Data protection policy

Axeria IARD SA Lyon – Sucursala Bucuresti, headquartered in Romania, 212 – 214 Gheorghe Titeica St. (2nd floor), Sector 2, Bucharest, Trade Registry number J2021011706408, registration number CUI 44552384, acting as a branch of AXERIA IARD, a company incorporated in France with share capital of 38,000,000 euros, (registration number 352 893 200) and having its registered office at 129 avenue Felix Faure 69003 Lyon (postal address: 26 rue du Général Mouton Duvernet 69003 Lyon) hereinafter referred to as “Axeria RO” attaches great importance to the protection of your personal data in accordance with the Applicable Privacy Law .

The purpose of this Privacy Policy is to inform Data Subjects of the existence of the Data Processing implemented by Axeria RO in its capacity as Data Controller and the procedures for its implementation.

1. DEFINITIONS

The following terms, whether used in the singular or plural in this Privacy Policy, shall have the following definition:

DEFINITIONS
The following terms, whether used in the singular or plural in this Privacy Policy, shall have the following definition:

Axeria RO:: means the company, acting in its capacity as Data Controller, referred to in the legal notice accessible from the Site.
Data Controller:: means the person, whether natural or legal, who determines the purposes of the Processing and the means by which it is carried out.
Data Processor:: means the natural or legal person, public authority, department or other body which processes Personal Data on behalf of the Data Controller.
Data Subjects:: means the natural person whose Personal Data is processed by Axeria RO as defined in this Privacy Policy.
GDPR:: means Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, applicable starting with 25th May 2018.
Insureds:: means any natural person of legal age who takes out an insurance policy with Axeria RO, for their personal needs, in accordance with the terms and conditions described in the “Products and Services” section of the Site.
Intermediate archiving:: means the removal of Personal Data that is still of administrative interest to Axeria RO (such as in the event of litigation) and/or in the event of a legal obligation, into a separate database, logically or physically separate and to which access is restricted in any event. This archive is an intermediate step before the relevant Personal Data is deleted or made anonymous.
Personal Data:: means the personal data of the Data Subject, as defined in the Personal Data Regulations, collected and processed by Axeria RO.
Personal Data Regulations:: means the relevant data protection and privacy law, including GDPR, applicable to the Data Subjects.
Privacy Policy:: means this policy on the confidentiality and protection of the Personal Data of Data Subjects implemented by Axeria RO.
Processing:: means any operation or set of operations carried out by Axeria RO in its capacity as Data Controller.
Specific rights:: means the rights granted by the Personal Data Regulations to Data Subjects with regard to the Processing of their Personal Data.
Site:: means the website accessible at the URL address: https://www.axeria-iard.ro/ on which this Privacy Policy is hosted.
Terminal(s):: means the hardware equipment (computer, tablet, smartphone, telephone, etc.) used by Data Subjects to consult or view the Site and/or any other digital medium published by a third party.
Users:: refers to all users of and visitors to the Site, including Insureds, Candidates, Brokers, prospects, injured persons, as well as any other individuals whose Personal Data are Processed in the context of this Privacy Policy.

2. PROCESSING OF YOUR PERSONAL DATA

We collect Personal Data:

Directly from you (via forms, contracts, contact)
From intermediaries (e.g., Brokers)
From public sources (e.g., government databases)
Through the Site using cookies and similar technologies whose dedicated policy is available here.

We use your Personal Data to enable you to access, use and improve the Site, and generally in connection with your relationship with Axeria RO in order to:

Using the Site: this Processing is based on Axeria RO’s legitimate interest in enabling Users to browse the Site, for which Personal Data, processed through session cookies, is kept for the duration indicated in the cookie policy available here.
The preparation of commercial statistics, analyses and marketing tools (in particular classification, scoring, etc.): this Processing is based on the consent of the Data Subjects, for which the Personal Data is kept for a period of thirteen (13) months.
Management of requests to exercise Specific Rights under the conditions set out in Article 8 – Specific Rights: this Processing is based on a legal obligation incumbent on Axeria RO, for which Personal Data is kept in an active database for the duration of the request, then in an Intermediate Archive for a period of three (3) years.
Online claims management: Personal Data is collected and processed in accordance with the dedicated privacy policy accessible here
Online complaints management: this Processing is based on contract performance, for which Personal Data is kept in an active database for the duration of the contract, then in an Intermediate Archive for a period of four (4) years.
Manage requests made using the contact form available here: this Processing is based on a legitimate interest of Axeria RO to handle and answer requests from Data Subjects, for which Personal Data is kept in an active database for the duration of the request, then in an Intermediate Archive for a period of three (3) years.

