Privacy Policy

Freedom Health GmbH Privacy Policy

At Freedom Health GmbH (‘Freedom GmbH’), we take your privacy very seriously. We promise all personal information we receive will be treated as strictly confidential, kept secure and will only be processed for lawful purposes in line with current data protection legislation and the detail provided in this privacy notice.

Occasionally we may need to amend the privacy policy, so it is valid for a period of one day from the date you viewed it. You should check the website from time to time to see our most up to date privacy policy.

This privacy notice was last updated in April 2025

1.Who are we?

Freedom Health GmbH is a Registered Intermediary, an insurance agent with authorisation according to § 34 d, sec.. 1 GewO [German Trade Regulation] with registration number: [D-HWU8-3V81O-73] at IHK Hamburg.

2. Where do we collect personal information from?

2.1 Information you give us

We collect personal information directly from you when you:

take out a Freedom GmbH policy (you may be asked to complete an application form).
make a claim.
make a complaint.
use the ‘contact us’ form or online chat facility on our website.
complete a feedback form or customer survey.
contact us by telephone, fax, email, or post to make a general enquiry or discuss your policy or claim.

If you give us personal information about another person who is to be included on your policy, you should only do so if you have their consent and you should make this privacy policy available to any person who is included on your policy who has given you consent to act for them.

2.2 Information we collect about you

We collect personal information from external sources including:

the main policyholder or member under whose policy you are covered.
social media or other insurance companies if we are investigating fraud.
other third parties such as:
- any broker appointed by the policyholder.
- a family member or other representative if you are unable to provide information relevant to your policy.
- medical professionals and hospitals.
- third parties who help us check we can make a claim payment.
- companies who provide consumer classification for marketing purposes.

2.3 Non-personal information we collect

Technical, usage and profile information which tells us how people are using our website may be automatically collected and aggregated by website analytics providers. This is done anonymously, and we cannot identify you personally. We call this ‘non-personal information’. We gather non-personal information from devices you use to connect to our website, such as computers and mobile phones, using cookies and other internet tracking software.

Non-personal information may be used to learn about online behaviour to improve our website and marketing messages and to provide a better brand experience. We may share non-personal information with third parties for research or statistical purposes but only when there is a legal data sharing agreement which clearly stipulates an agreed, limited purpose and which precludes any use for commercial gain.

3. What information do we collect?

The information we collect depends on the product or service you are interested in. For example, if you ask us for a quote, we will ask you for identity and contact information. If you take out a policy through us, we will ask for financial information so we can collect premiums.

In certain circumstances we may ask for more sensitive personal information about you such as information about your physical or mental health so we can provide a more personal quote, administer your policy, or process your claim. This is called ‘special category’ information.

We may also hold other personal information which relates to the way you use our website or engage with us even if you do not hold a policy.

Please see below for a more detailed summary of personal information we may collect.

4. How do we use personal information?

The main reason we collect personal information is so we can provide you with the health insurance cover you have purchased or has been purchased on your behalf (for example, by your employer) and to make sure we administer it correctly and efficiently. However, there are other reasons why we use personal information.

4.1 The legal basis for processing personal information

Your privacy is protected by data protection law which says we are only allowed to use personal information if we have a legal basis for doing so. We have explained below the main reasons why we process personal information and the legal basis we rely on according to current data protection law.

4.2 Legitimate interests

We process personal information for legitimate business needs, including managing all aspects of our relationship with our customers, such as administering policies and handling claims, to help us improve our services and products, and in order meet our legal and regulatory obligations.

‘Legitimate interests’ is one of the legal reasons why we may process personal information as long as we take into account our customers’ interests, rights and freedoms, and do not use personal information in a way which a customer would nor reasonably expect us to use it or is likely to cause them harm.

4.3 The legal basis for processing special category information

As well was processing personal information, we will also process special category information about your physical and mental health. We have explained below the main reasons why we process special category information and the additional legal basis we rely on according to current data protection legislation.

4.4 Typical uses of personal and special category information

Here is a list of the main ways we use personal and special category information and our legal basis for processing:

5. Who do we share information with?

We will not sell, distribute, or lease any data to third parties or any other organisations to use for their own commercial purposes unless we have your permission or are required to do so by law.

To provide our products and services, personal information may be shared with third parties who, for example, assist in our business administration or the prevention and detection of fraud. These might include:

A broker appointed by, and acting on behalf of, the policyholder.
A named alternative contact (such as a relative or advisor) who you have appointed to speak to us on your behalf and is authorised, by you, to discuss all aspects of your policy with us including claims and cancellation and can make changes on your behalf.
A relative or guardian acting on your behalf where you are incapacitated or unable to act for yourself, or other people or organisations associated with you such as your broker or lawyer.
Organisations we use to carry out customer satisfaction surveys or send out information about changes to products on our behalf.
Organisations we use to help us administer policies and claims as effectively and as cost-efficiently as possible. We use Freedom Healthnet Limited, trading as Freedom Health Insurance, as a data processor, to administer Freedom Worldwide EEA policies and claims. You can find the Freedom Health Insurance data privacy policy at www.freedomhealthinsurance.co.uk/privacy-policy.
A hospital administrator requiring a guarantee of payment or an authorisation code.
The underwriter(s) and the reinsurer(s) who provides the insurance cover.

