Legal notice and privacy
I AM A USER OF THIS WEBSITE (REDION.COM/EB/) AND/OR REDION EB SOCIAL CHANNELS
Introduction
Your privacy is important to us. That is why we are committed to protecting your personal information and treating it with the utmost care and attention. In this privacy notice, we will explain how we collect, use, share and protect your personal information. For these processing activities the Data Controller is:
Details of the Data Controller
Assicurazioni Generali S.p.A. – Email: privacy@eb.redion.com
Luxembourg Branch (“Redion EB”) Website: www.redion.com/eb/
Boulevard Marcel Cahen 52
L-1311 Luxembourg
Grand-Duché de Luxembourg
This privacy notice was last updated on [23/09/2026].
Definitions
For the purpose of our privacy notice, the following definition apply:
Redion Employee Benefits, “Redion EB” or “we” | Assicurazioni Generali S.p.A – Luxembourg Branch, operating under the trade name Redion Employee Benefits, A Generali Company, with registered office at Boulevard Marcel Cahen 52, L-1311 Luxembourg, Grand-Duché de Luxembourg |
GDPR | The General Data Protection Regulation meaning EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data |
Personal data | Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person |
Sensitive personal data | Sensitive personal data is any information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation |
Processing | Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction |
Controller | Controller means the natural or legal person which alone or jointly with others determines the purposes and means of the processing of personal data |
Processor | Processor is the natural or legal person, which processes data on behalf of the controller |
Data subject or “you” | Data subject means a natural person whose personal data is being processed |
How Redion EB collects and uses your personal data
Redion EB collects your personal data, either directly from you (e.g. through the “contact us” section, the “get updates” section, etc.) to provide the services you requested, or indirectly through the mere use of our website. In such case we process your personal data in order to allow you to surf on our website www.Redion EB.com, use all its features, ensure its proper functioning (including system administration activities) and improve your browsing experience.
Which personal data we collect
Our website uses cookies and similar technologies to ensure the proper functioning of the procedures performed and improve the surfing experience of users. We provide here a detailed information on the use of cookies and similar technologies, their management methods and how they are used within our Website.
Cookies are text files (letters and/or numbers) containing groups of information stored in Data Subjects’ computers or mobile devices every time they visit a website through a browser. At each subsequent visit the browser sends these cookies to the website which originated them or to another website. Cookies allow websites to store certain information in order to allow users to navigate online in a simple and fast way.
Cookies are used for different purposes and have different characteristics. They can be used either by Redion EB or by a third party.
Types of cookies
Our Website uses the following categories of cookies:
Type of cookies | Purposes |
Strictly necessary cookies | These cookies are necessary for a correct functioning of the website and for the use of the services contained therein. In their absence, the website or some of its sections may not work properly. |
Service | Description | Cookies | Links |
redion.com/eb/ | Remember the user’s privacy choice | cookie-agreed | |
fast.wistia.com | Allow users to see the videos in the correct way | _distillery |
Type of cookies | Purposes |
Analytics cookies | These cookies are used to collect information on the use of the website, such as, for instance, the pages visited more frequently. These cookies are sent from our domain or from third party’s domains |
Service | Description | Cookies | Links |
Piwik Pro | Recording information on how visitors use our website, including the IP address and the details on the visits to our website, or the origin of visitors. | _pk_id.* | https://help.piwik.pro/support/privacy/cookies-created-for-visitors-by-piwik-pro/ |
Type of cookies | Purposes |
Cookies for the integration of third parties’ functionalities. | These cookies are used in relation to the functionalities of the website (e.g. icons of social networks for sharing of contents or for the use of services provided by third party). |
Note: third party’s cookies may change name and increase or decrease at any time and without notice by the third party’s provider.
Internet user’s consent
The provision of data by users is optional; they always have the faculty to revoke their consent provided through the following procedures.
Users of our Website will provide consent for the provision of data through cookies if they fulfil one of the following actions:
- clicking on the OK button present in the banner;
Users may set their browser in order to receive a warning on the presence of cookies and decide to accept or refuse them. Moreover, they may delete such cookies through functions available in every browser for internet access.
