Privacy Policy

AXA Partners Group respects your privacy and ensures that all the personal data it handles is processed in accordance with best confidentiality practices and the applicable laws on data protection, in particular any national legislation or regulation applicable in the countries in which we are established and, within the European Union, the General Data Protection Regulation (EU Regulation No. 2016/679) (hereinafter referred as “GDPR”).

Personal Data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

AXA Partners is made up of a number of different companies and is part of the worldwide AXA Group. AXA Partners companies offer insurance policies and services, providing assistance.

The purpose of this Privacy Policy (hereinafter referred to as " this Policy") is to present to you the processing of your Personal Data when you have taken out insurance with Inter Partner Assistance SA Belgian Branch. It applies to the processing of Personal Data that you share with us during the handling of your request; this may include subsequent processing activities that may be carried out by insurers in the context of their insurance services, such as in the event of suspicion of insurance fraud or for analytics purposes.

By providing your Personal Data or the Personal Data of someone else, you acknowledge that we may use it in the ways set out in this Privacy Policy. Please bring this Privacy Policy to the attention of anyone on whose behalf you are acting, and ensure you have obtained their prior consent, where applicable.

In the context of this Policy, “you” will refer to the data subject whose personal data is processed for the purposes specified below.

WHO IS THE DATA CONTROLLER?

The Data Controller for the Processing of your Personal Data (i.e. the entity that determines the purposes and means of the processing) is the entity indicated as the insurer in your contractual documentation :

Inter Partner Assistance SA – Begian branch

Member of the AXA PARTNERS
Office: Boulevard du Régent 7, 1000 Brussels, Belgium
Registered with the Crossroads Bank for Enterprises under number 0415.591.055, RPM Brussels Insurance company approved under code 0487

The Data Controller is referred to in this Policy as “AXA Partners” or “the Data Controller” or “we”.

We inform you that, where available in your policy, international teleconsultation services are provided by a third party that is acting as Data Controller. You will have more information about the way this provider processes your personal data when you access its platform.

In what way is your Personal Data collected AND processed, and for what purposes?

The personal data we collect is essentially that which you provide us directly, either via our digital channels (including this Website, our chatbot or WhatsApp) or during phone calls or e-mail exchanges with our claim management team.

Whether or not the provision of your Personal Data to us is mandatory will be indicated to you at the time of collection of such data. If you do not provide the information mentioned as mandatory, we may not be able to provide you with the insurance policies or services you have requested.

We might also collect information about you from other people or organisations, such as our business partners, in particular to verify the eligibility of your claim, third parties who assist us in investigating potential fraud.

We have set out below the main reasons/purposes we may process your Personal Data for, the categories of Personal Data concerned and the applicable legal basis:

For more information on the terms applicable to your Personal Data, you can contact the DPO mentioned in the documentation given to you when you adhered to the insurance policy.

HOW DO WE ENSURE THE SECURITY OF YOUR PERSONAL DATA?

We use appropriate technical and organizational measures designed to protect the Personal Data about you. The measures that we use provide a level of security appropriate to the risk of the processing activity of your Personal Data, in line with AXA standards.

Do we use artificial intelligence (AI)?

Artificial Intelligence is an umbrella term for a range of technologies that replace manual processes and solve complex tasks by carrying out functions that previously required human action. Tasks that we have traditionally done by thinking and reasoning are increasingly being done by, or with the help of, AI.

We therefore use AI to improve our existing activities with a particular focus on simplifying complex processes, ensuring consistent standards and driving efficiencies. Some of these purposes are explained in more detail below, and are in accordance with Regulation (EU) n° 2024/1689 ‘‘EU AI Act’).

When using AI, we combine information you have provided to us directly, information we derive about you from your use of our services or your interactions with us, and information from other people and organizations.

Supporting processes to provide customer service

We use AI to improve our service management.
For example, we provide virtual assistants and chatbots, so you have a choice of methods to communicate with us, especially out of office hours. The virtual assistants and chatbots may use elements of AI, for example in understanding your questions, guiding you to or presenting you with appropriate help content, providing general responses or transferring you to an appropriate adviser, based on your question and the information you provide.

Where we are required to provide a call transcript, we may use AI to support the process of converting recorded information to text.

Management of claims and detection of fraud

We may use AI for wider processes that support claims management services, such as indexing the documents that support your claim to your customer record and reviewing documents as part of our fraud detection process.

Customer feedback and surveys

We may use AI to analyse information from customer surveys, feedback forms, calls, and complaints to understand how satisfied our customers are with our products, service, and communications. For instance, we may use AI to classify whether a comment or review is positive or negative, and what the comment or review is focused on (e.g. customer service, coverage, claims, etc.). This helps us to optimize customer journeys and improve products and services.

