Terms and conditions for processing personal data at Cachet Insurance Broker OÜ

Version 0.8 – 07.04.2021

Cachet Insurance Broker OÜ (registry code 14920263, address Kohtu 2-21, 10130 Tallinn, email info@Cachet.me, hereinafter Cachet Broker) processes personal data to market insurance contracts and provide insurance brokerage services and other related services.

1. GENERAL PROVISIONS
   1. Cachet Broker ensures that the processing of personal data is in accordance with the legislation regarding the protection and security of personal data (incl. the General Data Protection Regulation of the European Union, hereinafter GDPR), other personal data protection legislation, and good business practices.
   2. Cachet Broker considers the privacy of the individual and the protection of their data important and makes the best efforts to ensure the security and protection of the information system and other data carriers.
2. DEFINITIONS
   1. Client means a person or their representative who uses the services of Cachet Broker (services), is interested in the services, or is related to the services (e.g. insured person, beneficiary, property owner in the insurance contract, etc.).
   2. Processing of personal data means viewing, collecting, saving, storing, altering, transmitting, or receiving personal data and other activities related to personal data.
   3. Portal is the web service at https://Cachet.me/, through which Cachet Broker markets and mediates the insurance contract to the Client and through which Cachet Broker and the Client exchange information related to the insurance contract.
3. PURPOSE OF THE PROCESSING OF PERSONAL DATA AND ITS LEGAL BASIS
   1. Cachet Broker processes personal data to provide services and to market a personal insurance contract to the Client that meets their needs. For this purpose, Cachet Broker processes data on the insured object, the insurable interest, and the need of the Client and the use of the insured object, including a vehicle.
   2. To market the insurance and provide the services of an insurance broker, Cachet Broker processes personal data pursuant to the law. For other purposes and for the provision of other services, Cachet Broker processes personal data on the basis of a brokerage contract or consent.
4. PERSONAL DATA PROCESSED BY CACHET BROKER
   1. Client identification data – name, surname, personal identification code, phone number, email address, country of location, and other client data necessary for identifying the person and concluding a brokerage contract and insurance contract;
   2. Data on the insured object (incl. vehicle) that is necessary for marketing the insurance contract, incl. data on the use of the insured object (e.g. data on the provision of a ride-sharing service with a vehicle);
   3. Client data necessary for marketing the insurance contract – name, personal identification code, contact information (phone number, email address), data of beneficiaries and insured persons;
   4. Data necessary to assist in the performance of the insurance contract – data on insurance contracts marketed to the Client, data on insurance events: time, place, circumstances, insurance indemnity, repair, loss amount, refusal to indemnify, and other data;
   5. Insurance premium payment data – the Client’s bank account number, credit card data, invoice or payment notification data, and other payment data.
5. HOW CACHET BROKER COLLECTS AND USES PERSONAL DATA
   1. Cachet Broker may obtain the data on the client, the marketing of the insurance contract, and the insured object (incl. the vehicle) at the request and with the consent of the client from the portal used by the Client or directly from the Client.
   2. Data on the use of the insured object can be obtained by Cachet Broker at the request and with the consent of the Client from the Portal that has collected this data from ride-sharing platforms (Uber, Bolt, Yandex, etc.).
   3. Cachet Broker receives, transmits, and processes personal data only digitally.
   4. Cachet Broker uses personal data to request insurance offers from insurers, to prepare and submit a comparative insurance offer to the Client, to draw up an insurance contract, to provide insurance advice, to assist in the performance of the insurance contract, and to provide other services.
   5. The data on the use of the vehicle is used by Cachet Broker to assess the compliance of the insurance contract with the Client’s insurance interest, to recommend the amendment of the insurance contract or the conclusion of a new insurance contract.
   6. Data on insured events is used by Cachet Broker to inform the client how the insurer will perform the insurance contract if an insured event occurs.
   7. Cachet Broker processes personal data in the European Union (EU) and within the European Economic Area (EEA).
6. TRANSMISSION OF PERSONAL DATA
   1. Cachet Broker transmits the data on the Client, the insured object (e.g. vehicle), and its use to insurers to receive a personal insurance offer for the Client and to check the compliance and fulfilment of the data of the insurance contract.
   2. Cachet Broker forwards the data of the brokerage contract and the insurance contract to the Portal where the Client stores this data. Among other things, Cachet Broker transmits data on claims and insurance indemnity.
   3. Cachet Broker performs automatic inquiries, in the course of which the Client’s identification data is transmitted to the Portal to obtain the data necessary for concluding and performing the brokerage contract and the insurance contract, incl. data on the Client’s vehicle and its use.
   4. Upon concluding a brokerage contract, personal data necessary for concluding, amending, and executing the insurance contract, as well as data on the insured object (incl. vehicle), the use of the insured object (incl. vehicle), and the insured event are stored in the Portal.
7. DISCLOSURE AND STORAGE OF PERSONAL DATA
   1. Cachet Broker does not disclose personal data to third parties, unless the obligation to disclose arises from law.
   2. Cachet Broker retains personal data until the expiry of the limitation period for claims arising from the brokerage contract and after that, for the performance of legal obligations on the basis of its legitimate interest.
8. RIGHTS OF THE CLIENT (DATA SUBJECT)
   1. Receive information on the scope and use of the processing of their data;
   2. Require the termination of the use, correction, and deletion of their data;
   3. Consent or withdraw consent to the use of their personal data for direct marketing or other marketing purposes, to demand that no decisions be taken against them based solely on automated processing;
   4. Contact the Data Protection Inspectorate (www.aki.ee) for the protection of personal data or turn to a court to demand compensation for damage arising from the use of data that does not comply with legislation.
9. DATA CONTROLLER AND DATA PROCESSOR
   1. Cachet Broker is the controller of personal data in connection with concluding a brokerage contract and submitting a comparative insurance offer regarding personal data received from a Client.
   2. The insurers are controllers of personal data in regard to being responsible for concluding the insurance contract and Cachet Broker is the processor of personal data regarding the insurance contract.
   3. Cachet Broker is a controller for the client identification data obtained through the Portal https://Cachet.me/ and the data obtained on the usage activity of the insured object (incl. vehicles).
10. CACHET.ME
    1. https://Cachet.me/ is an insurance services intermediation environment provided by Cachet OÜ, in which insurance intermediaries and insurers market and enter into insurance contracts. The data processing terms of Cachet.me are published at https://Cachet.me/privaatsusreeglid/. Cachet OÜ is the controller of personal data necessary for managing the accounts of the platform users and for assessing the usage activity of the insured object (e.g. collection of vehicle usage activity data from ride-sharing platforms).
11. CHANGES AND VAILIDITY
    1. Cachet Broker has the right to change the conditions for processing personal data by providing at least 1 (one) month’s notice in advance through the Portal before the change takes effect.
    2. The conditions for processing personal data are valid from 1 January 2021