Privacy statement

Version: 16 July 2024

Privacy and security

At Tulip Assist, we consider your privacy and the safe processing of your personal data very important. Of course, you want to apply for insurance for your device without worrying about privacy and online safety. We want that for you too! That is why we would like to show you how we process your personal data.

Who is responsible for your data?

Tulip Assist Insurance Limited is responsible for all personal data you submit to Tulip Assist, a brand of Tulip Assist Services BV. These are our details:

You have taken out the insurance via Tulip Assist (Tulip Assist Services BV)

You have taken out the insurance with Tulip Assist Insurance Limited

Tulip Assist Insurance Limited is registered in Malta under the following registration number - C80601, having its registered office at Development House, St. Anne Street, Floriana FRN9010, Malta, and is authorised by the Malta Financial Services Authority to engage in the business of insurances under the Maltese Insurance Act (Chapter 403 of the Maltese legislation). Details can be found at https://www.mfsa.mt/financial-services-register/result/?id=12648.

For questions concerning privacy and security, you can always contact team Privacy and the Data Protection Officer (FG) at privacy@tulipassist.at. Tulip Assist's Data Protection Officer (FG) is officially registered at the Dutch Personal Data Authority (AP)..

What data do we store and why?

Tulip Assist collects personal data in various ways. Exactly what data is collected depends on what you do on our website and whether you have applied for Tulip Assist insurance. We expect you to always share accurate personal data with Tulip Assist and to notify us of any changes in a timely manner. We are happy to explain what data of yours we process.

Customer data

We obviously need to know who you are if you have applied for a Tulip Assist insurance policy. That way we can help you in the best way possible. We ask you to state your gender, so that we can address you correctly. It is compulsory to provide your first name and/or initials and surname along with your address details when you apply for an insurance. Additionally, we are obligated to collect your date of birth in order to perform a check to see if you are 18 years of age or older, and thus entitled to purchase an insurance from Tulip Assist. We need this information from you because of contractual obligations to be able to process and accept your insurance application.

We will send you updates about your insurance by email, and sometimes by text message. For this, we need your email address. We will also send you invoices and information about the products you have purchased. After your application, we will sometimes ask you what you think of us, usually by email and sometimes by phone. Thanks to your feedback, we can continue to improve ourselves!

Payment

If you submit an application for an insurance from Tulip Assist, we are always required to share your bank account number (IBAN number) with Tulip Assist. We will use your IBAN number with your explicit consent to collect your monthly premium via direct debit. We will also use your IBAN number to verify your identity.

Your insurance is always paid via direct debit and in some cases via a secure payment environment. The linking of your payment to your insurance is also done via a secure environment. When making a payment, we send your details from our secure payment environment directly to the payment processors.

Product details

When you apply for Tulip Assist insurance, we store your phone's IMEI and EAN number, along with some other information about your phone, such as the brand and type. The IMEI number is a unique code linked to your specific product. The EAN number is a number linked to the type of product you have. This way we can be sure you are actually insured for the phone you bought.

Insurance details

As soon as your Tulip Assist insurance is approved and activated, we link your policy to an insurance number. We also store some product data, like the type of insurance, the phone type you have insured, and the start and end date of your policy. We need this data to properly record your insurance.

Should you submit a damage claim, we always ask you to fill in a number of details, such as the location of the damage, type of damage, description of damage, where/how phone was stored, when the damage was discovered, witnesses (witnesses' names and address), third-party liability, third-party names and address, reason for claim, insurance company/owner, and insurance number. We also always link your claim to a specific damage ID. We need this data to process your claim in the best way possible.

Communication

We like to keep you informed about your insurance, application, or claims by mail, email, phone, or text message. Sometimes we will send you service messages about tips and tricks, security updates, review requests, information about when your insurance expires, or other relevant information. Do you no longer wish to receive these service messages? Please contact Tulip Assist customer service (info@tulipassist.at).

We use the following communication preferences: Service messages (always enabled) You will receive information about your insurance, customer account, payment, and invoices. From time to time, you may receive additional information about your insurance, such as user tips, updates, notifications, and review requests.

Newsletter

You will receive our newsletter by email. Of course, you will only receive it if you have given us explicit permission to do so. Do you no longer want to receive our newsletter? Then you can unsubscribe by clicking the "unsubscribe" button at the bottom of the newsletter, or inform our customer service.

Online recognition

When you visit our website, we store your IP address, click data and cookies. This allows us to offer you a personalised experience, matching your preferences.