Training of AI solution

Unless where personal data is strictly necessary at AXA Partners point of view, we anonymize the data for the purpose of training AI systems. Where anonymized data cannot be used, we may utilize personal information during the development and training of our AI solutions to enhance our services. In this case, the legal basis for the processing will be our legitimate interest, or scientific research if the processing relates to sensitive data.

Is an automated decision made in the context of this processing?

The issuance/management of the insurance contract may be in some cases subject to automated decision-making processes, in consideration of our underwriting/pricing/claims requirements (for example: age at policy inception, age at policy expiration, amount insured, eligibility for claim payment) and in consideration of regulatory requirements (for example, to offer you the product most suitable for your insurance needs, or to comply with anti-money laundering and anti-terrorism regulations where applicable). This automated process is necessary for the conclusion / execution of the contract, and may occur, for example, in relation to insurance products purchased online or issued through our IT platforms or IT platforms of our intermediaries' IT platforms.

At any time, you may exercise the right to obtain human intervention on the part of the Data Controller, to express your point of view, or to contest the decision, by contacting the DPO at the contact details indicated in this Privacy Policy.

To whom we disclose your Personal Data?

We only share your personal data with identified and authorized recipients in order to allow us to provide our services and carry out all related processing.
We might share your personal information with companies inside the AXA Group as well as other third parties outside the Group.

Disclosures to AXA Group entities:

In order to provide our services, your personal information will be shared with the entities in charge of handling your claims as well as potential requests or complaints. These entities are mostly located in the European Economic Area.

• AXA Assistance France – 8-10 rue Paul Vaillant Couturier – 92 240 Malakoff - France
• Inter Partner Assistance SA – branch in Belgium - 7 Boulevard du Régent, 1000 Bruxelles – Belgique
• Inter Partner Assistance Servicios España SA – calle Tarragona 161, 08014 Barcelona - Spain

Your personal information might also be shared with:

• the specialized teams in charge of fraud prevention and detection in certain entities of the Group (in particular contract and claims managers, staff in charge of the fight against fraud, internal control, legal department) as well as teams in charge of Anti-Money Laundering and Countering the Financing of Terrorism,
• the specialized teams in charge of the various satisfaction analyses with a view to improving the quality of the service,
• the specialized teams in charge of Statistical and actuarial study.

We also use a number of AXA entities to provide shared operational, IT and infrastructure related services to us, both within the AXA Partners group of companies and the wider AXA Group. These AXA Group entities may be located outside the European Economic Area, in particular in the United Kingdom and India.

Disclosures to third parties outside our AXA Group:

Your Personal Data may also be shared with:

• external subcontractors in charge of handling your claims on our behalf in region where we do not have entities,
• service providers who are involved in assistance services such as local correspondents, doctors, hospitals, ambulance companies, airlines…. wherever they are in the world
• services providers who are involved in related services such as payment and banking providers, IT support – infrastructure and cloud providers, communication services providers (including WhatsApp if you have chosen this channel), customer feedback and survey providers…, social media connector providers (like Apple and Google) etc...)
• business partners, reinsurers or authorized professional organizations who need to access to your information in order to provide you with the services included in your contract and carry-out certain legitimate activity such as risk assessment, underwriting,
• legal authorities or regulatory bodies such as law enforcement, courts, regulatory bodies, etc.
• Public or private bodies related to the insurance sector for annual statistics and fraud prevention purposes, for the settlement of claims,
• parties involved in current or potential legal proceedings, or who assist us in establishing, exercising and defending our legal rights. For example, we may share information with our legal advisors or other professional advisors,
• other parties to the extent you have given us your consent to do so or where permitted or required by law
• any other third parties against which we enforce our claims recovery rights.

Disclosure of your personal information to a third party outside of the AXA Group, with the exception of law enforcement agencies or other bodies exercising their official authority, will only be made where the third party has agreed to keep your information strictly confidential and shall only be used for the specific purpose for which we provide it to them.

HOW IS YOUR PERSONAL DATA PROTECTED WHEN TRANSFERRED OUTSIDE THE EUROPEAN ECONOMIC AREA

As a general manner, we endeavour to transfer your Personal Data only to organisations located within the European Economic Area (EEA) or in countries that guarantee a similar level of protection. In particular, your Personal Data remains hosted within the European Union.

However, for the purposes of our business, we may need to transfer your Personal Data to recipients located in countries that do not guarantee a similar level of protection, in particular to the United States and Mauritius in the context of the related services referred to above.

