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Nexiam UG (Haftungsbeschränkt)
Privacy Notice

Privacy Illustration

Introduction
You have arrived at a website that is owned and/or operated by Nexiam UG (haftungsbeschränkt), and its subsidiaries/
related companies (collectively, “Nexiam,” “we,” “our” or “us”).
If you have received a notification from Nexiam of a transfer of trades to it, Nexiam is the data controller of your personal
data. All Nexiam companies adhere to this privacy notice.
This Privacy Notice tells you who we are and outlines how we process your personal data. Nexiam respects your right to
privacy and complies with our obligations under relevant data protection legislation including the General Data Protection
Regulation (EU) 2016/679 (“GDPR”) and the Data Protection Acts 1988 - 2018.
The purpose of this Privacy Notice is to outline how we process personal data, including special categories of data and the
basis on which personal data is obtained from you or collected about you from third parties.
Nexiam is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data
and show you that we are accountable with the GDPR in relation to not only processing your data but to ensure you
understand your rights.

In this statement, we outline:

  • The types of data we collect.
  • How we use your data.
  • Your rights in relation to the data we hold about you.
  • How long we hold your data for.
  • How to contact us if you have any questions on your data or you have any complaints.

Legislation
All personal data we gather will be processed in accordance with all applicable data protection laws and principles,
including the GDPR and the Data Protection Acts 1988 – 2018 and, any other law and regulatory requirements relating to
the processing of personal data and to privacy including, Directive 2002/58/EC and the European Communities
(Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011.

Queries and Complaints
If you require further information about the way your personal data will be used, or if you are unhappy with the way we
your personal data, and wish to contact us, please submit your concerns by email to support@nexiam.net.

We can be contacted by post at:

Nexiam UG (haftungsbeschränkt)
Chamissostrasse 1
13587 Berlin

If you are unsatisfied with our use of your personal data or our response to any requests by you to exercise any of your
rights, then you have the right to complain to the Data Protection Commission. See below contact details,
Berliner Beauftragte für Datenschutz- und Informationsfreiheit

Alt Mobiat 59-61
10555 Berlin
Eingang: Alt-Moabit 60
Tel.: +49 30 13889-0
Fax: +49 30 2155050
mailbox@datenschutz-berlin.de

Information Collected
We collect information from you when you access our website, when you request a quote online or over the phone, when
you speak to members of our staff, to enter competitions or by corresponding with us by phone, email or otherwise. We
also collect information from sources other than you. We will only collect information that is adequate, relevant and limited
to what is necessary in relation to the purposes identified with this notice.
The table below outlines the categories and types of data we collect along with the source of data. The types of data
we collect may change over time; the following table is an indicative list to help you understand the types of data we collect

Data CategoryData Type
Policy DataIdentity data, employment status & occupation, previous
payment history, details of any previous services arranged by
us.
Identity and Individual DataName, date of birth, marital status, home address, contact
address, email address, phone number, dependents, health
details, employment details, payment details, financial
details, ID documents, vehicle registration details, PPS
number, driver license number, passport number, IP address and
other technical/usage data when you visit our website.
Financial DataBank details, payment card details, transaction history.
Special Category Data – Health DataInformation about your health.
Criminal Convictions DataDetails of any unspent motoring, including penalty points or
non-motoring convictions (if any).
Technical DataWe receive technical information when you visit our websites
and through email exchange. This could be the IP (Internet
Protocol) address used to connect your computer to the
internet, login information, browser type and version, time
zone setting.
Usage DataBy interacting with our websites through social media sites,
browser plugin types and versions, or other applications, we
may receive statistical data about your browsing actions and
patterns.

Purpose for Which We Hold Your Information

The main purposes for which Nexiam uses your personal information are to provide a quote, setup, administer and manage your requests and to carry out marketing and analytics. The following table provides more details on the purposes for which we process your personal data and the legal basis by which we do this.

