Lockton Insurance Brokers Denmark Aps Privacy Notice

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Lockton Insurance BrokersDenmark Aps Privacy NoticeLast updated: 22nd October 2021

ContentsLOCKTON INSURANCE BROKERS DENMARK APS PRIVACY NOTICE.1SECTION 1: INTRODUCTION – HOW THE INSURANCE MARKET WORKS.2SECTION 2: THE DATA WE MAY COLLECT ABOUT YOU (YOUR PERSONAL DATA).3SECTION 3: WHERE WE MIGHT COLLECT YOUR PERSONAL DATA FROM.5SECTION 4: THE PURPOSES, CATEGORIES, LEGAL GROUNDS AND RECIPIENTS,OF OUR PROCESSING OF YOUR PERSONAL DATA.2SECTION 5: CONSENT. 10SECTION 6: PROFILING AND AUTOMATED DECISION MAKING. 10SECTION 7: DATA SECURITY . 11SECTION 8: RETENTION OF YOUR PERSONAL DATA . 11SECTION 9: INTERNATIONAL TRANSFERS. 11SECTION 10: YOUR RIGHTS AND CONTACT DETAILS OF THE ICO . 12SECTION 11: GLOSSARY OF KEY TERMS. 13

Lockton Insurance Brokers DenmarkAps Privacy NoticeLast updated: 22nd October 2021What is the purpose of this document?Lockton Insurance Brokers Denmark Aps is committedto protecting the privacy and security of your personaldata.This notice describes how we, as an intermediary,collect and use personal data about you during and afteryour engagement with us, in accordance with theapplicable Data Protection Laws, including the GeneralData Protection Regulation ("GDPR") and the DanishData Protection Act ("DDPA"). In particular this notice isdesigned to help you understand how we process yourpersonal data through the insurance lifecycle. Insuranceis the pooling and sharing of risk in order to provideprotection against a possible eventuality. In order to dothis, information, including your personal data, needs tobe shared between different insurance marketparticipants. The insurance market is committed tosafeguarding that information.This notice also aims to give you information on howLockton Insurance Brokers Denmark ApS collects andprocesses your personal data through your use of thiswebsite, including any data you may provide throughthis website, for example when you sign up to ournewsletter or fill in our contact us form. In particular,this notice, together with the Terms of Use and CookiesNotice sets out how we look after your personal datawhen you visit our website (regardless of where you visitit from) and tells you about your privacy rights and howthe law protects you.ControllerLockton Insurance Brokers Denmark ApS is a “datacontroller”. This means that we are responsible fordeciding how we process personal data about you. Weare required under the GDPR to notify you of theinformation contained in this privacy notice.Our Data Protection ManagerWe have appointed a data protection manager tooversee compliance with and questions in relation to thisprivacy notice.If you have any questions about this privacy notice,including any requests to exercise your legal rights,please contact our Data Protection Manager using thedetails set out below:Contact DetailsData Protection ManagerLockton Insurance Brokers Denmark ApSHellerupgardvej 18 2900 Hellerup Copenhagen, DenmarkEmail: dataprotection@uk.lockton.comLockton is committed to protecting the privacy needs ofchildren and encourages parents and guardians to takean active role in their children’s online activities andinterests. Lockton does not intentionally collectpersonal data from children, and Lockton does nottarget its website to children.It is important that you read this notice, together withany other privacy notice we may provide on specificoccasions when we are collecting or processing personaldata about you, so that you are aware of how and whywe are using such personal data. This privacy noticesupplements the other notices and is not intended tooverride them.LOCKTON INSURANCE BROKERS DENMARK APS PRIVACY NOTICE1