For example, in Internet Explorer, menu Tools-> Internet Options -> Privacy, you can access a control panel where it’s possible to accept or not the different types of cookies and remove them.
Chrome: https://support.google.com/chrome/answer/95647?hl=eng
Firefox: Cookies – Information that websites store on your computer | Firefox Help
Internet Explorer: http://windows.microsoft.com/it-it/windows7/how-to-manage-cookies-in-internet-explorer-9
Opera: http://help.opera.com/Windows/10.00/it/cookies.html
Safari: Delete your Safari history, cache, and cookies on iPhone – Apple Support
Note that if you have disabled one or more cookies, we can always use information collected by these cookies before the deactivation. However, we cease to collect information via the opted-out cookie.
If you have questions or comments about this Cookie Policy, or general questions regarding the Privacy Policy, please contact us by email at privacy@eb.redion.com.
In addition, We are collecting personal data you have provided to us while using the functionalities available on our website (e.g. signing up to newsletters, filling in contact forms, etc..), such as
- Name and surname;
- Email address;
- Subscription information such as updates you are interested in;
The information you provide is necessary for us to be able to process your requests and provide you with the services you requested.
With whom we share your personal data
We may share your personal data with third parties which have been assigned with specific tasks (such as, for example, hosting services such as cloud providers, security service providers, etc). Third parties also include companies belonging to the Generali Group. Depending on the activity performed, these third parties may act as independent Data Controllers, Joint Controllers, or Data Processors. The Data Processors involved in the purposes described above are given proper instructions on how to process your personal data correctly.
Where we transfer your personal data
As a rule, we do not transfer your personal data to countries outside the European Economic Area (EEA) however, if such a transfer is required, Redion EB will ensure that appropriate safeguards are in place that provide sufficient protection for your fundamental privacy rights and freedoms. Such safeguards include, but are not limited to, Standard Contractual Clauses, as approved by the European Commission.
Which rights do you have and how can you exercise them?
You can exercise the right of access, rectification, updating, integration, cancellation, limitation to processing, portability in respect to your personal data.
In case you provided your consent to the processing of personal data, you may withdraw it at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
If your personal data are transferred outside the European Economic Area, you have the right to obtain copy of such data as well as indication of the Country/Countries where the data have been made available.
Insofar as applicable, you have the right to object to the processing of your personal data and request the stop of the processing operations when they are based on the legitimate interest.
In case you consider that the processing of your personal data infringes the applicable privacy laws, you have the right to lodge a complaint with the Luxembourg National Data Protection Commission (Commission Nationale pour la Protection des Données – CNPD) (https://cnpd.public.lu/en/commission-nationale.html) or the EU Data Protection Authority in your jurisdiction.
You can exercise you rights by sending an e-mail to privacy@eb.redion.com or by using this form.
How long will Redion EB retain your personal data?
Your personal data can be retained for the time strictly necessary to perform the above indicated activities.
Changes and updates to the Privacy Notice
This Privacy Notice may be amended or updated, in whole or in part, including to reflect changes in privacy legislation.
Any updates will be made available on www.redion.com/eb/.
I AM... A REDION EB CLIENT, NETWORK PARTNER, CONSULTANT OR BROKER, PROVIDER
Introduction
Your privacy is important to us. That is why we are committed to protecting your personal information and treating it with the utmost care and attention. In this privacy notice, we will explain how we collect, use, share and protect your personal information. For these processing activities the Data Controller is:
Details of the Data Controller
Assicurazioni Generali S.p.A. – Email: privacy@eb.redion.com
Luxembourg Branch (“Redion EB”) Website: www.redion.com/eb/
Boulevard Marcel Cahen 52
L-1311 Luxembourg
Grand-Duché de Luxembourg
Definitions
For the purpose of our privacy notice, the following definition apply:
|
Generali Employee Benefits, “Redion EB” or “we” |
Assicurazioni Generali S.p.A – Luxembourg Branch, operating under the trade name Redion Employee Benefits, A Generali Company, with registered office at Boulevard Marcel Cahen 52, L-1311 Luxembourg, Grand-Duché de Luxembourg |
|
GDPR |
The General Data Protection Regulation meaning EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data |
|
Personal data |
Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person |
|
Sensitive personal data |
Sensitive personal data is any information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation |
|
Processing |
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction |
|
Controller |
Controller means the natural or legal person which alone or jointly with others determines the purposes and means of the processing of personal data |
|
Processor |
Processor is the natural or legal person, which processes data on behalf of the controller |
|
Data subject or “you” |
Data subject means a natural person whose personal data is being processed |
How does Redion EB collect your personal data?
