Privacy policy

Version , 13.09.2022

1 Who is the owner of the data collection?

The owner of the data collection is Sanitas Management AG, Jägergasse 3, 8004 Zurich (hereinafter “Sanitas” or “we”).

2 Who can use the web Portal and the Portal app?

For access to the web Portal and the Portal app, Sanitas differentiates between insureds with individual contracts and insureds with family contracts. Insureds with individual contracts and the person with primary responsibility in a family contract (head of family) will be referred to as “main users” below. All other co-insureds in a family contract will be referred to as “additional users”.

There may be differences between the privacy rights of main users and those of additional users. The “Health” area in the Portal app can be used independently and individually by main and additional users.

3 What rights do users of the Portal (web and app) have with regard to their data?

The main user and all additional users are entitled at all times to assert their rights as data subjects vis-à-vis Sanitas. This means that they will receive information on their data that Sanitas has stored and processed and can rectify and add to their data and object to its processing. They may also request that their data be erased (subject to statutory retention requirements).

These rights can be asserted by the data subject by sending a signed original letter accompanied by a copy of a valid form of ID (e.g. identity card or passport) to the Sanitas Data Protection Officer:

Sanitas
Data Protection Officer
Jägergasse 3
8004 Zurich

Other data protection enquiries can also be sent to the above address or to the following email address:

datenschutz@sanitas.com

Insofar as Sanitas falls within the scope of application of the General Data Protection Regulation (GDPR), VGS Datenschutzpartner AG is its representative pursuant to Art. 27 GDPR. Contact details:

VGS Datenschutzpartner AG
Am Kaiserkai 69
20457 Hamburg
Germany

4 Access to the web Portal and the Portal app and provision of correspondence

From the moment he/she registers for the web Portal or the Portal app, the main user receives access to the data of all additional users, including sensitive personal data. The main user will also automatically be sent all documents relating to him/her and the additional users (premium invoices, policies, claims settlements, etc.) electronically via the portal. This does not apply to documents for which only postal delivery is possible for legal or technical reasons (for example, debt enforcement proceedings).

By agreeing to this data privacy policy, the main user expressly confirms that all additional users agree that the individual insurance carriers of the Sanitas Group (Sanitas Grundversicherungen AG, Sanitas Privatversicherungen AG) send him/her all correspondence together, that he/she is entitled and obliged to make all declarations for all additional users and to accept such declarations from the insurance carriers of the Sanitas Group.

By agreeing to this data privacy policy, the main user confirms that he/she has informed all additional users of legal age and has their consent to access all their data, including sensitive personal data.

Once registration is complete, the main user can activate independent access to the web Portal and the Portal app (“Insurance” and “Payments” areas) for additional users of legal age. Upon registration with their own log-in details, additional users have access to their personal interactions with Sanitas, unrestricted access to their own contract data and restricted access to the data of the other additional users. Despite the activation of further log-ins, the main user retains access to all data of the people in his/her family contract.

5 When does Sanitas process data?

Sanitas processes data when somebody uses the web Portal or the Portal app. On the one hand, Sanitas processes data made available by the user. On the other, it processes data that is generated when the web Portal and the Portal app are used, as well as data that is processed automatically or manually when the user contacts Sanitas. For example, Sanitas processes data when the user

  • registers for the web Portal and the Portal app
  • subscribes to a newsletter or other advertising via the web Portal or the Portal app
  • takes part in Sanitas market research or opinion polls
  • gives his/her explicit consent to the use of data from third-party apps, integrated services (e.g. Symptom Check) or other data. This consent is voluntary and can be granted individually in the Portal app and revoked at any time.
  • When the Active function is used: the use of Sanitas Active is optional and voluntary. To use Sanitas Active, explicit data approval must be given in the Portal app (see 6.3).

6 What data does Sanitas process?

Sanitas processes the following data in conjunction with the use of the web Portal and the Portal app:

6.1 Personal data

  • Surname and first name
  • Date of birth and age
  • Sex
  • Address
  • Nationality
  • Habits of use
  • Language preferences
  • Telephone number(s)
  • Email address(es)
  • ID numbers of the user’s technical devices
  • Customer number
  • Information on subscribed newsletters or information and advertising received
  • Consents (e.g. for advertising or notifications)
  • User account information (including date the account is opened)
  • Interests indicated by the user
  • Preferred interaction channels
  • Data entered by the user in the vaccination pass function of the Portal app, such as blood group and vaccinations
  • Location data in the Portal app on use of the search function
  • Images scanned in and sent

6.2  Data on customer activities

  • Session data with regard to visits to the web Portal and the Portal app (including duration and frequency of visits), language and country settings, information on the browser and computer operating system, internet protocol addresses, search terms and search results, evaluations submitted
  • Data on usage of the web Portal and the Portal app (including data on information viewed)
  • Communication with Sanitas by telephone, email, voice messaging, text messaging (e.g. mobile, push notifications), picture messaging (MMS), video messaging or instant messaging
  • Data on the use of other (digital) services provided by Sanitas, such as the Sanitas Coach app or the Sanitas Medgate app. This does not include usage data within the respective app or service, which can only be used with the explicit consent of the user.