Changes to this privacy notice and your dutyto inform us of changesThis notice may be updated from time to time. Weencourage you to review this notice regularly when youvisit our website to learn more about how we processyour personal data and safeguarding your privacy.Contents of this privacy noticeThis notice is provided in a layered format so you can clickthrough to the specific areas sets out below:1 – INTRODUCTION – HOW THE INSURANCE MARKETWORKSThis version is dated 22 nd October 2021 and historicversions can be obtained by contacting our DataProtection Manager.2 – THE DATA WE MAY COLLECT ABOUT YOU (YOURPERSONAL DATA)It is important that the personal data we process aboutyou is accurate and current. Please keep us informed ifyour personal data changes during your relationshipwith us.3 – WHERE WE MIGHT COLLECT YOUR PERSONAL DATAFROMThird Party LinksOur website may, from time to time, contain links to andfrom third-party websites, plug-ins and applications,including without limitation websites of our partnernetworks and affiliates. Clicking on those links may allowthird parties to collect or share data about you. Pleasenote that these third-party websites have their ownprivacy notices and we do not control those websites oraccept any responsibility or liability for these privacynotices. When you leave our website, we encourage youto read the privacy notice of every website you visit. Thisnotice is specific to our website.4 – THE PURPOSES, CATEGORIES, LEGAL GROUNDS ANDRECIPIENTS, OF OUR PROCESSING OF YOUR PERSONALDATA5 – CONSENT6 – PROFILING AND AUTOMATED DECISION MAKING7 – DATA SECURITY8 – RETENTION OF YOUR PERSONAL DATA9 – INTERNATIONAL TRANSFERS10 - YOUR RIGHTS AND CONTACT DETAILS OF THE IDPC11 – GLOSSARY OF KEY TERMSDefined TermsIn this notice: we, us or our refers to Lockton Insurance BrokersDenmark Aps, a company registered with companynumber (CVR) 41057637 and its registered office atHellerupgardvej 18, 2900 Hellerup, Copenhagen,Denmark, an independent insurance intermediaryauthorised and regulated in Denmark by the DanishFinancial Supervisory Authority (FSA) under CVR41057637. you or your, refers to the individual whose personaldata may be processed by us and other insurancemarket participants (you may be a potential oractual policyholder, insured, beneficiary under apolicy, their family member, claimant or otherperson involved in a claim or relevant to a policy).There are other terms in bold with specific meanings.Those meanings can be found in Section 12: Glossary ofKey Terms.LOCKTON INSURANCE BROKERS DENMARK APS PRIVACY NOTICE1

Section 1: Introduction – How the insurancemarket worksINSURANCE LIFECYCLE:Quotation /InceptionRenewalPolicyAdministrationClaims ProcessingFLOWS OF PERSONAL DATA THROUGH THE INSURANCE LIFECYCLE:Stage of Insurance LifecycleYouQuotation/ InceptionPolicyholder/InsuredBeneficiaryWho has access to your Personal DataPolicy aryReinsurerClaims CKTON INSURANCE BROKERS DENMARK APS PRIVACY NOTICE2

Section 2: The data we may collect about you(Your Personal Data)In order for us to obtain insurance quotes, place and administer insurance policies, and/or deal with any claims orcomplaints, we need to collect and process personal data about you.The types of personal data that are processed may include:Types of Personal DataDetailsIndividual details Name, address (including proof of address), other contact details (e.g. email andtelephone numbers), gender, marital status, date and place of birth, nationality,employer, job title and employment history, and family details, including theirrelationship to youIdentification details Identification numbers issued by government bodies or agencies, including yourCPR, passport number, and driving licence numberFinancial information Bank account or payment card details, income or other financial informationRisk details Information about you which we need to collect in order to assess the risk to beinsured and provide a quote. This may include data relating to your health orother special categories of personal data and/or information about any criminalconvictions, . For certain types of policy, this could also include telematics dataPolicy information Information about the quotes you receive and policies you take outCredit and anti-fraud data Credit history, credit score, sanctions and criminal offences, and informationreceived from various anti-fraud and sanctions databases, or regulators or lawenforcement agencies relating to youPrevious and current claims Information about previous and current claims, (including other unrelatedinsurances), which may include data relating to your health or other specialcategories of personal data and/or information about any criminal convictionsand in some cases, surveillance reportsSpecial categories ofpersonal data Certain special categories of personal data which have additional protectionunder the GDPR. The categories are health, racial or ethnic origin, politicalopinions, religious or philosophical beliefs, trade union membership, geneticdata, biometric, or data concerning sex life or sexual orientationTechnical data Criminal convictions and criminal proceedings data, including driving offencesUsage data Information about how you use our website, products and services, includinginformation from your visit from cookies, such as clickstream to, through andfrom our website (including date and time), items you viewed or searched for,page response times, download errors, length of visits to certain pages, pageinteraction information (such as clicks), and methods used to browse away fromthe pageMarketing andcommunications data Your preference in receiving marketing from us and third parties and yourcommunication preferencesLOCKTON INSURANCE BROKERS DENMARK APS PRIVACY NOTICE3

