Aon Privacy Statement

Aon is a leading risk management, employee benefits and insurance broker and also active as a Managing General Agent under the name One Underwriting (hereinafter referred to as ‘Aon’).

Who is responsible for your information?
Throughout this Statement, “Aon” refers to Aon plc, including its affiliated companies and subsidiaries (also referred to as “we,” “us,” or “our”). Personal information is collected by each member of the Aon group who is responsible for its processing in their capacity as a controller. A full list of our group entities is available here. These entities may provide separate privacy notices when your personal information is first collected by that Aon entity, for example, when you or the business you work for engages us to provide a service.

Aon entities also provide services to our clients as a processor. Where this is the case we will process your personal information in line with our legal obligations and contractual commitments with our clients.

We use personal data to provide our services. We also work with other organizations or companies including, in any event, insurers. We believe it is very important to handle personal data with care. Therefore, we carefully process and secure personal data, having due regard for privacy legislation.

Use of personal data
For the provision of our services, Aon uses personal data (data that can be traced back to a private individual), such as:
- name, address, contact details, date of birth, gender, nationality and marital status;
- financial details such as bank account numbers and card details, data on credit history and status as regards bankruptcy or suspension of payments;
- demographic data, such as information about lifestyle and insurance needs;
- data on driving behavior and details concerning driver’s license, insurance history and claims history.

We may also process special data such as criminal data or health data in order, for example, to effect accident -, medical expenses - or professional liability insurances and deal with claims. We will only process the data necessary for the provision of our services. If certain data are not provided, this may prevent us from providing the requested services or processing or paying out a claim. If you provide us with data on third parties (your partner, children, co-insured or data on emergency contacts), we assume that you inform them about the processing of their data by Aon and make them aware of this privacy statement.

Besides the information that you personally provide, Aon may obtain information from third parties. For example, data are processed to prevent fraud against financial institutions and Aon also consults third parties for data on fraud (FRISS) and creditworthiness (Focum). If Aon acts as a Managing General Agent, Aon also conforms to the Code of Conduct for the Processing of Personal Data by Insurers, the Protocol for the Incident Alert System for Financial Institutions (www.verzekeraars.nl) and the CIS Privacy Regulations (www.stichtingcis.nl). These data may be requested both during and before the provision of our services. In these situations, Aon has a legitimate interest in processing your data. You may object to this processing.

Aon processes the data as part of its business operations, including
- the provision of the services requested by you;
- broking and advising on, accepting, administrating and managing of insurances;
- claims handling;
- investigating claims or complaints or (legal) disputes in connection with insurance policies or the services provided;
- consultancy in the field of risk management;
- risk management of Aon;
- consultancy on pensions and absenteeism support;
- researching customer satisfaction;
- internal reporting, statistical analysis, marketing Aon products and services and improving products and services;
- investigating creditworthiness and credit control policy;
- investigating sanctions imposed, validating and where necessary exchange of data (with Stichting CIS, police, justice etc.), facilitating prevention, detecting and/or investigating criminal activity; (among others based on statistical analyzes);
- fulfilling legal obligations;
- the fulfillment of obligations under the agreements with insurers;
- cost of claims limitation, through a responsible acceptance policy;
- the provision of other products that may be of interest to you;
- for marketing purposes, such as: (1) promotional purposes. This includes sending newsletters, displaying information, sending user information, service messages or other electronic messages on the website of Aon Netherlands and beyond, via advertising networks and social media channels such as Facebook, Instagram, Twitter and LinkedIn; and (2) profiling purposes. This includes sharing and combining personal data within Aon Netherlands group companies to develop a profile. This allows us to better tailor the content of our websites, information, products and services to your interests and behavior. This includes personal data such as name, gender, e-mail address, telephone number, date of birth and interaction data (such as IP address, surfing and clicking behavior on websites and apps, location data and cookie ID).

The information may be stored on internal and external systems, including customer relationship management applications. Through these systems, the Aon employees concerned have access to these data, which they may use solely for the purposes for which Aon processes the data.

Recording of telephone conversations
Telephone conversations with clients may be recorded at random for purposes of training of Aon customer service employees. Furthermore, certain telephone conversations will be recorded for the following specific, predefined and lawful purposes:
1. Verification of and enquiry regarding requests, transactions and other (precontractual) agreements with a client;
2. For purposes of detection and/or countering fraudulent activities or other criminal activities which may be aimed at Aon, the Aon group of companies or its clients or employees;
3. When obliged by law.

In principle, recorded conversations will only be reviewed in cases where the content of the conversation is unclear or subject to dispute. The recorded conversations and any personal information regarding the recording will be stored in such a manner that these are not accessible by unauthorized persons. Authorizations for access is governed by the Aon Privacy Protocol on access to telephone conversations recordings. Technical and organizational measures have been taken to prevent manipulation of recordings and to ensure that information can be traced and reconstructed. In cases where the contents of a recording give rise to differences in interpretation or dispute, a client will have the right to listen to the recorded conversation. This enables both Aon and the client to reach an acceptable solution for disputes which arose from transactions which were concluded via telephone conversation.

Principles and lawfulness for processing by Aon:

Performance of the agreement
In connection with the services we provide and the establishment of agreements, we obtain and use the personal data necessary to make an offer, establish and perform the agreement.

Compliance with a legal obligation
It may be necessary to process data to comply with legal obligations. For example, Aon is required under the Financial Supervision Act to hold a license and is supervised by the AFM. Aon has a duty to abide by the applicable rules.