Where Personal Data is disclosed to an AXA entity outside the EEA, this transfer is governed by the Binding Corporate Rules (BCR) implemented within the AXA Group. These rules represent an internationally recognized standard for the protection of personal information and guarantee an intangible and minimum level of protection of your Personal Data by the various AXA Group companies around the world. These BCRs have been approved by 16 data protection authorities, including the CNIL, the lead authority for the AXA group. To find out more about the AXA Binding Corporate Rules, including the list of companies bound by the BCRs and FAQs, you can access the following link: Our commitments | AXA (please scroll to the bottom of the page you access to).

Where your Personal Data is disclosed to an external third party or an AXA entity not covered by the BCRs that is located outside the EEA, in a country which is not recognised as providing a sufficient and adequate level of data protection by the European Commission, we ensure that appropriate safeguards such as Standard Contractual Clauses adopted by the European Commission are signed between the issuer and the recipient of the data in that third country. You can find out more about these standard contractual clauses by contacting our Data Protection Officer.

However, please note that for the purposes of assistance services, your Personal Data may be transferred from time to time to service providers located in the country where you are located and whose Data protection regulations may not offer guarantees similar to European regulations. This transfer will be based on article 49 para. 1 b) or c) of the General Data Protection Regulation 2016/679 of 27 April 2016 (transfer necessary for the performance of a contract between you and us, or a contract concluded in your interest between AXA and the service provider or between AXA and the subscriber).

WHAT ARE YOUR RIGHTS TO YOUR PERSONAL DATA?

In accordance with the applicable Personal Data protection regulations (subject to your specific national legislation which would modify or not apply the list of rights below), you have right to:

• Access to your Personal Data: you have the right to request access to the Personal Data we process about you, and to obtain a copy of that data,
• Rectify your Personal Data: you have the right to ask us to rectify or complete the Personal Data we process about you that are inaccurate, incomplete, or not up to date,
• • Your data is inaccurate and needs to be corrected or updated,
  • You would rather restrict the processing than delete your data subject to unlawful processing,
  • Your data is no longer necessary to achieve the purpose of processing but still required for the establishment, exercise or defense of your legal rights,
  • You may have previously objected to the processing, where this right is applicable.

This means that we may simply keep your data but may not process or use it in any other way.

• Decide what happens to your Personal Data after your death: depending on the country where you bought the insurance policy, you have the right to give us instructions as to how your Personal Data should be used after your death.

Depending on the legal basis for the processing of your Personal Data described in the tables above, you may also have the right to:

• Request the deletion of your Personal Data: you have the right to ask us to delete your Personal Data, except if your Personal Data is necessary for us to comply with a legal obligation, or to establish, exercise or defend a legal claim,
• Object to the processing of your Personal Data: you have the right to prevent us from processing your Personal Data, essentially when the data processing activity is based on our legitimate interest,
• Ask for the portability of your Personal Data: you have the right to receive the Personal Data you have provided to us in a suitable format and have the right to transfer that data to another data controller without us interfering, when the data processing activity is based on the performance of a contract or the consent,
• Withdraw your consent: Where a processing is based on your consent, you can withdraw that consent at any time by contacting our DPO with contact details in the section below. The withdrawal of your consent will not affect the lawfulness of processing based on consent before that withdrawal.

How to contact our Data Protection Officer?

You can contact our DPO to exercise your rights at the following addresses.

Your request must be accompanied by a photocopy of both sides of your identity card (or any other identity document):

• By post:
  Data Protection Officer Inter Partner Assistance S.A. Belgian Branch
  Boulevard du Régent 7
  1000 Brussels, Belgium
• By email:
  dpo.BNL@axa-assistance.com

We will process requests within the time limits provided for by law. Except in cases of manifestly unfounded or excessive requests, no payment will be required for the processing of such requests.

HOW TO MAKE A COMPLAINT TO A SUPERVISORY AUTHORITY?

If you believe that we are not complying with the relevant regulations, you are invited to consult us as a matter of priority.

You may also file a complaint with the Personal Data Protection Authority at the following address:
DATA PROTECTION AUTHORITY
Rue de la Presse, 35
1000 Brussels, Belgium
Tel. +32 2 274 48 00
Email: contact@apd-gba.be

You can also file a complaint with the court of first instance in your place of residence.

Update of the present privacy policy

We may update this Policy in response to legal, technical, or commercial changes. When we update our Policy, we will take appropriate measures to inform you, in line with the significance of the changes we make.

Its last update was on 06/08/2026.