Personal data does not include data where the identity has been removed (anonymous data).We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregateddata may be derived from your personal data but is not considered personal data in law as this data does not directlyor indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so thatit can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordancewith this privacy notice.If you fail to provide personal dataWhere we need to collect personal data by law, or under the terms of a contract we have with you and you fail toprovide that data when requested, we may not be able to perform the contract we have or are trying to enter intowith you (for example, to provide you with insurance broking services). In this case, we may have to cancel a serviceyou have with us but we will notify you if this is the case at the time.LOCKTON INSURANCE BROKERS DENMARK APS PRIVACY NOTICE4

Section 3: Where we might collect your personaldata fromWe might collect your personal data from varioussources, including: you (for example by filling in forms or bycorresponding with us by post, phone, email orotherwise. This includes personal data you providewhen you:-make enquiries about or request our services;-subscribe to receive our newsletters orpublications;-request marketing to be sent to you;-give us some feedback);your family members, employer (including trade orprofessional associations of which you are a member)or representative; other insurance market participants; credit reference agencies; anti-fraud databases, sanctions lists, courtjudgements and other databases; government agencies such as the Borgerserviceand SKAT; Technical Data from analytics providers such asGoogle; forms on our website, and Technical Data and UsageData about your equipment, browsing actions andpatterns from your interaction with our website. Wecollect this personal data by using cookies and othersimilar technologies. Please see our Cookies Noticefor further details; search information providers, e.g.:-Individual Details from publicly available sourcessuch as the open electoral registeranderhvervsstyrelsen ; or-Individual Details from data brokers oraggregators; claims forms; third parties who introduce business to us;Which of the above sources apply will depend on yourparticular circumstances.For example, we might collect your personal data where: you have taken out an insurance policy through us(you are the policyholder), in which case we mightcollect your personal data from you, credit referenceagencies, anti-fraud databases, sanctions lists etc; a third party (such as a family member or youremployer) has taken out an insurance policy throughus for your benefit (you are an insured orbeneficiary), in which case we might collect yourpersonal data from your family member, employeretc; you are a claimant or other person involved in aclaim or relevant to a policy. E.g. you are making aclaim against an insurance policy you have taken outthrough us or that a third party has taken outthrough us for your benefit, or you are making aclaim against a third party’s insurance policy thatwas taken out through us, or a third party is making aclaim against an insurance policy you have taken outthrough us, in which case we might collect yourpersonal data from you, other insurance marketparticipants, witnesses, experts (including medicalexperts), loss adjustors, solicitors, and claimshandlers etc.in the event of a claim, third parties including the otherparty to the claim (claimant/defendant), witnesses,experts (including medical experts), loss adjustors,solicitors, and claims handlers.LOCKTON INSURANCE BROKERS DENMARK APS PRIVACY NOTICE5

Section 4: The purposes, categories, legalgrounds and recipients, of our processing of yourpersonal dataWe set out below the purposes for which we might use your personal data:PurposesRelationship Management - To provide you with information (for example in respect of products andservices) that you request from us, and taking steps at your request prior toentering into a contractQuotation / Inception - Setting you up as a client, including possible fraud, sanctions, credit andanti-money laundering checks- Evaluating the risks to be covered and matching to appropriateinsurer/policy/premium- Payment of premium where the insured/policyholder is an individualPolicy Administration - Client care, including communicating with you and sending you updates- Payments to and from individualsClaims Processing - Managing insurance and reinsurance claims- Defending or prosecuting legal claims- Investigation or prosecuting fraudRenewals - Contacting the insured/policyholder to renew the insurance policy- Evaluating the risks to be covered and matching to appropriatepolicy/premium- Payment of premium where the insured/policyholder is an individualOther purposes outside of theinsurance lifecycle but necessaryfor the provision of insurancethroughout the insurancelifecycle period - Complying with our legal and regulatory obligations- General risk modelling- Transferring books of business, company sales and reorganisationsConsultancy Services - Setting you up as a client, including possible fraud, sanctions, credit andanti-money laundering checks- Client care, including communicating with you and sending you updates- Payments to and from individuals- General risk modelling- Analysis as part of the specific consultancy advice- Transferring books of business, company sales and reorganisations- Complying with our legal and regulatory obligationsLOCKTON INSURANCE BROKERS DENMARK APS PRIVACY NOTICE2