When we have a contractual relationship with you or with your organisation it may occur that we receive and collect personal data via the systems we use to provide our services or by reference (e.g. emails, telephone calls, business cards etc.).
When you contact us via the dedicated sections on our website (www.redion.com/eb/) or via social media such as LinkedIn, we collect your personal data. Further information on the processing activities we carry out on our website can be found in the “I am … a user of this website”-section.
Which personal data does Redion EB collect?
Depending on the services, the processing may involve, but is not limited to:
– identification data (such as name, surname, gender, date of birth);
– Professional contact details (such as email address, phone number, company name and job title);
– Login details and credentials for systems we use to provide our services
– Dietary restrictions
Additionally we may collect – also from publicly available sources – certain additional categories of information where necessary to carry out mandatory due‑diligence activities, including screening against applicable international sanctions and counter‑terrorist‑financing (CTF) lists:
- Date and place of birth;
- Nationality;
- ID Number/ passport number
- Country of residence
- Tax ID/Number
- Data relating to any criminal convictions and offences
For which purposes does Redion EB process your personal data and based on which Legal basis?
We process your personal data in the context of the pre-contractual or contractual relationship we establish with you or with your organisation, with the purpose of performing all necessary activities for the implementation of the contractual relationship that may be established, including, for example:
|
Purpose |
Legal Basis |
|
Developing Redion EB business, offering of services and performance of agreements we have entered into |
Performance of a contract – article 6 (1) (b) GDPR Legitimate Interest – article 6(1) (f) GDPR |
|
Take legal actions as well as exercise the Company’s right of defence. |
Legitimate Interest – article 6(1) (f) GDPR |
|
Organisation and management of the work activities assigned to you for the implementation of the agreement in force; |
Performance of a contract – article 6 (1) (b) GDPR |
|
Enabling the Company to carry out or take part in, manage or organise corporate transactions, including mergers, acquisitions and restructuring, |
Legitimate Interest – article 6(1) (f) GDPR |
|
Fulfilment, of regulatory and legal obligations (national and supranational, such as, international sanctions screening, financial reporting and tax obligation). |
Legal obligation – article 6(1) (c) GDPR |
How do we process your personal data?
We may process your personal data using different methods, including electronic means and both in manual and automated form, using the best solutions.
We may use statistical and artificial intelligence (AI) systems and analytical solutions.
These systems help us customize our products and services, optimise internal processes and pursue the above-mentioned purposes, ensuring a high level of quality experience and alignment with the Generali Group’s overall strategy. We process your personal data only when strictly necessary, preferring the use of anonymized or aggregated datasets, whenever possible.
In our activities, we never use fully automated processes, and human intervention is always involved.
With which parties does Redion EB share your personal data and why?
Your personal data may be shared with business partners, third‑party service providers who support us in delivering our services, such as cloud‑service providers, event organisers or similar operational partners and with other companies belonging to the Generali Group. Depending on the activity performed, these third parties may act as independent Data Controllers, Joint Controllers, or Data Processors. The Data Processors involved in the purposes described above are given proper instructions on how to process your personal data correctly.
Where we transfer your personal data
As a rule, we do not transfer your personal data to countries outside the European Economic Area (EEA) however, if such a transfer is required, Redion EB will ensure that appropriate safeguards are in place that provide sufficient protection for your fundamental privacy rights and freedoms. Such safeguards include, but are not limited to, Standard Contractual Clauses, as approved by the European Commission.
Which rights do you have and how can you exercise them?
You can exercise the right of access, rectification, updating, integration, cancellation, limitation to processing, portability in respect to your personal data.