Legitimate interest
The collection and use of certain data is necessary to exercise legitimate commercial interests, such as offering products that might be of interest to you or engaging in market research to improve our products and services. When we process your data on this basis, we will make sure that the necessary steps are taken to ensure that the processing does not infringe your rights and freedoms under privacy laws.

Consent
We process data based on consent when we process special data in conjunction with activities such as profiling. You are free to withhold or withdraw your consent at any time. However, without your consent, we may not be able to provide our services. Whenever special data are needed, and you wish to use our services, you agree to the collection and use of those special data.

Disclosure to third parties
We engage third parties for the performance of our services. In this context, we may share data with:
- insurers and brokers, when necessary to arrange insurance and provide our services;
- assessment offices, lawyers and research companies for work relating to claims and the required reports;
- investigation authorities, where necessary to prevent or investigate fraud and criminal acts;
- government authorities, where necessary for Aon to fulfil its legal obligations. In connection with motor vehicle insurance, data are shared with the Rijksdienst voor het Wegverkeer (Dutch National Road Authority);
- third parties when work is outsourced. This work will be done under Aon’s responsibility, in accordance with our security standards and on our instructions;
- legal successors, in the event that the services are sold to another organization or of the takeover or sale of (part of) Aon. If personal data are shared in this situation, the data will continue to be used in accordance with this statement;
- medical experts, e.g. in the case of services relating to medical expenses insurance and claims handling;
- research companies whose services are engaged in connection with research into creditworthiness, criminal past, fraud (and the issue of certificates of good conduct) to detect and prevent fraud in the insurance industry;
- mailing and promotion companies for making a sales promotion gift available and / or offering other products that may be of interest to you.

Processing outside the EU
Aon is a global organization with business processes, management structures and technical systems that extend beyond geographical borders. Considering the global nature of the services provided by Aon, personal data may be transmitted to and used, stored and otherwise processed in countries other than the country in which the information was obtained. In all cases, Aon will ensure an adequate level of security by means of the standard EU agreements or a license.

Security levels
It is our responsibility to ensure the most extensive protection possible for the personal data we process against loss or unauthorized use. We take adequate security measures to guarantee the security and accuracy of those data. If, despite these measures, a data breach might occur, Aon has a procedure in place for the proper reporting and handling of the breach.

Direct Marketing
We will use your personal data for direct marketing for other services and products which we believe may be of interest to you. However, we will give you the opportunity to indicate your preferences for direct marketing activities.

Automatic data collection
Aon may also collect information by means of cookies when you visit an Aon website or use mobile apps. Cookies are small, simple text files that are placed on your computer, tablet or mobile phone when you visit one of our websites or apps. These files store information about your website/app visit, to provide you with the best possible service. Aon gives you the opportunity to refuse consent to this automatic data collection. However, if you do not consent, Aon may not be able to (fully) provide its services for you. Find out more here about our use of cookies.

Third party websites
Via Aon’s websites, you can click through to other websites that are managed by Aon and its subsidiaries and operating companies in the various countries. Aon may also provide links to websites that are not managed by Aon. Such websites are not monitored by Aon and Aon is not responsible for the privacy policy or content of such external websites.

Data of minors
Our websites are not aimed at children aged under 16 years.

Accuracy of data
To properly provide our services, we rely on the accuracy of the data available to us. Therefore, we expect that you will inform us of changes to your data.

Right of access/rectification/objection/data portability and deletion
You have the following rights regarding your data that we process:
- right of access regarding the processing of your personal data by Aon;
- the right to have data rectified, frozen and/or deleted, particularly when further processing of your data is no longer required;
- right to object to the use of data for marketing purposes;
- right to object to the further processing of your personal data;
- the right to receive a copy of your data for purposes of transfer to another party.

Some of these rights may only be exercised in specific situations. If we are not able to comply with a request, we will notify you accordingly. To exercise these rights and obtain further information about this Privacy Statement, please submit your request at www.aon.nl/privacyverzoek.

Aon keeps your data for as long as is necessary for the purposes for which the data are processed. Aon must also keep data in order to fulfil the duty to keep records and the duty of care, for the purposes of providing evidence and to comply with laws and regulations. After expiry the retention periods, Aon will delete the data.

We reserve the right to delete defamatory, libelous and unlawful posts on the Internet and social media, as well as spam.

If you decide to respond to our content via social media, we may investigate the sender. If it is necessary for us to report such posts, we may also investigate the sender for that purpose.

We value your opinion. Please send your comments or questions about our privacy statement to [email protected], or write to us at the following address: Aon Groep Nederland B.V. Attn. Legal & Compliance department P.O. Box 518 3000 AM Rotterdam

You can also contact our Data Protection Officer:
mr. R. Blokland
[email protected]

Dutch Data Protection Authority (DPA)
If you have any complaints about the processing of your personal data by Aon, please inform us so that we can work with you to find a solution. You have the right to submit a complaint to the privacy supervisor, the Dutch Data Protection Authority.

This privacy statement is not an agreement and we may update this privacy statement from time to time. The date of the change will be updated as soon as we make changes. We will inform you of changes in various ways, including by publishing the revised privacy statement on our website, after which the revised statement will take immediate effect. You should consult this statement from time to time to ensure that you are aware of how Aon handles your personal data.

This privacy statement was last updated on May 1, 2021.