PurposesWebsite Management - To administer and protect our business and this website and for internaloperations, including to keep our website safe and secure, data analysis,troubleshooting, testing, system maintenance, support, reporting andhosting of data, research, statistical and survey purposes- To use data analytics to improve our website, products/services,marketing, customer relationships and experiences, including to ensurethat content from our website is presented in the most effective mannerfor you and for your deviceMarketing - To make suggestions and recommendations to you about products orservices that may be of interest to you, to provide industry insight or toinvite you to events- To measure and understand the effectiveness of marketing we serve toyou and others and to deliver relevant marketing to youPlease note that in addition to the disclosures we have identified against each purpose, we may also disclose personaldata for those purposes to our service providers, contractors, agents and group companies that perform activities onour behalf.MARKETINGWe strive to provide you with choices regarding certainpersonal data uses, particularly around marketing andadvertising. We have established the following personaldata control mechanisms:Marketing communications from usWe may use your Individual Details and PolicyInformation to form a view on what we think you maywant or need, or what may be of interest to you. This ishow we decide which products, services, events andindustry insight may be relevant for you.You will receive marketing communications from us ifyou have requested information from us (including forexample where you have provided your explicit consentby way of opting-in to receiving our marketingcommunications in accordance with applicable law) or ifotherwise permitted under the applicable law and youhave not opted out of receiving that marketing. Suchmarketing communications may include risk or insurancerelated information or details of services, or products, orevents, which we think, may be of interest to you.Managing your Marketing Preference(including Opting out)You can manage your marketing preferences or ask us orthird parties to stop sending you marketing messages atany time by following the opt-out links on any marketingmessage sent to you or by contacting our DataProtection Manager at any time.Where you opt out of receiving these marketingmessages, this will not apply to personal data providedto us as a result of a product/service purchase,product/service experience or other transactions, andwill not affect communications relating to any suchmatters on which we are advising you.COOKIESYou can set your browser to refuse all or some browsercookies, or to alert you when websites set or accesscookies. If you disable or refuse cookies, please note thatsome parts of this website may become inaccessible ornot function properly. For more information about thecookies we use, please see our Cookies Notice.Third party marketingWe will get your express opt-in consent before we shareyour personal data with any company outside theLockton group of companies for marketing purposes.We may share your personal data with other companiesin the Lockton group of companies, if allowed andappropriate, for marketing purposes.LOCKTON INSURANCE BROKERS DENMARK APS PRIVACY NOTICE3

CHANGE OF PURPOSEWe will only use your personal data for the purposes for which we collected it, unless we reasonably consider that weneed to use it for another reason and that reason is compatible with the original purpose. If you wish to get anexplanation as to how the processing for the new purpose is compatible with the original purpose, please contact ourData Protection Manager.If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basiswhich allows us to do so.Please note that we may process your personal data without your knowledge or consent, in compliance with theabove rules, where this is required or permitted by law.LEGAL GROUNDS FOR PROCESSINGWe will only use your personal data when the law allows us to. In particular, we will rely on the following legalgrounds to use your personal data:For processing ordinary, non-sensitive personal dataLegal groundDetailsYour explicit consent (optional)You have given your explicit consent to the processing of those personaldata for one or more specified purposes, cf. Article 6(1)(a) in the GDPR.You are free to withdraw your consent, by contacting our DataProtection ManagerPerformance of our contract with youProcessing is necessary for the performance of a contract to which youare party or in order to take steps at your request prior to entering intoa contract, cf. Article 6(1)(b) in the GDPRCompliance with a legal obligationProcessing is necessary for compliance with a legal obligation to whichwe are subject, cf. Article 6(1)(c) in the GDPRFor our legitimate business interestsProcessing is necessary for the purposes of the legitimate interestspursued by us or by a third party, except where such interests areoverridden by your interests or fundamental rights and freedoms whichrequire protection of personal data, in particular where you are a child,cf. Article 6(1)(f) in the GDPR. These legitimate interests are set out nextto each purpose belowYour explicit consent (optional)You have given your explicit consent to the processing of those personaldata for one or more specified purposes, cf. Article 6(1)(a) in the GDPR.You are free to withdraw your consent, by contacting our DataProtection ManagerFor processing special categories of personal dataLegal groundDetailsYour explicit consent (optional)You have given your explicit consent to the processing of those personaldata for one or more specified purposes, cf. Article 9(2)(a) in the GDPR.You are free to withdraw your consent, by contacting our DataProtection ManagerYour explicit consent (necessary)You have given your explicit consent to the processing of those personaldata for one or more specified purposes, where we are unable toprocure, provide or administer insurance cover without this consent.You are free to withdraw your consent by contacting our DataProtection Manager. However, withdrawal of this consent will impactour ability to place or administer insurance or assist with the payment ofclaims. For more detail see Section 6: ConsentLOCKTON INSURANCE BROKERS DENMARK APS PRIVACY NOTICE2

