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KEY POINTS IN THE FILING AND PROCESSING OF PERSONAL DATA

* The purpose of processing personal data: Clarifying and resolving an advisory case or a dispute that you have submitted to FINE.

* The legal bases for processing personal data:

1) When the case concerns a contract you have entered into as a consumer, the processing of your personal data is based on FINE’s legal obligation to process an insurance, banking or investment service case that falls within its competence.
2) In other cases, the legal basis for processing personal data is FINE’s legitimate interest; FINE cannot examine and process your case without also processing your personal data.

* The categories of personal data being processed: In addition to the personal data and documents you submit with your processing request, FINE will need to request relevant documents and a statement of opposition from the service provider who is the other party in the case. You will be requested for a separate authorisation to obtain documents and data covered by secrecy from the service provider. It may also be necessary to hear other interested parties, such as the injuring party in a liability insurance case. During the processing of the case, FINE will notify you separately about all the data obtained from the aforementioned other interested parties.

* If you are the agent or representative of a customer or a service provider or if you are being heard in relation to a case being processed at FINE, FINE will file as your personal data the necessary name and contact information required for processing the case, such as an email address and a telephone number, as well as any other information you may submit in relation to the case, to the extent necessary for processing the case.

* FINE will protect your data and will not disclose any personal data of interested parties or their representatives to third parties. However, the material you have submitted will be notified to the service provider who is the other party in the case and to any other persons being heard in the case, such as the injuring party in a liability insurance case.

* If FINE considers it necessary to request an expert opinion in order to resolve the case, FINE may disclose data to the expert it employs. FINE may also be obliged to provide data to an authority upon a separate request from that authority under the law.

* FINE will retain your personal information for ten (10) years after the case has been closed. This retention period is based on the legal limitation periods and periods for bringing proceedings.

* The bringing of your dispute to FINE and its processing at FINE also affects the legal status of the other party in the case. The processing of personal data is necessary for the exercise or defence of a legal claim. Your data will not be processed by automated means. For these reasons, under the General Data Protection Regulation, you do not have the right to request the erasure or portability of your personal data or restrict the processing of your personal data or to object to such processing. You have the right to receive confirmation of the processing of your personal data from FINE, to rectify inaccurate data concerning you and to receive a copy of the personal data concerning you that FINE has in its filing system during the data’s storage period.

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