6.3 Data collected and processed during the use of Sanitas Active

The use of the Sanitas Active function is optional and voluntary. To use Sanitas Active, explicit data approval must be given in the Portal app. This approval can be changed and revoked for the future in the settings at any time. Data collected and processed within Sanitas Active can be deleted at any time. The following data from the Portal app is also used within Sanitas Active:

  • Surname and first name
  • Date of birth and age
  • Sex
  • Email address(es)
  • Customer number
  • Language preferences
  • Consent to the receipt of notifications
  • ID numbers of the user’s technical devices
  • Habits of use

The use of movement tracking is voluntary and only takes place if the user explicitly agrees to the use of the following data:

  • Number of steps
  • Distance and time cycled
  • User weight
  • Calories burned
  • Calories burned during activity

To enable the aforementioned activity data to be shared with Sanitas, a fitness tracker or a health app must be connected to Sanitas Active (Fitbit, Garmin, Apple Health). This connection may also be changed and revoked for the future in the settings at any time. Sanitas cooperates with mHealth Pioneers GmbH, Körtestraße 10, 10967 Berlin for this function. Sanitas does not transmit any personal data to mHealth Pioneers GmbH. mHealth Pioneers transmits activity and lifestyle data to Sanitas. This data is used as follows:

Sanitas only processes this data for the purposes listed in section 7.

Sanitas does not process this data for other purposes, such as checking for health risks for admission to supplementary insurance (risk selection). In particular, no data will be passed on to Sanitas Grundversicherungen AG for the purpose of making specific behavioural recommendations.

For the purpose of verifying your identity (authentication), Sanitas may, if you have basic insurance with Sanitas, compare your data with the data stored about you by Sanitas Grundversicherungen AG. This comparison takes place each time you use the Active function and affects the following data:

  • Customer number
  • Date of birth

If you are insured as a family member with Sanitas Grundversicherungen AG and/or Sanitas Privatversicherungen AG, your details are verified using the customer number of the head of the family. However, the data you provide as part of the use of Sanitas Active, its evaluations and the Active services used are not disclosed to the policyholder (head of family) and are not visible to him/her.

By agreeing to this data privacy provision, you expressly give your consent to this data comparison and thus to the disclosure of the above data by Sanitas Grundversicherungen AG to Sanitas Privatversicherungen AG and Sanitas Management AG each time you use Sanitas Active. No other data is disclosed by Sanitas Grundversicherungen AG to Sanitas Privatversicherungen AG and Sanitas Management AG.

Finally, the Sports Check-in function within Sanitas Active requires users to actively allow access to location data in their device’s settings.

 

7 For what purpose does Sanitas process the data?

Sanitas processes the data listed in section 6 for various reasons. These reasons can be summarised in various groups. Specifically, we can process all or part of this data for one or more of the following purposes:

7.1 Processing purposes in conjunction with the web Portal and the Portal app

  • Provision of the web Portal and the Portal app and their functions (see terms of use for Sanitas web Portal and Sanitas Portal app).
  • Provision of personalised content and recommendations within the “Health” area
  • Data collected and processed during the use of Sanitas Active: calculation of incentivisation upon reaching the daily movement goal, redemption of vouchers

7.2  Processing purposes in conjunction with customer communication

  • Provision, administration and execution of customer communication by electronic means of communication
  • Business-related communication by telephone, email, voice messaging, text messaging (e.g. mobile, push notifications), picture messaging (MMS), video messaging or instant messaging
  • Evaluation of the usage of Sanitas offers by telephone, fax, email, voice messaging, text messaging (e.g. mobile, push notifications), picture messaging (MMS) or instant messaging, such as: type of use, frequency and duration of use, and exact location of use

7.3  Processing purposes in conjunction with analysis of user behaviour

  • Optimisation of the customer portal and Portal app by means of individualised and personal/anonymous and group-related recording and evaluation of past and current user behaviour
  • Individualised and personal/anonymous and group-related identification, classification and analysis of current and potential user requirements and user interests
  • Individualised and personal/anonymous and group-related classification and analysis of user potential and behaviour
  • Statistical evaluation of customer behaviour based on usage data
  • Linking and enriching with personal and non-personal data that is publicly accessible or acquired from third parties, for example, data from the Swiss Federal Statistical Office, calendar data, sociodemographic data, publicly accessible data from social networks, for the purpose of improving our database and analysing user behaviour

