information. To this end, RedClick does not ask the user for their password, access code or PIN (personal identification number). Only if a user decides to contact RedClick by email would RedClick receive such data, which will include, in any case, their email address and, additionally, that data that the user enter in the text of the sent email.

For the purposes of conducting and managing commercial campaigns and/or contests organized or promoted by RedClick, the relevant participation and submission forms, either online or in paper, may include personal data collection fields. These data will be solely used in the scope of the initiative unless you authorize us otherwise. For more information, please read the campaign and/or contest Terms & Conditions.

If you have been the victim of an attack, fraud, or attempted fraud, and have provided information, report it to the Garda.

The regulations on Telecommunications and Information Society Services attribute to the Data Protection Commission the protection of the rights and guarantees of users in the field of electronic communications. Among them, the defense of the privacy of Internet users against Spam. 

 

8. Update of the Privacy Policy

This Privacy Policy may need to be updated. It is therefore necessary that you review this policy periodically and, if possible, every time you access the RedClick website, in order to be properly informed about the type of information collected and its processing.