Customer service

When you contact our customer service, we want to help you as best as we can. To do this, we store the email conversations you have with our customer service staff. Phone calls may also be recorded for coaching purposes. We will always inform you of this before the phone call. Sometimes we ask you to provide us with specific personal information during an email or phone call. We ask these questions in order to verify that you really are the customer of the insurance you’re asking about. We also make notes of our contact, so we know exactly what has been discussed when you contact us again.

Repair

Has your claim been approved and do we ask you to send in your device for repair? We'll be happy to help! Before you send your device to Tulip Assist, it is important to create a back-up and reset it to factory settings. This is essential for processing and it also removes all personal data from your device.

You are responsible for resetting your device yourself (when possible). If you don't do this or if it is unsuccessful, the data will still be deleted from your device, if at all possible. Additionally, you then also consent to your data possibly being forwarded to, for example, a repair company.

Repairs are carried out by specialised repair companies. Is your device, or a component, being replaced by a new one? Then your old device or component will be carefully destroyed or recycled by the repair company.

Profiling and automatic decisions

When you submit an insurance application, we make an automatic decision on your application. We look at various factors, such as your claim history, age (18 years or older), and registration in online databases.

If you visit our website or file a claim with us, in some cases we would like to know how you completed your claim. We may store your completed data, click behaviour, fill-in behaviour, and choices. In some cases, we may combine this data with each other, to best assess your claim based on this information and profiling.

How do we handle the sharing and storing of your personal data?

Sharing personal data

Your privacy is very important to us. That is why we only share certain or specific personal data with partners and third parties if this is really necessary, for example because it is necessary for your insurance. We never sell your data to third parties.

In order to arrange this properly, we have entered into a processing agreement with all parties with whom we share your personal data. This is a contract in which clear agreements are made about who is responsible for what data. There are various parties with whom we share your personal data to ensure that your device is insured quickly and we can provide you with the best possible service:

• Tulip Assist Insurance Limited
• The processor of payment data;
• The processor of communication data (e.g., telephony, text messaging, and email);
• The processor of customer information (credit and payment risks);
• Administrative processors;
• If applicable and explicitly agreed: (Online) marketing channels;
• If applicable: the reseller;
• If applicable: the package delivery company;
• If applicable: the device manufacturer;
• If applicable: the risk assessor;
• If applicable: the identity data processor;
• If applicable: the repair company;
• Good to know: if you send in a device for repair, you are responsible for restoring your device to its factory settings (if possible) before sending it to Tulip Assist.

Most parties are based in the European Union and are subject to the General Data Protection Regulation. In some cases, we also share certain details with partners based in the United States of America (USA) who were previously voluntary members of the European-American 'Privacy Shield.' We have made strict agreements with these parties concerning the processing of personal data. We have set out these agreements in standard contractual clauses (SCC).

Storing your personal data

We do not store your personal data longer than necessary. In some cases, we may need your personal data to detect fraud or illegal activities. In this case, we have a legal obligation to share this personal data with the police, the judiciary, or the public prosecutor when a request comes to us. Besides this, we have a tax responsibility to the tax authorities. This means that, from a legitimate, legal, and commercial point of view, we store your personal data in order to deliver the products and services you have ordered and to provide you with the safest and most reliable service possible.

Would you like us to change your privacy preferences for you? Then please contact our privacy team: privacy@tulipassist.at

Securing your personal data

We always provide the best possible information security. Our website has a secure connection (recognisable by the 'https' in the address bar) and SSL certificates. Moreover, we always use the best security software to ensure that your personal data is stored as securely as possible. This is done in ISO 27001 certified data centres on our own servers in the Netherlands.

We check and monitor all our employees, who has access to which personal data, and we keep track of who has accessed which personal data. This way, we always know what happens to your personal data. All employees also have a Certificate of Good Conduct (VOG), so we can be sure that everyone handles your personal data in a secure manner.

Your rights concerning your data

You may, of course, always submit a request for the inspection, rectification, data portability, or removal of your personal data from our file. In addition, you may always express your point of view or challenge a decision if you disagree with the way your insurance application or claim has been handled. You always have the right to a human review if we have made an automatic decision on your application or claim. You can request this through our customer service. In doing so, we ask you to verify that it is really you, so that we don't share your details with someone else.

Deleting your data

Of course, you can delete the data we have of you, if you want to. This means you will no longer be a customer of Tulip Assist Insurance, your policy expires, and your insurance will be terminated by the insurer. This is because we will erase your data and will no longer know if you have ordered a certain product from us. Your request will be dealt with by our customer service within 15 business days.

Don't want to receive our newsletter anymore? Then you can easily unsubscribe at the bottom of the newsletter.

Vragen of opmerkingen

If you have any questions or comments about privacy and security, you can always contact our customer service. For further questions or complaints, please contact the Dutch Data Protection Authority or the National Ombudsman.