Reason for ProcessingLegal Basis for Processing
To provide you with a quote for setting up a corporation in
the EU and process your application
Performance of a contract or in order to take steps at your
request prior to entering into a contract
To administer your incorporationPerformance of a contract
To respond to your queries and to provide you with the
information you request from us in relation to our services
and/or products
Performance of a contract
To comply with a legal obligation
Necessary for the purposes of the legitimate interests pursued
by the controller
To manage payments, fees and charges in respect of
agreements, and to collect and recover money owed to us
Performance of a contract
Necessary for the purposes of the legitimate interests pursued by the controller
To comply with a legal obligation
Recording telephone calls (for training, quality, verification,
and for the prevention of fraud purposes)
Necessary for our legitimate interests (training, quality, and
verification purposes)
Necessary to comply with a legal obligation
To manage our relationship with you, including notifying you
about changes to the services, or our Privacy Notice
Performance of a contract
To comply with a legal obligation
To provide you with marketing communicationConsent
Necessary for the purposes of the legitimate interest
pursued by the controller
To administer and protect our business, our site, and for
internal operations, including troubleshooting, data analysis,
testing, research, statistical, and survey purposes
Necessary for the purposes of the legitimate interests
pursued by the controller
To use data analytics to improve or optimize our site,
marketing, customer relationships, and experiences
Necessary for the purposes of the legitimate interests
pursued by the controller

Special Categories of Personal Data and Data Relating to Criminal Convictions and Offences

We will process data where it is necessary for the purpose of providing the requested services or to comply with a legal
obligation to which we are subject. We will also process data on criminal convictions and offences, including penalty point
data, where it is necessary and proportionate for the steps taken leading into or the performance of your insurance contract
and to comply with our legal obligations. Processing for this purpose is permitted under Section 50 of the Data Protection
Act 2018.

Sharing Information with Third Parties

There are various circumstances where we share personal data with third parties. Nexiam will make your information
available to third parties with whom we have a relationship to provide services on our behalf. We will only provide to those
third parties the information that is necessary for them to perform the services and where there is a lawful basis to do so.
We collaborate with local service providers, including tax advisors, legal consultants, insurers, immigration experts,
lawyers, accommodation and transportation providers, and other mobility-related service providers to deliver end-to-end
global movement services. Nexiam ensures all partners comply with data protection legislation and uphold similar
standards of data security and privacy.

Nexiam May Share Relevant Personal Information with the Following Categories of Third Parties in Accordance with
Applicable Laws and Privacy Regulations:

Service Providers: We may share your personal information with partners or service providers that are integral to delivering
the Nexiam products or services you have applied for or contracted. These third parties are bound by strict data protection
agreements to ensure your information is handled securely and responsibly.

Credit Reference Agencies: If required for contract fulfillment, we may share your personal information with credit
reference agencies to assess your creditworthiness. This may also include sharing information with our partners through
relevant databases for verifying the accuracy of provided details and preventing fraudulent activity.

Business Transactions: In the event of a sale, merger, or acquisition of our business, we may share your personal
information with potential buyers or sellers as part of the transaction process. Any transferred data will be subject to the
same privacy standards as before the transaction.

Business Partners, Suppliers, and Sub-contractors: We may share your personal information with business partners, suppliers, and subcontractors who act as data processors on our behalf. These third parties will only process your
information for the performance of contracts related to the services we provide to you or your company.

Regulatory Authorities and Outsourced Providers: We may disclose your personal information to outsourced service
providers, both regulated and unregulated, as required by law or for compliance purposes. This includes authorities such
as the Berliner Beauftragte für Datenschutz (Berlin Commissioner for Data Protection) or other relevant regulatory bodies.
We have a duty to disclose or share your personal information with a third party in order to comply with any legal
obligation, or in order to enforce or apply our terms of business and other agreements, or
to protect the rights, property or safety of our group of companies, related to an Nexiam product or others. This includes exchanging information with third
parties such as Government agencies for the purposes of fraud protection, anti-money laundering, credit risk reduction or
criminal activity.
We take steps to ensure that any third-party who handles your information comply with data protection legislation and
protect your information just as we do. We only disclose personal information that is necessary for them to provide the service
that they are undertaking on our behalf.

Marketing

For marketing purposes, we may contact you in relation to special offers, competitions, products, and services from Nexiam
via email, post, SMS, and phone.
We process information you provide to us and data received from other sources ,
To provide you with the information about other goods and services that we offer which are similar to those that you have already
purchased or enquired about
For occasional market research and statistical purposes. You may ‘opt out’ of participating in such market research at any
time.
To provide or permit selected third parties to provide you with information about goods and services that may interest you.
If you do not wish us to use your information in this way, or to pass your details on to third parties for marketing purposes
please tick the relevant box on the form on which we collect your information.
To send you offers, with your consent, for products which we feel relevant to your needs.
To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to
you.
Where we rely on consent for marketing purposes, consent will always be provided in the form of a clear opt-in. You have
the right to withdraw your consent at any time using the unsubscribe link on emails/ text messages, alternatively you can
contact us using the contact details listed in this Privacy Notice to opt-out of future marketing communications from Nexiam
Where we rely on Legitimate Interest (to develop and grow our business) to communicate with you for marketing purposes.
We will always provide you with an option to opt-out at the point of data collection and within each communication
thereafter. Additionally, you can use the contact details listed in this Privacy Notice to opt-out of receiving future marketing
communications.

