Personal Data Security Policy

1.1 Purpose and Objectives of the Policy

The purpose of the Policy is to guarantee and protect the fundamental rights and freedoms of individuals, especially the right to private, family, and personal life, regarding the processing of personal data. The Policy is an integral part of the Broker's development strategy, as compromising the security of personal data will affect its ability to provide services. Thus, the objectives of the Policy are the availability, integrity, and confidentiality of information, including personal data processed by the Broker, information systems, and IT processes. The Policy establishes a set of rules determining the way personal data is collected, classified, and processed, as well as the protection measures for such data.

This Policy extends to and applies to all employees of the Broker and its delegates (assistants), and its regulations represent a standard for them. Each employee of the Broker must sign confidentiality agreements/obligations related to the protection of information that the Broker holds and processes.

Internal regulations and procedures aim to implement this Policy, not replace it.

This policy will be supplemented, updated, and constantly aligned with the legislation of the Republic of Moldova. The policy is not superior to the legislation of the Republic of Moldova.

1.2 Terms and Definitions

Consent

Any manifestation of free, explicit, and unconditional will, in written or electronic form, in accordance with the requirements of the electronic document, through which the data subject agrees to have their personal data processed.

Personal data

Any information related to an identified or identifiable natural person (data subject). An identifiable person is one who can be identified, directly or indirectly, by reference to an identification number or one or more specific elements of their physical, physiological, mental, economic, cultural, or social identity.

User

A person authorized by the Broker, in accordance with the applicable procedures and regulations, to process personal data on behalf of the Broker.

Security

The technical and organizational measures for personal data security are established in such a way as to ensure an adequate level of security for the personal data processed, concerning accidental or unlawful destruction, loss, alteration, disclosure, or unauthorized access.

Database (Personal Data Record System)

Any structured set of personal data accessible according to specific criteria, whether centralized, decentralized, or distributed based on functional or geographical criteria.

2.1 Collection of personal data

The contractor (client), by paying the insurance premium and/or signing the insurance contract, expresses their willful consent for the processing of their personal data by the Broker and/or for the data to be processed by third-party companies in accordance with the applicable legislation and only for the purpose described in point 2.2.

A. Ordinary personal data:

Additionally, in order to improve the quality of its services and ensure the security of personal data, the Broker will use video recordings in its office and audio recordings of all calls.

2.2 The Broker will process the personal data mentioned above for the following purposes:

• Providing insurance services to clients, i.e., issuing insurance contracts (other legal operations such as contract modifications, additional agreements, contract termination; issuing invoices and other primary accounting documents); refusal by the client of the personal data processing by the Broker is equivalent to the impossibility of providing intermediary insurance services.
• Conclusion of partnership contracts (other legal operations such as contract modifications, contract termination; issuing invoices and other primary accounting documents)
• Conclusion of mandate contracts with insurers (other legal operations such as contract modifications, contract termination; issuing invoices and other primary accounting documents)
• Preparation of financial and statistical reports
• Conducting market studies or direct marketing
• Organization of promotional campaigns to promote the Broker's image

2.3 Transmission of personal data

Personal data may be transmitted to state institutions to which the Broker is subordinated and that monitor the Broker's activity in accordance with the applicable legislation (National Commission for Financial Markets, National Bank of Moldova, Tax Service, National Bureau of Statistics), only for statistical purposes and solely to comply with the obligations arising from the applicable legal framework.

The transmission of personal data to third parties will be carried out both in physical form (paper documents, insurance contracts) and electronic form (reports), in accordance with the Broker's internal procedures, respecting all security standards to avoid information leaks, human errors, and the destruction or distortion of personal data.

Exercise of rights:

To exercise one or more rights regarding the processing of personal data, including the right to delete data, the data subject may submit a written, dated, and signed request (complaint) either in paper form or electronically (using an advanced electronic signature) to the operator's office at M. Kogălniceanu 12, Chisinau, or via email: info@easig.md.

Any written complaint addressed to the operator will be processed appropriately, in accordance with its internal procedures.

In order to ensure quality services and comply with legal provisions, especially in the field of preventing and combating money laundering and terrorist financing, all responses provided to the operator are mandatory. Refusal by the data subject to provide the personal data required for fulfilling the proposed/requested activity may result in the impossibility of providing insurance services and/or achieving other data processing purposes by the operator.