These processing operations are carried out in compliance with the Personal Data Regulations.

Each User is invited to read this Privacy Policy, which is available on the Site or may be obtained on request from Axeria RO by sending an e-mail to the following address: dpo@axeria-iard.ro

3. COLLECTION OF YOUR PERSONAL DATA

Axeria RO collects the following categories of Personal Data from you when you browse the Site, create an Account and then add to it as you go along, or when you contact Axeria RO by telephone, electronically or in person:

Identification data: surname, first name, gender, date of birth, postal address, e-mail address, telephone number.
Browsing data (date, time, IP address, pages viewed) of the Data Subject when browsing the Site.

4. STORAGE OF PERSONAL DATA

The Site is hosted by the company whose contact details are available by clicking here.

Every precaution has been taken to store the Personal Data of Data Subjects in a secure environment and prevent it from being distorted, damaged or accessed by unauthorized third parties. Personal Data transmitted by the Data Subject will never be passed on to third parties for commercial purposes, nor will it be sold or exchanged.

5. RECIPIENTS OR CATEGORIES OF RECIPIENTS

During our business, we may use Data Processors to provide certain services on our behalf. As a result, some of your Personal Data may be transmitted. However, our Data Processors may not use your Personal Data for any purpose other than those requested. The collected Personal Data is reserved for the exclusive use of Axeria RO and the following Data Processors:

In charge of hosting the Site.
In charge of the development and maintenance of the Site.
To handle certain claims made online.

As the Data Controller, Axeria RO undertakes not to transfer Personal Data outside the European Union. In the event of such a transfer, Axeria RO undertakes to implement appropriate safeguards in accordance with the European General Data Protection Regulation (GDPR), and in particular to implement the Standard Contractual Clauses adopted by the European Commission in their current version.

Recipient of Personal Data	Type of Personal Data transferred	Purpose of the planned transfer	Data localisation	Level of protection offered by the country or exception provided for in the Personal Data Regulations
Cyberfolks	All Personal Data processed from the Site	Site hosting	Romania	Suitable
Intaro	All Personal Data processed from the Site	Website facilities management maintenance	Romania	Suitable
Intaro	All personal data processed via the online complaints management platform, MTPL public calculator and claims notification platform	Publisher of the platform and Data Processor for certain online claims, complaints and calculating MTPL premiums	Romania	Suitable

6. HYPERTEXT LINKS

On the Site, Users may access other websites via hypertext links making referrals to the relevant authorities. If Users decide to access these sites from the Site, they leave the Site. Axeria RO invites Users to consult the privacy policy of the website concerned in order to understand how their Personal Data is shared and used in this context.

7. DATA SECURITY AND CONFIDENTIALITY

In accordance with the Personal Data Regulations, Axeria RO implements all appropriate technical, physical, and organisational measures with regard to the nature of the Personal Data and the risks presented by the Processing, to preserve the security and confidentiality of Users’ Personal Data, in particular to prevent it from being deformed, damaged, or accessed by unauthorised third parties.

8. SPECIFIC RIGHTS

In accordance with the Personal Data Regulations, the Data Subject may, at any time, benefit from the following Specific Rights of/to:

Access your Personal Data
Correction
Deletion
Limitation of Processing
Portability
Objection
Post-mortem instructions
- Access rights

The Data Subject may obtain from Axeria RO confirmation as to whether Personal Data relating to him or her is being processed and, where Personal Data is being processed, access to such Personal Data and the following information:

The purposes of the Processing
Categories of Personal Data
The recipients or categories of recipients to whom the Personal Data have been or will be communicated
Where possible, the intended retention period for Personal Data or, where this is not possible, the criteria used to determine this period
The existence of the right to ask Axeria RO to rectify or delete Personal Data, or to limit the Processing of Personal Data, or the right to object to such Processing
The right to lodge a complaint with the ANSPDCP
Where Personal Data is not collected from the Data Subject, any available information as to its source
The existence of automated decision-making, including profiling, and, at least in such cases, useful information concerning the underlying logic and the significance and intended consequences of such processing for the Data Subject

Where Personal Data is transferred to a third country or to an international organization, the Data Subject has the right to be informed of the appropriate safeguards with respect to such transfer.

Axeria RO provides a copy of the Personal Data being processed.

Axeria RO may charge a reasonable fee based on administrative costs for any additional copies requested by the Data Subject.

Where the Data Subject submits his or her request electronically, the information shall be provided in a commonly used electronic form, unless he or she requests otherwise.

The Data Subject’s right to obtain a copy of his or her Personal Data must not infringe the rights and freedoms of others.