Data Analytics:

To enhance our AI-driven workflows and improve service delivery, we use analytics tools.
This includes:
Optimizing the performance of our platform to meet your needs.
Ensuring compliance and accuracy in mobility processes.
Collaborating with search engine providers to improve accessibility and usability.
Consequences of not providing us with information
You can choose not to give us personal information, however this may have an effect on you. We may need to collect
personal information by law, or to enter into or fulfil a contract we have with you. If you choose not to give us this personal
information, it may delay or prevent us from fulfilling our contract with you or doing what we must do by law. It may also
mean that we cannot provide you with a quote or manage your cases with us which means we may need to cancel a
product or service you have with us.

Subject Rights

As a data subject you will have the following rights in relation to the processing of your personal data. You can send us a
request in relation to any of the rights outlined below, and we will do our best to adhere to your request as soon as
possible.

Right to Access

You have the right to know what personal data we hold on you, why we hold the data, and how we are using the data.
When submitting a request, please provide us with as much information as possible to help us identify the information you
wish to access (i.e. specific dates)

Right to Rectification

You have a right to request that the personal data held in relation to you is up to date and accurate.
Where information is inaccurate or incomplete, we encourage you to contact us to have this information rectified. Upon
receipt of your request, we will ensure that the personal data is rectified and as up to date as is reasonably possible.
Right to Erasure (right to be forgotten)
You have the right to seek the erasure of personal data relating to you in the following circumstances:
The personal data is no longer required for the purposes for which it was obtained.
Where the use of the data is only lawful on the basis of consent, you withdraw consent to the processing and no other
lawful basis exists.
The personal data is being used unlawfully.
You object to the use of your personal data and there are no overriding legitimate grounds for the use of the data.
Your personal data requires deletion in line with legal requirements.
However, we will be unable to fulfil an erasure request if the personal data is required for any of the below activities:
Exercising the right of freedom of expression and information.
Compliance with a legal obligation, such as the performance of a contract (i.e. your quote) or compliance with certain
legislation
For the performance of a task carried out in public interest
Archiving, research, or statistical purposes in the public interest.
The establishment, exercise or defence of legal claims.

Right to Restriction of Processing

You have the right to restrict the extent for which your personal data is being used by us in circumstances where:
You believe the personal data is not accurate (restriction period will exist until we update your information).
The processing of the personal data is unlawful, but you wish to restrict the use of the data rather than erase it.
Where the personal data is no longer required by us, but you require the retention of the data for the establishment,
exercise, or defence of a legal claim.
You have a pending objection to the future use of your personal data.
When the use of your data has been restricted, your personal data will only be further used: with your consent; for the
establishment, exercise or defence of legal claims; for the protection of the rights of other people; or for reasons important
to public interest.

Right to Data Portability

You have the right to the provision of all personal data that you have provided to Nexiam in relation to you in a structured,
commonly used machine-readable format where:
The lawfulness of the use of your personal data by us is reliant on the basis of a contract
The lawfulness of the use of your personal data by us is reliant on the provision of your consent
The data is being utilised by fully automated means.
We will refuse such a request if the data being requested may adversely affect the rights and freedoms of others.

Right to Object

You have the right to object to the further use of your personal data where:
The lawful basis for the use of your personal data by us is reliant on the basis of our legitimate interests
Where personal data is being processed for the purposes of direct marketing
or profiling related to direct marketing Right to object to automated processing, including profiling
You have the right not to be subject to a decision based solely on automated processing or profiling, where such decisions
would have a legal effect or significant impact on you.
Where we (or one of our third-party processors) use profiling, which produces legal effects for you otherwise significantly
affecting you, you will have the right to object to such processing.