In case you provided your consent to the processing of personal data, you may withdraw it at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
If your personal data are transferred outside the European Economic Area, you have the right to obtain copy of such data as well as indication of the Country/Countries where the data have been made available.
Insofar as applicable, you have the right to object to the processing of your personal data and request the stop of the processing operations when they are based on the legitimate interest.
In case you consider that the processing of your personal data infringes the applicable privacy laws, you have the right to lodge a complaint with the Luxembourg National Data Protection Commission (Commission Nationale pour la Protection des Données – CNPD) (https://cnpd.public.lu/en/commission-nationale.html) or the EU Data Protection Authority in your jurisdiction.
You can exercise you rights by sending an e-mail to privacy@eb.redion.com or by using this form.
How long will Redion EB retain your personal data?
Your personal data are retained for the period necessary to fulfil the purposes for which they were collected.
In relation to the conclusion, performance and management of the reinsurance and captive agreements, data is retained for a minimum of 10 years after the termination of the agreement.
With reference to legal obligations, data is retained for the period necessary to fulfil applicable obligations, without prejudice to any longer storage periods provided for by specific laws.
Changes and updates to the Privacy Notice
This Privacy Notice may be amended or updated, in whole or in part, including to reflect changes in privacy legislation.
Any updates will be made available on www.redion.com/eb/.
I AM... INSURED BY A REDION EB NETWORK PARTNER OR A BENEFICIARY UNDER AN INSURANCE POLICY
Introduction
Your privacy is important to us. That is why we are committed to protecting your personal information and treating it with the utmost care and attention. In this privacy notice, we will explain how we collect, use, share and protect your personal information. For these processing activities the Data Controller is:
Details of the Data Controller
Assicurazioni Generali S.p.A. – Email: privacy@Redion EB.com
Luxembourg Branch (“Redion EB”) Website: www.redion.com/eb/
Boulevard Marcel Cahen 52
L-1311 Luxembourg
Grand-Duché de Luxembourg
This privacy notice was last updated on [xx/xx/20xx].
Definitions
For the purpose of our privacy notice, the following definition apply:
|
Generali Employee Benefits, “Redion EB” or “we” |
Assicurazioni Generali S.p.A – Luxembourg Branch, operating under the trade name Redion Employee Benefits, A Generali Company, with registered office at Boulevard Marcel Cahen 52, L-1311 Luxembourg, Grand-Duché de Luxembourg |
|
GDPR |
The General Data Protection Regulation meaning EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data |
|
Personal data |
Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person |
|
Sensitive personal data |
Sensitive personal data is any information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation |
|
Processing |
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction |
|
Controller |
Controller means the natural or legal person which alone or jointly with others determines the purposes and means of the processing of personal data |
|
Processor |
Processor is the natural or legal person, which processes data on behalf of the controller |
|
Data subject or “you” |
Data subject means a natural person whose personal data is being processed |
How does Redion EB collect your personal data?
Redion EB does not collect your personal data directly from you. We receive it through external sources such as local insurers within our network (hereinafter “Network Partners”), brokers and consultants.
When your employer subscribes to an employee benefits insurance policy with one of our Network Partners, you may be covered under such policy as an insured person or as a beneficiary. In such case we may obtain from the Network Partner your personal data. The same goes for the situation where a claim is submitted.
Which personal data does Redion EB collect?
To provide our services to our clients and fulfil our obligations as a reinsurer, we only collect and process personal data strictly necessary to achieve the purposes below described. Only to the extent necessary for the fulfilment of the reinsurance agreement, it may occur that we collect personal data of a relative (e.g. spouse, children, etc.).
Whenever possible, we collect anonymised data or pseudonymised data (using indirect identifiers instead of your name) to fulfil our purposes. In case pseudonymised data is collected, only the Network Partner can connect such identifier to your person.
As a rule, we also further pseudonymise personal data upon collection to enhance security.
Depending on the services, the processing may involve, but is not limited to:
– identification data (such as name, surname, gender, date of birth);
– indirect identifiers (such as insured/claimant unique code);
– health data (such as diagnosis code (ICD code);
– any other personal data provided by your Insurer or third party involved (e.g. employer. broker, etc.), if any.
