Privacy Policy

AXA, provides you with the TRAVEL EYE service which allows you to receive alerts when you are on a business trip or while on expatriation. This service is organized by us, as well as the company Safeture which provides the platform.
This information notice describes how your Personal Data is collected and processed when you use this service.

Data Controller and Data Processor

The Data Controller, as defined by the General Data Protection Regulation 2016/679 of April 27, 2016 (GDPR), is your employer.
To contact your employer’s data protection officer, please refer to the information provided by the latter for this purpose.
If you wish, you can also contact our data protection officer whose reference contact has been provided in the Information Notice.

Data categories

Your personal data, which can be collected and processed within the framework of the TRAVEL EYE service, are the following:

• Your private or professional identity and contact information (surname, first name, address, e-mail addresses, telephone number, etc.),
• Your policy number or contract number
• Data related to your professional trips (destinations, accommodation, meeting places, routes, means of transport, travel time, etc.),
• If you are on expatriation, the address of your new residence and, subject to your consent and at your initiative, information related to your personal trip, should you wish to benefit from the service during these occasions,
• Location information and geo-location data (GPS location data where actively enabled ),
• Your status data (Emergency, special alerts, status requests, etc.),
• Data related to the computer use of the platform (user ID, roles, permissions, connection time, IP address, other information from cookies, battery level of mobile phone etc.).
  This data can be communicated directly by you. In some cases, it can also be legitimately received from third parties, for example travel agencies, from access to the PNR list. Provided that you have previously given your authorization, it may come from a connection to your professional calendar or from geolocation.

Purpose of processing

The purpose of processing is to:

• Provide you with information and advice on risks and security in the countries where you are or plan to be on a business trip or expatriate from, especially with reports of global incidents but also alerts and security analysis,
• Anticipate crises that may occur during your stay in these same countries and the emergency plans to be implemented,
• If necessary, organize emergency assistance services.

Legal basis

This processing is justified by the legitimate interest of your employer to meet its security obligations towards its employees.
However some processing will only be conducted in line with your consent, for example the enablement and sharing of geolocation/GPS data.

Data recipients

Your Personal Data may be transmitted to companies and / or to people who contribute to the proper performance of the service (such as IT service providers) or subsequently to an assistance provider if necessary.
They may be communicated to the supervisory authorities, to the competent public services as well as to any other public or private body with which we may be required to exchange personal data in accordance with the applicable regulation.

Location of your data

The platform on which your Personal Data is processed is located within the European Union in Sweden.
Your data is not intended to be processed or stored in countries outside the US, EU or the EEA.

Obligation to communicate Personal Data

As a general rule, AXA only process information which is necessary for the conclusion or execution of the contract which we have signed with your employer, in your interest, or which is necessary for the proper execution of a law. Without this information, we would periodically be unable to offer you the information services referred to above, and, if necessary, the security assistance services provided for in the contract signed by your employer.
Unless this is prescribed or required by contract or applicable law, you are not obliged to provide us with any personal data relating to you. You will not suffer any negative consequences by not voluntarily providing us with personal data. However, in certain individual cases, failure to communicate such data to us may delay or prevent communication with you, or even delay, hinder or prevent the provision of specific services such as security assistance.

Data conservation duration

After 6 month personal data which is not in use is deleted.
The data linked to your computer use of the platform (connection and device related data etc.) will be deleted no later than 6 months after your deletion as a user of the platform.
The status data will be anonymized at the latest 6 months after their creation.
All other data will be erased without delay after the end of the business relationship between AXA and your employer, unless legal obligations prevent such erasure. In this case, your personal data will be erased at the end of this legal obligation and the limitation periods for initiating a complaint.

Your rights as a data subject

In line with GDPR, you can request the following from your organisation as it relates to this service:

• confirmation that your Personal Data is or is not being processed and, if applicable, a copy of this Personal data
• the correction of any inaccurate or incomplete Personal Data
• the erasure of your Personal Data or the limitation of certain processing.
  You also have the right to:
• withdraw your consent at any time, without prejudice to the processing carried out lawfully before the withdrawal, when the processing of your Personal Data is based on your consent
• contest, for reasons related to your personal situation, to the processing of your Personal Data based on legitimate interests
• benefit from the transferability of your Personal Data in a machine readable format
• not to be subject to a decision based exclusively on an automated processing, including profiling, that legally affects you or seriously affects you.
  Should you believe that your Personal Data is being processed in a manner not compliant with applicable data protection regulations, you can contact the data protection supervisory authority in place in the country where your employer is located.