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APICIL LIFE Privacy Policy

1. General statement

The processing of data, sometimes of a sensitive nature, and respect for your private life have always been at the heart of our profession and a priority for us.

Data protection is a major commitment for us and we implement every possible measure to protect your information in line with the international norm ISO27001.

Furthermore, the APICIL group operates in strict compliance with the personal data protection laws in place, in particular the European data protection regulation (GDPR).

Respect for the use of your data is part of the APICIL Group’s DNA and as such:

  • We do not sell your data;
  • Your data is stored within the European Union;
  • We protect and ensure the confidentiality of your data;
  • We collect only the most necessary data;
  • We have appointed a DPO (Data Protection Officer);
  • We update our processing register;
  • We ensure our employees understand the GDPR;
  • We update our contracts with our clients, suppliers and subcontractors.

The aim of this Privacy policy (hereafter named “Privacy policy”) is to enable you to:

  • provide your personal data with peace of mind and in the utmost confidentiality,
  • be informed about how your data is used,
  • and, in general, to inform you about your rights in terms of personal data.

Apicil Life is a life insurance company, located at 18-20 rue Edward Steichen in Luxembourg. It is a fully-owned subsidiary of the APICIL Group, which shares this commitment to its clients’ data privacy and protection.

2. Data protection at APICIL Life

When do we collect your personal data?


The main instances in which we collect your personal data are:

  • when you create or connect to your personal account,
  • to facilitate your navigation of our website,
  • when you fill in an online form on our website, or leave a comment,
  • when you subscribe to a product or a service,
  • when you contact us via telephone, e-mail, social networks, forums or via any other means,
  • when you signal a problem or ask for assistance.

Every form indicates whether the data requested is mandatory or optional. By failing to provide all the necessary personal data, you may not be able to access all the services or products concerned.

Moreover, the fields marked ‘mandatory’ are necessary for the drafting of your contract. The mandatory or optional nature of the data is indicated alongside the eventual consequences in the absence of a response.

If you are a minor sending personal data, you must first obtain your parents’ consent. APICIL Life cannot be held liable if this consent is not first obtained. All parents and tutors are encouraged to educate minors in responsible data practices.

What kind of personal data do we collect?


In the context of its activities, APICIL Life may collect the following personal data from you (this list is non-exhaustive):

Identification data

  • Title/name/first name/
  • country/date of birth,
  • e-mail,
  • postal address,
  • telephone number
  • user name
  • gender
  • ID card / passport / proof of ID

Personal data

  • Familial status, number of children, marital status, matrimonial regime

Professional life

  • Training and professional background, level of studies, name of employer, type of job

Economic and financial information

  • revenue, financial situation
  • tax status
  • bank details

Connection data

  • IP address, search history, pages opened, operating system, information about the device from which you are connecting to the site, etc.
  • Localisation data
  • Geographical location

What is this personal data collected for?


APICIL Life has to process your personal data for several reasons.

The legal bases on which we rely to process personal data include treatments that:

  • are necessary for your contract such as:
    • Processing your subscription or membership requests,
    • Monitoring, implementing and managing your contract,
    • Providing you with information,
    • Responding to your requests or claims,
    • Creating your personal account and connecting to it.
  • are necessary for compliance with APICIL Life's legal and regulatory obligations such as the fight against money laundering, social and tax declarations, accounting obligations;
  • are necessary to serve our legitimate interests such as the development of APICIL Life's activities, the improvement of products and services, the search for new products and services, the administration, maintenance and improvement of our Websites, the fight against fraud;
  • and which are based on the consent of our customers, which can be withdrawn at any time (using the preference settings contained in the e-mails or on our websites, or on request) such as contacting you about our products and services and provide you with marketing information.

How is my data protected?


APICIL Life is committed to ensuring the security of the data you send. In order to prevent unauthorised access, use, modification, destruction, loss, damage or disclosure, appropriate technical and organisational measures have been taken to protect the data collected.

In particular, the security of your data is ensured by:

  • a username and password that protect access to your personal account;
  • limiting data access to authorized persons who are aware of the laws in force.

In the event your personal data is violated, please note that APICIL Life is obliged to notify the competent supervisory authority and to inform you, as soon as possible, of any personal data breaches that may infringe upon your rights and freedoms, and to enable you to take the necessary steps.

What are my rights?


You have the right to access your personal data, to modify or delete it, to be forgotten by APICIL Life, to limit the processing of your data, to receive the personal data provided to APICIL Life concerning you in a structured, frequently used and machine readable format, and, for a legitimate reason, to oppose the processing of personal data.

When the processing of data is based on your consent, you also have the right to withdraw it.

You may exercise these rights at any time

  • dataprotection@apicil.lu
  • Or by writing to APICIL Life at:

Data Protection Officer (DPO)
Legal and Compliance Department
18-20 RUE EDWARD STEICHEN
L2540 Luxembourg

You also have the right to lodge a complaint directly with the NCDP in Luxembourg or via a data protection authority of a European Union Member State and to define post mortem directives.

Regarding the treatments implemented in order to ensure appropriate monitoring of the risks pertaining to money laundering and the funding of terrorist organisations, your requests for access to these files should be sent to:

  • The National Commission for Data Protection, 1 Avenue du Rock'n'Roll, 4361 Esch-sur-Alzette, Luxembourg;

Modification of the Privacy policy

APICIL Life reserves the right to modify, or more generally, to update this Privacy policy at any time without notice. Any substantial changes will be reported on the website and / or, where appropriate, by email. We invite you to check this page regularly to remain informed of changes to the Privacy policy.

Contact APICIL LIFE

For any remark or question related to this document you can write to us at:

APICIL Life
Data Protection Officer (DPO)
Legal and Compliance Department
18-20 RUE EDWARD STEICHEN
L2540 Luxembourg.