For which purposes does Redion EB process your personal data and based on which Legal basis?
We process your personal data for the following purposes:
|
Purpose |
Legal Basis |
|
Concluding, performing and managing the reinsurance and captive agreements, including claims handling and validation; |
Legitimate Interest – article 6(1) (f) GDPR Substantial public interest – article 9(2) (g) GDPR as provided for in Luxembourg insurance law when the processing of health data is required Legal claims – article 9(2)(f) GDPR when personal data is necessary to establish, exercise or defend legal claims |
|
Statistical reporting and data analytics |
Legitimate Interest – article 6(1) (f) GDPR Statistical purposes- article 9(2)(j) GDPR |
|
Claiming and defending the rights of the Company, its officers, representatives and shareholders in a potential dispute |
Legitimate Interest – article 6(1) (f) GDPR |
|
Managing IT and IT security activities (such as asset management, business continuity) |
Legitimate Interest – article 6(1) (f) GDPR |
|
Enabling the Company to carry out or take part in, manage or organise corporate transactions, including mergers, acquisitions and restructuring, |
Legitimate Interest – article 6(1) (f) GDPR |
|
Fulfilment, of regulatory and legal obligations (national and supranational, such as, international sanctions screening, financial reporting and tax obligation). |
Legal obligation – article 6(1) (c) GDPR |
How do we process your personal data?
We may process your personal data using different methods, including electronic means and both in manual and automated form, using the best solutions.
We may use statistical and artificial intelligence (AI) systems and analytical solutions.
These systems help us customize our products and services, optimise internal processes and pursue the above-mentioned purposes, ensuring a high level of quality experience and alignment with the Generali Group’s overall strategy. We process your personal data only when strictly necessary, preferring the use of anonymized or aggregated datasets, whenever possible.
In our activities, we never use fully automated processes, and human intervention is always involved.
With which parties does Redion EB share your personal data and why?
Your personal data may be shared with captive and third reinsurers, with third parties which have been assigned with specific tasks (such as, for example, lawyers, consultants, experts, etc), with other companies belonging to the Generali Group. Depending on the activity performed, these third parties may act as independent Data Controllers, Joint Controllers, or Data Processors. The Data Processors involved in the purposes described above are given proper instructions on how to process your personal data correctly.
Where we transfer your personal data
As a rule, we do not transfer your personal data to countries outside the European Economic Area (EEA) however, if such a transfer is required, Redion EB will ensure that appropriate safeguards are in place that provide sufficient protection for your fundamental privacy rights and freedoms. Such safeguards include, but are not limited to, Standard Contractual Clauses, as approved by the European Commission.
Which rights do you have and how can you exercise them?
You can exercise the right of access, rectification, updating, integration, cancellation, limitation to processing, portability in respect to your personal data.
In case you provided your consent to the processing of personal data, you may withdraw it at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
If your personal data are transferred outside the European Economic Area, you have the right to obtain copy of such data as well as indication of the Country/Countries where the data have been made available.
Insofar as applicable, you have the right to object to the processing of your personal data and request the stop of the processing operations when they are based on the legitimate interest.
In case you consider that the processing of your personal data infringes the applicable privacy laws, you have the right to lodge a complaint with the Luxembourg National Data Protection Commission (Commission Nationale pour la Protection des Données – CNPD) (https://cnpd.public.lu/en/commission-nationale.html) or the EU Data Protection Authority in your jurisdiction.
You can exercise you rights by sending an e-mail to privacy@eb.redion.com or by using this form.
How long will Redion EB retain your personal data?
Your personal data are retained for the period necessary to fulfil the purposes for which they were collected.
In relation to the conclusion, performance and management of the reinsurance and captive agreements, data is retained for a minimum of 10 years after the termination of the agreement.
With reference to legal obligations, data is retained for the period necessary to fulfil applicable obligations, without prejudice to any longer storage periods provided for by specific laws.
Changes and updates to the Privacy Notice
This Privacy Notice may be amended or updated, in whole or in part, including to reflect changes in privacy legislation.
Any updates will be made available on www.redion.com/eb/.
Updated on September 2026