If your policy is underwritten by Tokio Marine Europe S.A. trading as Tokio Marine HCC, you can find the Tokio Marine HCC data privacy policy at www.tmhcc.com/en/legal/privacy-policy. Residents in the EU can contact the Tokio Marine HCC Data Protection Officer at DPO-TMELux@tmhcc.com.

If your policy is underwritten by HDI Global Specialty SE, you can find the HDI Global Specialty SE privacy notice at www.hdi.global/legal/privacy/.

Suppliers and providers of goods or services we make available to you.
Regulatory bodies.
Alternative Dispute Resolution bodies.
Other insurance companies, fraud teams, the police and any law enforcement agencies and organisations which maintain anti-fraud databases where necessary for the prevention or detection of crime.
Other insurance companies to whom the policyholder has authorised the transfer of your cover from us and require personal information from us to facilitate an efficient transfer with minimal delay.

The extent of personal information we disclose will be limited to that which is necessary for the third party to carry out its purpose and we will not pass personal information, including special category information, to any third party if it is not needed.

We will not pass personal information, including special category information, to a third party who has been appointed by you if we do not believe it is in your best interests without checking with you first.

We will also disclose personal information to third parties:

if we sell or buy any business or assets, in which case we will only disclose information to the extent such disclosure is required as part of the sale or purchase.
if the assets of Freedom GmbH, either in whole or in part, are acquired by a third party, in which case information held by Freedom GmbH will be transferred, as an asset, to the third-party purchaser.
if we are under a legal duty to disclose or share information to comply with legal or regulatory obligations, to enforce any agreements governing the terms of use of our service or any other agreements with any other supplier, or to protect the rights, property or safety of Freedom GmbH, its customers, employees or others.

6. How do we process your information?

Steps are taken to ensure the data we hold is accurate, kept up to date and not kept for longer than is necessary. Measures are taken to safeguard against unauthorised or unlawful processing and accidental loss or destruction or damage to the data.

From time to time, it may be necessary to process data outside of the European Economic Area (EEA), for example if we need to place a guarantee of payment with a hospital. We will take all reasonable steps to ensure any organisation used to process data in these situations provides appropriate guarantees in respect of its technical and organisational security measures and the transfer and processing of data complies with all relevant data protection and privacy laws.

7. Cookies

Cookies are files containing small amounts of information which are downloaded to the device you use when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website which recognises the cookie. Cookies do lots of different and useful jobs, such as remembering your preferences and improving your online experience.

We never store your personal details in cookies. If you want to block cookies, you can turn them off in your browser settings, but the quality of your online experience will be reduced.

8.How long do we keep personal information for?

We only keep personal information for as long as it is necessary, but it will depend on what information we hold, why we hold it and what our wider regulatory obligations are.

We typically keep information provided in quotes (where no policy is purchased) for no more than three months after the quote expires and information provided in respect of a policy and claim for no more than two years after a policy is cancelled. Medical notes not related to an ongoing claim or policy will not be kept for longer than twelve months.

If there is a dispute or legal action, or there are extenuating circumstances, we may be required to keep personal information for longer.

9.What are your rights?

You have rights in respect of the way we process your personal information which are outlined below. If we cannot do what you ask, we will explain why – it is usually because of a legal or regulatory issue.

9.1 The right to access your personal information

You are entitled to a copy of the personal information we hold about you and certain details of how we use it. There will not usually be a charge for sending you this information which will be sent to you in writing.

9.2 The right to rectification

We take reasonable steps to make sure personal information we hold is accurate and complete. However, if you believe the information we hold about you is factually incorrect, you can ask us to amend it.

9.3 The right to erasure

In certain circumstances, you can ask us to erase your personal information – for example if it is no longer needed or if you withdraw your consent. However, this must be balanced against the consequences of erasure and there may be legal reasons why we cannot comply.

9.4 Right to restriction of processing

In certain circumstances, you can ask us to stop using your personal information – for example if you think the personal information we hold may be inaccurate or if you think we no longer need to process it.

9.5 Right to data portability

In certain circumstances, you can ask us to transfer personal information you have provided to us to another third party of your choice.

9.6 Right to object to direct marketing

You can ask us to stop sending marketing messages at any time by contacting the Data Protection Officer.

9.7 Right not to be subject to automated-decision making

Some of our decisions are made automatically by using systems which adopt automatic calculations based on personal information parameters rather than an employee making those decisions.

When we provide a quote, your premium is automatically calculated based on your age as well as the breadth of policy cover you have chosen, and this is generally fixed. When your policy renews each year, we use the same information to automatically calculate a premium but may take into consideration how long you have held a policy with us and what claims you have made. The law allows us to make automated decisions in these circumstances.

9.8 The right to withdraw consent

Where we have asked for, and you have given, your consent for us to use your personal information, you have the right to withdraw your consent. This may mean we will no longer be able to administer your insurance policy.

9.9 The right to make a complaint

You can complain to the Federal Commissioner for Data Protection and Freedom of Information (BfDI) if you object to the way we use your personal information. More information can be found on the BfDI website at https://www.bfdi.bund.de.

10.Contact

Questions, comments and requests regarding this privacy policy or Freedom GmbH’s data protection procedures should be sent to:

The Managing Director

Freedom Health GmbH

Hohe Bleichen 8

20354 Hamburg

Germany

Email: dataprotection@freedomhealthinsurance.eu