For legal claimsProcessing is necessary for the establishment, exercise or defence oflegal claims, cf. Article 9(2)(f) in the GDPRWe may process data on criminal offences or convictions about you if you give your explicit consent hereto.Processing may also take place if it is necessary for the purpose of safeguarding a legitimate interest and this interestclearly overrides your interests, cf. Section 8(3) in the DDPA. Furthermore, such personal data may be processedabout you if the conditions for processing of special categories of personal data are met, cf. Section 8(5) in the DDPA.DISCLOSURES OF YOUR PERSONAL DATAWe may have to share your personal data with theparties set out below for the Purposes set out in thetable above. Internal third parties: other companies in the LocktonGroup (which means our subsidiaries and ultimateholding company and its subsidiaries) who provide ITand system administration services and undertakeleadership reporting External third parties:- Service providers who provide IT and systemadministration services;- Professional advisers including lawyers, bankers,auditors and insurers who provide consultancy,banking, legal, insurance and accounting services;- Credit reference agencies;- Anti-fraud and sanctions database providers;- Other insurance market participants such asintermediaries, insurers and reinsurers;- Banks;- Claims handlers;- Solicitors;- Auditors;- Loss adjustors;- Experts;- Third parties involved inclaims/investigations/prosecutions;- Private investigators;- Police;- Courts;- FSA, the Danish Data Protection Agency(Datatilsynet) and other regulators;- Third parties to whom we may choose to sell,transfer, or merge parts of our business or ourassets. Alternatively, we may seek to acquireother businesses or merge with them. If a changehappens to our business, then the new ownersmay use your personal data in the same way asset out in this privacy notice.LOCKTON INSURANCE BROKERS DENMARK APS PRIVACY NOTICETHE PURPOSES, CATEGORIES, LEGALGROUNDS AND RECIPIENTS, OF OURPROCESSING OF YOUR PERSONAL DATAWe have set out below, in a table format, a descriptionof all the ways we plan to use your personal data,including the categories of personal data and which ofthe legal bases we rely on to do so. We have alsoidentified what our legitimate interests are whereappropriate, and the third parties with whom we needto share your personal data.Note that we may process your personal data for morethan one lawful ground depending on the specificpurpose for which we are using your personal data.Please contact our Data Protection Manager if you needdetails about the specific legal ground we are relying onto process your personal data where more than oneground has been set out in the table below.3

