Data privacy

Information on the processing of data in our company

We take the protection of your personal data very seriously in the AVW Group (hereinafter “AVW”). We process your personal data solely in accordance with this data privacy statement and with the relevant legal provisions, especially the European General Data Protection Regulation (hereinafter “GDPR”).

The following privacy statement relates to the processing of your personal data on our websites (Part A), as a customer or potential customer (Part B), as an insurer, agent or broker (Part C), as a service provider or supplier (Part D), and in connection with any application addressed to our company (Part E). Finally, Part F contains some general information which applies to all data processing operations at AVW.

Part A: Processing of data on our website and for the newsletter

Part B: Processing of data of customers, prospective clients and potential customers

Part C: Processing of data of insurers, agents and brokers

Part D: Processing of data of service providers and suppliers

Part E: Processing of data of applicants

Part F: General information (your rights, controller responsible for processing, data protection officer)

Part A: Processing of data on our websites and for the newsletter

Collection and use of personal data

AVW processes personal data of the people using its website. For one part, these are standardised procedures involving the collection of data for the protection and optimisation of our website (IP addresses, log data). Additionally, the procedures involve the processing of personal data which are provided directly by you for this purpose. This is the case, for example, if you sign up for our newsletter, send us details of your losses or damages using the online claim forms, or get in touch with us through a contact form or feedback form.

The data you enter are encrypted before being transmitted to our web server. Therefore, these data cannot be viewed by unauthorised persons.

Your personal data will be used for the stated purposes only and to the extent necessary to achieve these purposes.

We have put technical and organisational measures in place to protect your data from loss, alteration or third-party access.

IP address storage

We store the IP address transmitted by your web browser for seven days, adhering strictly to its intended purpose of use in the interests of being able to detect, restrict and eliminate attacks on our website. At the end of this period, we delete or anonymise the IP address. The legal basis for this is Art. 6 (1) f) GDPR.

Usage data

When you visit our website, usage data are logged and temporarily stored on our web server for statistical purposes in order to improve the quality of our websites. This record consists of the following data:

  • the page from which the file was requested
  • the name of the file
  • the date and time of the request
  • the volume of data transmitted
  • the access status (file transferred, file not found)
  • the description of the type of web browser used
  • the IP address of the computer sending the request, shortened in such a way that it can no longer bear reference to any individual person

The log data listed above are stored in anonymous form only.

Transmission of data to third parties

We send your data to service providers who assist us with the operation of our websites (e.g. hosting and design) and with the associated processes, acting on our instructions as processors as defined in Art. 28 GDPR. Our service providers are duty-bound to follow our instructions and to adhere strictly to contractual agreements.

Use of data supplied with registrations for the email newsletter

You can sign up on our website for our newsletter and thereby gain access to expert information. If you have granted us specific consent to inform you by email about our own products and services, the data will be processed in accordance with Art. 6 (1) a) GDPR (consent).

We use the so-called "double opt-in" procedure to ensure that a newsletter subscription actually originates from the owner of the registered email address. This means that after registering you will first receive an email asking you to click on a link contained in this email to reconfirm that you would like to receive our newsletter and that you are the legitimate holder of the email address. Only after confirmation will you be registered for the newsletter.

You may revoke your consent at any time without affecting the legality of the processing already carried out. If the consent is revoked, we will stop processing the data.

If you no longer wish to receive the newsletter, you can unsubscribe at any time by sending an email to service@avw-gruppe.de, for example, or by using the link to unsubscribe from the newsletter which you will find in every newsletter email.

Cookies

We use cookies on our websites. Cookies are small text files which can be stored and read on your end device. A distinction is drawn between session cookies, which are deleted again as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. Cookies may contain data which make it possible to recognise the device used. In some cases, however, cookies only contain information on certain settings which cannot be related to individuals.

We use session cookies on our websites. Processing is carried out on the basis of Art. 6 (1) f) GDPR and in the interests of optimising site navigation for users.

You can set your browser to inform you about the use of cookies so as to allow transparency for you with regard to cookies. You can also delete cookies at any time through the corresponding browser setting and prevent the use of new cookies. Please note that, in this case, our websites may not be displayed optimally and that some functions may no longer be available.

Online notification of claims (web form)

You can use our web form to report cases of loss or damage directly. In order to use our web form, we require information on the date of loss, place of loss, cause of loss, circumstances of loss, estimated amount of loss, information as to whether you are entitled to deduct input tax, and in some cases information on the claimant and contact details. On the vehicle damage form, we also require information on the vehicle and driver at the time of the accident and where the vehicle can be inspected. Mandatory fields are marked with an asterisk (*). You may provide further information but you do not have to.

Of course, you do not need to use our web form to report cases of loss or damage. You can also notify us of your claim by post, fax or email.