Right to Withdraw Consent

Where we are processing your personal data on the legal basis of consent, you are entitled to withdraw your consent at any
time.
How to update/amend the personal information you have provided
You are entitled to know whether we hold information about you and, if we do (subject to certain limitations), to have access
to that information and have it corrected if it is inaccurate or out of date.
To exercise your rights under the GDPR please contact the Data Protection Officer at Nexaim UG (haftungsbeschränkt)
Chamissostrasse 1 13587 Berlin with proof of identity or email us at support@nexiam.net
You must contact us if any of your details change so that we can keep your information accurate and up to date.
Where do I send requests? Please send all your requests to support@nexiam.net with as much details as possible regarding your requirements to allow
us to deal with your request efficiently. To answer your request, we may ask you to provide identification for verification
purposes. All the above requests will be forwarded on should there be a third party involved as we have indicated in the
processing of your personal data.
How long will a request take to complete?
Once we receive your request, we will have 30 days to provide a response, with an extension of two further months if
required. If we need more time to deal with your request, we will contact you about the delay, within one month of the
receipt of your request. If we refuse your request, we will let you know within one month of the receipt of your request and
provide you with the reason we refused the request.
You are entitled to contact the Data Protection Commission if we refuse your request.
How much does it cost to submit a request?
We will not charge a fee for any requests, provided we do not consider them to be unjustified or excessive. If we do
consider requests to be unjustified or excessive, we may charge a reasonable fee (also for multiple copies) or refuse the
request.

Breaches

Nexiam will take care to make sure your data is protected and safeguarded. In the unlikely event of a data breach, we will
contact you in line with our legal obligations.
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which it was obtained. This means that the period
of time for which we store your personal data may depend on the type of data we hold. To determine the appropriate
retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of
harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means, and the applicable legal requirements. Nexiam will process
personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory
body (Berliner Beauftragte für Datenschutz) and our internal governance. Policy data is retained for 6 years after the last
transaction.

Retention of Legacy data from acquired companies:

Nexiam has acquired a number of companies, as a result of this we are deemed the data controller of any lapsed policy
data and legacy call recordings. We retain legacy data for a minimum of six years in line with our obligations as set out by
the Berliner Beauftragte für Datenschutz We may also be required to retain data for more than 6 years by the insurer or
underwriter of the policy in certain circumstances, for example in cases where there’s a claim in progress or reported.
Automated individual decision-making including profiling
Prior to arranging your incorporation and stay in the EU product or service we may use automated (computer based)
decision making. For example, before we can arrange an insurance product or service for you, we must obtain a quotation
from an Insurer’s Rating Engine which will carry out a real-time automated assessment to determine the insurance risks
based on the information that you have supplied. This will be used to determine if the Insurer can provide you with a policy
and to calculate the premium you will have to pay to arrange cover with them. The results of the automated decision making
may limit the products or services that Nexiam can provide to you via Nexiam UG (haftungsbeschränkt) and its subsidiaries.
If you do not agree with the result or if you have any concerns, you have the right to request to speak to a staff member to
seek clarification.

Data Security

Nexiam intent is to strictly protect the security of your personal information, to honour your choice for its intended use and
to carefully protect your data from loss, misuse, unauthorised access or disclosure, alteration or destruction. We have taken
appropriate steps to safeguard and secure information we collect online, including the use of encryption when collecting or
transferring sensitive data. However, you should always take into consideration that the internet is an open forum and that
data may flow across networks with little or no security measures, and therefore such information may be accessed by other
users other than those you intended to access it.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL
technology. All of our staff are provided with training to ensure that your information will be used only in adherence with
our privacy statement and the data protection laws applicable. Employees who misuse customer information are subject to
disciplinary action.
Data saved on our digital platform will be saved on our existing back office software systems. Where we have given you (or
where you have chosen) a password which enables you to access certain parts of our website, you are responsible for
keeping this password confidential. We ask you not to share a password with anyone.

International Transfers

It may be necessary to transfer your personal information to other group companies or service providers located in
countries outside of the European Economic Area (EEA). The types of processing may include, the fulfilment of your order,
the processing of your payment details and the provision of support services. Nexiam will take all reasonable steps
necessary to ensure that your information is treated securely and in accordance with our Privacy Notice.
If we transfer personal data to a third party or outside the EEA we, as the data controller, will ensure the recipient has the
necessary protections in place, such as Standard Contractual Clauses or an Adequacy Decision.

Business Relationships

This website may contain links to other websites. Nexiam is not responsible for the privacy practices or the content of such
websites.

Changes to Our Privacy Notice

Nexiam may modify or update this Privacy Notice from time to time without prior notice. When a change is made, we will
post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to
review this Privacy Notice periodically so that you are aware of any changes. We encourage you to check this Privacy
Notice often so that you can be aware of how we are protecting your personal information. Your continued use of our
website constitutes your consent to the contents of this privacy notice.
Effective Date
This Privacy Notice was last reviewed on 9th January 2025.

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