PurposeCategories of DataLegal GroundsRELATIONSHIPMANAGEMENTTo provide you withinformation (for examplein respect of products andservices) that you requestfrom us, and taking stepsat your request prior toentering into a contractOrdinary, non-sensitivePersonal Data:- Individual details- Marketing andCommunications DataOrdinary, non-sensitivePersonal Data:- Performance of our contractwith you- Compliance with a legalobligation- For our legitimate businessinterests (to correspond withyou)QUOTATION/INCEPTIONSetting you up as a client,including fraud, credit andanti-money launderingand sanctions checksOrdinary non-sensitivePersonal Data:- Individual details- Identification details- Financial informationOrdinary non-sensitive- Credit referencePersonal Data:agencies- Performance of our contract - Anti-fraud andwith yousanctions databases- Compliance with a legalobligation- For our legitimate businessinterests (to ensure that theclient is within our acceptablerisk profile)- To assist with the preventionof crime and fraudSpecial Categories ofPersonal Data andCriminal Offence Data:- Credit and anti-frauddataSpecial Categories of PersonalData and Criminal Offence Data:- Consent- Our legitimate interests inpreventing fraud and ensuringthat the client is within ouracceptable risk profile. It is ourassessment that suchlegitimate interests clearlyoverride your interests if theprocessing relates toinformation about criminaloffences and convictionsOrdinary, non-sensitivePersonal Data:- Individual details- Identification details- Policy informationOrdinary, non-sensitivePersonal Data:- Performance of our contractwith you- For our legitimate businessinterests (to determine thelikely risk profile andappropriate insurer andinsurance product)QUOTATION/INCEPTIONEvaluating the risks to becovered and matching toappropriateinsurer/policy/premiumLOCKTON INSURANCE BROKERS DENMARK APS PRIVACY NOTICEDisclosures- Other insurancemarket participantssuch asintermediaries,insurers andreinsurers2

PurposeCategories of DataLegal GroundsSpecial Categories ofPersonal Data andCriminal Offence Data:- Risk details- Previous claims- Credit and anti-fraudchecksSpecial Categories of PersonalData and Criminal Offence Data:- Consent- Our legitimate interests inpreventing fraud and ensuringthat the client is within ouracceptable risk profile. It is ourassessment that suchlegitimate interests clearlyoverride your interests if theprocessing relates toinformation about criminaloffences and convictionsQUOTATION/INCEPTIONandPOLICY ADMINISTRATIONPayments to and fromindividuals, includingcollection or refunding ofpremiums, paying onclaims, and processingother paymentsOrdinary, non-sensitivePersonal Data:- Individual details- Financial informationOrdinary, non-sensitivePersonal Data:- Performance of our contractwith you- For our legitimate businessinterests (to recover debtsdue to us, and ensuring ourclients are able to meet theirfinancial obligations)POLICY ADMINISTRATIONGeneral client care,including communicationwith you regardingadministration andrequested changes to theinsurance policy. Sendingyou updates regardingyour insurance policy.Notifying you aboutchanges to our terms orprivacy noticeOrdinary, non-sensitivePersonal Data:- Individual details- Policy informationOrdinary, non-sensitive- Other insurancePersonal Data:market participants- Performance of our contractsuch aswith youintermediaries,- For our legitimate businessinsurers andinterests (to correspond withreinsurersclients, beneficiaries andclaimants in order to facilitatethe placing of and claimsunder insurance policies)- Compliance with a legalobligation- ConsentSpecial Categories ofPersonal Data andCriminal Offence Data:- Risk details- Previous claims- Current claimsSpecial Categories of PersonalData and Criminal Offence Data:- ConsentOrdinary, non-sensitivePersonal Data:- Individual details- Identification details- Financial information- Policy informationOrdinary, non-sensitivePersonal Data:- Performance of our contractwith you- For our legitimate businessinterests (to assist our clientsin assessing and makingclaims)CLAIMS PROCESSINGManaging insuranceclaims including fraud,credit and anti-moneylaundering and sanctionschecksLOCKTON INSURANCE BROKERS DENMARK APS PRIVACY NOTICEDisclosures- Other insurancemarket participantssuch asintermediaries,insurers andreinsurers- Banks- Other insurancemarket participantssuch asintermediaries,insurers andreinsurers- Claims handlers- Solicitors3

PurposeCLAIMS PROCESSINGDefending or prosecutinglegal claimsCategories of DataLegal GroundsSpecial Categories ofPersonal Data andCriminal Offence Data:- Credit and anti-frauddata- Risk details- Previous claims- Current claimsSpecial Categories of Personal- Loss adjustorsData and Criminal Offence Data: - Experts- Consent- Third parties- For legal claimsinvolved in the claim- Our legitimate interests in(such as health carepreventing fr

LOCKTON INSURANCE BROKERS DENMARK APS PRIVACY NOTICE 3 Section 2: The data we may collect about you (Your Personal Data) In order for us to obtain insurance quotes, place and administer insurance policies, and/or deal with any claims or complaints, we need to collect and process personal data about you. The types of personal data that are processed may include:

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