The legal basis for the processing is Art. 6 (1) b) GDPR. Your data will only be processed to send a reply to your claim.

Contact form

You can contact us through an online form. You will need to enter your name and email address in order to use our contact form. You may provide further information but you do not have to.

The legal basis for the processing is Art. 6 (1) b) GDPR if you are asking about an existing policy / contract or seeking to take out a policy.


 In other cases, the processing will serve our legitimate interests in answering your inquiry pursuant to Art. 6 (1) f) GDPR. Your data will only be processed to respond to your inquiry and will be deleted immediately after processing the inquiry. The data will not be passed on to third parties.

Customer feedback

You can send us feedback through an online form. You do not need to enter any personal data in order to use our feedback form. However, if you do provide personal data (e.g. name and email address), the legal basis for the processing is Art. 6 (1) f) GDPR. Depending on the content of your customer feedback, the data collected in this context will also be forwarded to our quality control or complaints management section and processed there. We are obliged to have a complaints management system in place pursuant to section 17 of the German law on insurance brokerage (Versicherungsvermittlungsverordnung - VersVermV) and we must also allow the relevant Chamber of Commerce and Industry to inspect the files at any time. Beyond this, your data will not be passed on to third parties. The storage period is in line with the standard three-year limitation period (section 195 of the German Civil Code (Bürgerliches Gesetzbuch - BGB)).

Part B: Processing of data of customers, prospective clients and potential customers

Collection and use of personal data

We collect personal data from our customers within the framework of the policy / contractual relationship. This generally includes the name, function / job title and company contact details (email address and telephone number) of the contact persons of our corporate customers. Insofar as the customers are natural persons, we collect their name, address and other data where applicable, depending on the type of insurance in any given case. These data are necessary and mandatory for the conclusion of a policy / contract. Failure to provide the data will render the conclusion / execution of the contract impossible.

These data will be used, on the one hand, to the extent necessary for the processing of an order or an inquiry. On the other hand, we will also use the data to maintain business relations in various ways, such as sending invitations to our events or conducting satisfaction surveys.

We collect personal data of prospective clients and potential customers in the context of making initial business contacts and conducting marketing operations. Again, this will generally include the name, function / job title and company contact details (email address and telephone number) of the contact persons of prospective clients and potential customers.

Controller / transfer

The respective contractual partner is responsible for data processing within our group of companies, i.e. either AVW Versicherungsmakler GmbH or AVW Assekuranzvermittlung der Wohnungswirtschaft GmbH & Co. KG. If the contractual partner is AVW Assekuranzvermittlung der Wohnungswirtschaft GmbH & Co. KG, the data will also be passed on to AVW Versicherungsmakler GmbH within the group of companies.

In all other respects, we will only pass on the personal data we collect to third parties if this is our legitimate right under data protection law. We will therefore pass on your personal data to companies or individuals after instructing them to carry out specific tasks and services for us (e.g. IT service providers, tax accountants). The transfer of your personal data to these companies is limited to the extent necessary to do their work. These companies are bound by the data protection regulations, as it were, and have been carefully selected by us and are regularly monitored by us. In addition, we only pass on your personal data to third parties if we are obliged to do so by law or by court order.

Legal basis

The legal basis for the processing of personal data for the fulfilment of an existing contract or for the initiation of a contract is Art. 6 (1) b) GDPR.

The legal basis for the processing of personal data for the cultivation or establishment of business relationships is Art. 6 (1) f) GDPR. It serves our legitimate interests in business development, marketing and customer care. You have the right to object to the processing of your personal data for this purpose at any time (cf. Part E - your rights as the data subject).

The legal basis for the transfer of personal data within the group of companies is Art. 6 (1) f) GDPR. It serves our legitimate interests in optimising processes within the group of companies. You may object to this processing at any time for reasons arising from your particular situation (cf. Part E - your rights as the data subject).

Storage period

Personal data will only be stored for the period of time required to achieve the purpose for which they are stored or to the extent dictated by law. The personal data are therefore routinely blocked or erased when the purpose of storage ceases to apply or a statutory period expires.

Part C: Processing of data of insurers, agents and brokers

Collection and use of personal data

We collect personal data from insurers, agents and brokers within the framework of the policy / contractual relationship. This generally includes the name, function / job title and company contact details (email address and telephone number) of the contact persons of the insurers, agents and brokers. These data are necessary and mandatory for the conclusion of a policy / contract. Failure to provide the data will render the conclusion / execution of the contract impossible. These data will be used, on the one hand, to the extent necessary for the execution of the contract. On the other hand, we also use the data for the development of business relations and joint marketing initiatives (e.g. sending invitations to our events or engaging speakers).