Rights of rectification

The Data Subject may obtain from Axeria RO, as soon as possible, the rectification of any Personal Data concerning him or her that is inaccurate. The Data Subject may also request that incomplete Personal Data be completed, including by providing an additional declaration.

Erasure rights

The Data Subject may obtain from Axeria RO the deletion, as soon as possible, of Personal Data concerning him or her where one of the following reasons applies:

Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed by Axeria RO
The Data Subject has withdrawn his/her consent to the Processing of this Personal Data and there is no other legal basis for the Processing
The Data Subject exercises his/her right to object under the conditions set out below and there is no compelling legitimate reason for the Processing
The Personal Data has been processed unlawfully
Personal Data must be deleted to comply with a legal obligation
The Personal Data has been collected from a child.
- Limitation rights

The Data Subject may obtain from Axeria RO the limitation of the Processing of his/her Personal Data where one of the following grounds applies:

Axeria RO shall verify the accuracy of the Personal Data following a challenge by the Data Subject to the accuracy of the Personal Data
The Processing is unlawful and the Data Subject objects to the erasure of the Personal Data and instead requests that its use be restricted.
Axeria RO no longer requires Personal Data for the purposes of Processing, but it is still necessary for the Data Subject to establish, exercise or defend legal claims
The Data Subject has objected to the Processing under the conditions set out below and Axeria RO verifies whether the legitimate reasons pursued prevail over the alleged reasons.
- Right to data portability

The Data Subject has the right to receive from Axeria RO Personal Data in a structured, commonly used and machine-readable format where:

The Processing of Personal Data is based on consent or on a contract
Processing is carried out using automated processes.

Where the Data Subject exercises his or her right to portability, he or she has the right to have the Personal Data transmitted directly by Axeria RO to another Data Controller designated by him or her, where technically possible.

The Data Subject’s right to the portability of his or her Personal Data must not infringe the rights and freedoms of others.

Right to object

The Data Subject may object at any time, on grounds relating to his or her particular situation, to the Processing of his or her Personal Data based on Axeria RO’s legitimate interests. Axeria RO will then no longer process the Personal Data, unless it can demonstrate that there are compelling legitimate grounds for the Processing which override the interests and rights and freedoms of the Data Subject, or may retain the Personal Data for the establishment, exercise or defense of legal claims.

Post-mortem instructions

The Data Subject may provide Axeria RO with instructions regarding the retention, deletion and sharing of his or her Personal Data after his or her death, which instructions may also be registered with a “certified trusted digital third party”. These directives, or a sort of “digital will”, may designate a person to be responsible for their execution; failing this, the heirs of the Data Subject will be designated.

In the absence of a directive, the heirs of the Data Subject may contact Axeria RO in order to obtain information:

To access the processing of personal data for the purpose of “organizing and settling the estate of the deceased“
Receive communication of “digital assets” or “data resembling family souvenirs, which may be passed on to heirs“
Close the Data Subject’s Account on the Site and oppose the continued Processing of his/her Personal Data.

In any event, the Data Subject may inform Axeria RO at any time that he or she does not wish his or her Personal Data to be communicated to a third party in the event of his or her death.

9. EXERCISE OF SPECIFIC RIGHTS

These rights may be exercised at any time by contacting Axeria RO by e-mail at the following address: dpo@axeria-iard.ro.

For the purposes of enforcing its rights under the conditions set out above and in the event that Axeria RO has doubts about the person making the request, Axeria RO may ask the latter to prove his or her identity by providing his or her surname, first name and e-mail address and to accompany the request with a copy of a valid form of identification.

A reply will be sent to the Data Subject within a maximum of one (1) month following the date of receipt of the request.

If necessary, this period may be extended by two (2) months by Axeria RO, which will notify the Data Subject, taking into account the complexity and/or number of requests.

Should the Data Subject request the deletion of his or her Personal Data, Axeria RO may nevertheless retain such Personal Data in the form of Intermediate Archiving for the period necessary to meet its legal obligations, or for evidentiary purposes during the applicable limitation period.

The Data Subject may also lodge a complaint with the competent supervisory authority/ In Romania, this is the National Supervisory Authority for Personal Data Processing whose address is B-dul G-ral. Gheorghe Magheru 28-30 Sector 1, postal code 01033 Bucharest, Romania.

Version in force on: 01.03.2026.

AXERIA IARD SA Lyon – Sucursala Bucuresti
Str. Gheorghe Titeica 212-214 (Floreasca), Sector 2, Bucuresti - Cladirea Ethos House, Etaj 2
J2021011706408 CUI 44552384
Autorizata si inregistrata sub numarul 352893200 si supervizata de Autorité de contrôle prudentiel et de résolution (ACPR) Franta https://acpr.banque-france.fr