7.4  Processing purposes in conjunction with direct marketing

  • Simplification of processes and utilisation of findings from the analysis of user behaviour for the continued improvement of the web Portal and the Portal app
  • Avoidance of unnecessary advertising by using the findings from the analysis of user behaviour for customised and personalised direct marketing
  • Distribution of customised and personalised advertising by post, telephone, fax, email, voice messaging, text messaging (e.g. mobile, push notifications), picture messaging (MMS), video messaging or instant messaging
  • Customisation and personalisation of the web Portal and the Portal app and advertising through our channels on multimedia portals and social networks

For these purposes, Sanitas is authorised to merge or supplement the data listed in section 6 with additional information (e.g. number of times insured has moved house) that has already been collected by the Sanitas Group about the user in question. Data will not be passed on to third parties for use for their own purposes.

7.5 Processing purposes in conjunction with healthcare providers

Evaluation of service data (invoices from healthcare providers) and survey results in order to identify potential cost reductions.

8 Who does Sanitas pass the data on to?

Sanitas may pass on the data listed in sections 6.1 and 6.2 for the processing purposes stated in sections 7.1 to 7.4 to other companies in the Sanitas Group or to third parties who process the data for Sanitas within the framework of a contractual relationship. The other companies in the Sanitas Group can use the data listed in sections 6.1 and 6.2 in their own interests for the same purposes as Sanitas as outlined in sections  7.1 to 7.4. In particular, the companies of the Sanitas Group can process the data in their own interests for customised and personalised analysis of user behaviour (see section 7.3) and for direct marketing activities (see section 7.4). Within Sanitas or the Sanitas Group, employees can only access data to the extent required for the fulfilment of their tasks. Arrangements are in place to ensure that contracted companies do not use the data independently, outside the scope of the contract, or pass it on to third parties. Sanitas may also pass on personal details and usage data in order to comply with the applicable laws and regulations, in the event of legal proceedings, at the request of relevant courts and authorities or owing to other legal obligations.

9 What rules apply with regard to links to third-party websites?

The web Portal and the Portal app and any associated communications (e.g. emails) may contain links to third-party websites. Sanitas has no influence on the information and services on third-party websites, nor does it have any influence on how third parties handle the data collected on their websites. Sanitas is therefore not responsible for complying with data privacy and other applicable laws with regard to third-party links in the web Portal or the Portal app or any associated communications (e.g. emails). If you have any questions on this matter, please contact the third-party providers directly.

10 How does Sanitas protect data?

Sanitas has all the requisite technical and organisational precautions in place to protect your data from unauthorised access and misuse. These precautions are checked regularly and adjusted in line with advances in technology.

11 How can you contact Sanitas?

General questions on the web Portal or the Portal app can be sent to the following email address:

info@sanitas.com

12 Final provisions

Sanitas accepts no responsibility for the fact that information, software and/or documentation on the web Portal or the Portal app may be viewed or downloaded at locations outside of Switzerland. If users access the web Portal or the Portal app from outside Switzerland, they alone are responsible for compliance with all applicable local laws. Access to information, software and/or documentation on the web Portal and the Portal app from countries where such access is unlawful is prohibited. In this case and where users seek to do business with Sanitas, they should contact a Sanitas employee (info@sanitas.com; see also section 11).).

Sanitas reserves the right to make changes to or stop the web Portal and the Portal app at any time and without prior notice. We may also change these data privacy rules at any time. Changes will be indicated appropriately and the consent of users sought.

All questions and disputes in connection with the web Portal and the Portal app are subject exclusively to Swiss law with the express exclusion of any conflict-of-law provisions. Mandatory provisions concerning conflict-of-law rules remain unaffected. Sole jurisdiction is Zurich; compulsory places of jurisdiction remain reserved.

In case of doubt and/or conflict between the German, French, Italian and English versions of these terms, the German text takes precedence.

The most important changes in brief

•  Adapted to the new navigation structure of the Sanitas Portal 

•  Terms and conditions for the Active function integrated (Available from 30.09.2022)

•  Content adjusted and simplified

Purpose and basis

Data privacy and data security are a top priority for Sanitas. The company therefore places great emphasis on the protection of personal details in all its business processes.

The following data privacy rules stipulate which data Sanitas collects in conjunction with use of the Sanitas customer portal (hereinafter: customer portal) and the Sanitas Portal app (hereinafter: Portal app) and associated services, and how Sanitas processes this data.

Sanitas has drawn up this privacy policy to ensure that users are fully and transparently informed about the processing of their data in connection with the customer portal and the Portal app, so that users can decide whether they wish to consent to the processing of their data in connection with the customer portal and the Portal app.

I confirm that I have read and accept the data privacy policy.