Controller / transfer

The respective contractual partner is responsible for data processing within our group of companies, i.e. either AVW Versicherungsmakler GmbH or AVW Assekuranzvermittlung der Wohnungswirtschaft GmbH & Co. KG. If the contractual partner is AVW Assekuranzvermittlung der Wohnungswirtschaft GmbH & Co. KG, the data will also be passed on to AVW Versicherungsmakler GmbH within the group of companies.

In all other respects, we will only pass on the personal data we collect to third parties if this is our legitimate right under data protection law. We will therefore pass on your personal data to companies or individuals after instructing them to carry out specific tasks and services for us (e.g. IT service providers, tax accountants). The transfer of your personal data to these companies is limited to the extent necessary to do their work. These companies are bound by the data protection regulations, as it were, and have been carefully selected by us and are regularly monitored by us. In addition, we only pass on your personal data to third parties if we are obliged to do so by law or by court order.

Legal basis

The legal basis for the processing of personal data for the fulfilment of an existing contract or for the initiation of a contract is Art. 6 (1) b) GDPR.

The legal basis for the transfer of personal data within the group of companies is Art. 6 (1) f) GDPR. It serves our legitimate interests in optimising processes within the group of companies. You may object to this processing at any time for reasons arising from your particular situation (cf. Part E - your rights as the data subject).

Storage period

Personal data will only be stored for the period of time required to achieve the purpose for which they are stored or to the extent dictated by law. The personal data are therefore routinely blocked or erased when the purpose of storage ceases to apply or a statutory period expires.

Part D: Processing of data of service providers and suppliers

Collection and use of personal data

We collect personal data from service providers and suppliers within the framework of the policy / contractual relationship. This generally includes the name, function / job title and company contact details (email address and telephone number) of the contact persons of the service providers and suppliers. These data are necessary and mandatory for the conclusion of a policy / contract. Failure to provide the data will render the conclusion / execution of the contract impossible. These data will be used to the extent necessary for the execution of the contract.

Controller / transfer

The respective contractual partner is responsible for data processing within our group of companies, i.e. either AVW Versicherungsmakler GmbH or AVW Assekuranzvermittlung der Wohnungswirtschaft GmbH & Co. KG. If the contractual partner is AVW Assekuranzvermittlung der Wohnungswirtschaft GmbH & Co. KG, the data will also be passed on to AVW Versicherungsmakler GmbH within the group of companies.

In all other respects, we will only pass on the personal data we collect to third parties if this is our legitimate right under data protection law. We will therefore pass on your personal data to companies or individuals after instructing them to carry out specific tasks and services for us (e.g. IT service providers, tax accountants). The transfer of your personal data to these companies is limited to the extent necessary to do their work. These companies are bound by the data protection regulations, as it were, and have been carefully selected by us and are regularly monitored by us. In addition, we only pass on your personal data to third parties if we are obliged to do so by law or by court order.

Legal basis

The legal basis for the processing of personal data for the fulfilment of an existing contract or for the initiation of a contract is Art. 6 (1) b) GDPR.

The legal basis for the transfer of personal data within the group of companies is Art. 6 (1) f) GDPR. It serves our legitimate interests in optimising processes within the group of companies. You may object to this processing at any time for reasons arising from your particular situation (cf. Part E - your rights as the data subject).

Storage period

Personal data will only be stored for the period of time required to achieve the purpose for which they are stored or to the extent dictated by law. The personal data are therefore routinely blocked or erased when the purpose of storage ceases to apply or a statutory period expires.

Part E: Processing of data of applicants

Collection and use of personal data

We use the data you provide when you apply for a job with us (your contact details, date of birth, curriculum vitae, certificates, professional qualifications, career history and – if required for the reimbursement of travel expenses – your bank details) in order to process your application.

The data in your application will be processed solely for the purpose of filling the position for which you have applied.

Controller / transfer

The party responsible for the data processing is AVW Versicherungsmakler GmbH.

We will only pass on the personal data we collect to third parties if this is our legitimate right under data protection law. We will therefore pass on your personal data to companies or individuals after instructing them to carry out specific tasks and services for us (e.g. IT service providers, tax accountants). The transfer of your personal data to these companies is limited to the extent necessary to do their work. These companies are bound by the data protection regulations, as it were, and have been carefully selected by us and are regularly monitored by us. In addition, we only pass on your personal data to third parties if we are obliged to do so by law or by court order.

Legal basis

The legal basis for the processing of the data is section 26 of the Federal Data Protection Act (Bundesdatenschutzgesetz - BDSG).

Storage period

If you are not appointed, we will save your data for six months after the application process has been completed in order to be able to answer questions in connection with your application and – where applicable – rejection. If we do not have a vacant position at the time of your application, but your application is of interest for a future vacancy, we will only save your data for this purpose if you have given your express consent.

Some data may be stored for a longer period of time in individual cases (e.g. in case of reimbursement of travel expenses). The term of storage will then depend on the statutory retention periods prescribed under the relevant laws, e.g. German Fiscal Code (Abgabenordnung - AO) (six years) or German Commercial Code (Handelsgesetzbuch - HGB) (10 years).

Part F: General information (your rights, controller responsible for processing, data protection officer)

Your rights as the data subject

As the data subject, you are granted certain rights under the GDPR in connection with the processing of your personal data:

1. Right of access (Art. 15 GDPR)

You have the right to request confirmation as to whether personal data relating to you are being processed and, if this is the case, you have a right of access to these personal data and to the other information listed in Art. 15 GDPR.

2. Right to rectification and erasure (Art. 16 and 17 GDPR):

You have the right to request the rectification of incorrect personal data concerning you without undue delay and, where applicable, the completion of incomplete personal data.

You also have the right to request the erasure of personal data concerning you without undue delay where one of the grounds listed in Art. 17 GDPR applies, e.g. if the data are no longer required for the purposes for which they were collected.

3. Right to restriction of processing (Art. 18 GDPR):

You have the right to request a restriction on processing for the length of time required for any verification procedure if one of the conditions listed in Art. 18 GDPR is met, e.g. if you have filed an objection to processing.

4. Right to data portability (Art. 20 GDPR)

In certain cases, as detailed in Art. 20 GDPR, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format and the right to request the transmission of these data to a third party.

5. Right to object (Art. 21 GDPR)

If data are collected on the basis of Art. 6 (1) f) (data processing to safeguard legitimate interests), you have the right to object to their processing at any time on grounds relating to your particular situation. We will then no longer process your personal data unless there are compelling legitimate grounds for their processing which override the interests, rights and freedoms of the data subject, or if the data are processed for the establishment, exercise or defence of legal claims.

You may of course object at any time to the processing of your personal data for the purposes of advertising and data analysis. You can use the following address to notify us of your objection to the processing of your personal data for advertising: datenschutz@avw-gruppe.de. You can also use the contact details given in the imprint or in the section headed “Controller”.

6. Right to lodge a complaint with a supervisory authority

Under Art. 77 GDPR, you have the right to lodge a complaint with a supervisory authority if you consider that the processing of data relating to you infringes data protection regulations. The right to lodge a complaint with a supervisory authority may be exercised in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. This also includes the data protection supervisory authority with oversight of the controller  who, in the case of AVW Versicherungsmakler GmbH, is the Hamburg Commissioner for Data Protection and Freedom of Information (Hamburgischer Beauftragter für Datenschutz und Informationsfreiheit), Herr Prof. Dr. Johannes Caspar, Ludwig-Erhard-Str 22, 7. OG, 20459 Hamburg, tel.: 040 / 428 54 - 4040, fax: 040 / 428 54 - 4000, email: mailbox@datenschutz.hamburg.de. The data protection supervisory authority with oversight of AVW Assekuranzvermittlung der Wohnungswirtschaft GmbH & Co. KG is the Independent Centre for Privacy Protection Schleswig-Holstein – Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein, Marit Hansen, Postfach 71 16, 24171 Kiel, tel.: 0431 988-1200, fax:  0431 988-1223, email: mail@datenschutzzentrum.de.

Controller

The controller responsible for the collection and processing of data at AVW – unless stated otherwise above – is as follows:

AVW Versicherungsmakler GmbH

Hammerbrookstr. 5

20097 Hamburg

Tel.: +49 (40) 2 41 97 - 0

Fax: +49 (40) 2 41 97 - 115

Service@avw-gruppe.de

If it follows from the information stated above that the designated controller would be AVW Assekuranzvermittlung der Wohnungswirtschaft GmbH & Co. KG then the contact details are as follows:

AVW Assekuranzvermittlung der Wohnungswirtschaft GmbH & Co. KG

Gerold Damm 6

23715 Bosau

Tel.: +49 (4527) 927 46 - 0

Fax: +49 (4527) 927 46 - 11

avw@assekuranzvermittlung.com

Address for email correspondence in connection with data privacy: datenschutz@avw-gruppe.de.

Contact details of the data protection officer

Our external data protection officer will also be happy to provide you with information or advice on the subject of data protection:

Data protection officer (Datenschutzbeauftragter)

c/o AVW Unternehmensgruppe

Hammerbrookstr. 5

20097 Hamburg

Tel.: 02166 / 96 523 - 30

Fax: 02166 / 96 523 - 39

email: datenschutzbeauftragter.avw@securedataservice.de

Validity and revision

It may be necessary to revise this data privacy statement due to the introduction of new technologies, the constant amendment and development of data protection, and most notably changes in basic legal requirements. AVW therefore reserves the right to revise the data privacy statement at any time with effect for the future. We recommend that you read the data privacy statement from time to time and print out a copy for your files.

Last revised: 25.08.2020