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Privacy and Personal Data Protection Policy of Otherwise

Last update: July 2025

1. When does this policy apply?

When you:

• Access and use the website https://www.otherwise.fr (the "Otherwise Platform"); and

• View information about the insurance products offered, request a quote, subscribe to a product or service, or manage your contracts (the "Services"),

you entrust us with certain Personal Data, such as your name, email address, or identity document.

2. Otherwise's Commitment (Lovys)

Otherwise is a brand operated by Lovys, which is committed to protecting your Personal Data and ensuring its processing in compliance with the General Data Protection Regulation (GDPR).

This Privacy Policy (the "GDPR Policy") describes the practices for collecting, using, and protecting your data, as well as your rights.

3. Who is responsible for your data?

Lovys,

A simplified joint-stock company with a capital of €2,036.79

Registered with the Bobigny Trade and Companies Registry under number 832 028 021

‍
Registered office: 5 rue Pleyel – 93200 Saint-Denis (France)

is the data controller for the data collected via the Otherwise Platform and for the Services provided.

4. What data is collected?

Depending on your usage, Lovys may collect:

• Your identity, family, professional, and economic data;
• Your banking data;
• Information related to your contracts and their management;
• Regulatory compliance data (fraud, money laundering, etc.);
• Your preferences and browsing data (see Cookie Policy).

5. Why do we collect your data? For how long?

Purpose

Legal Basis

Retention Period

Contract management

Performance of the contract

Duration of the contract + 24 months

Responding to requests

Legitimate interest

36 months after last contact

Fighting fraud and money laundering

Legal obligation and legitimate interest

Up to 5 years after contract ends or case closure

Communication & customer loyalty

Legitimate interest or consent

36 months for prospects / contract + 24 months for clients

Recruitment

Consent, legitimate interest, or pre-contractual measures

Duration of recruitment + 24 months (with consent)

6. Are your data shared?

Access is limited to the following individuals and entities:

• Lovys internal teams;
• Insurance partners and co-distributors;
• Subcontractors (e.g., technical services, claims management).

Your data will only be shared with other third parties in the following cases:
‍
1. Necessity for the execution of the contract;
2. Legal obligation;
3. Request by a competent authority;
4. Your consent.

7. Are your data transferred outside the EU?

Yes, possibly. However, Lovys ensures that transfers are always subject to guarantees compliant with the GDPR (standard contractual clauses, adequacy decision, etc.).

8. Data Security

Lovys applies strict security measures:

• Restricted access;
• Secure password management;
• Contractual obligations of subcontractors;
• Regular controls and risk management.

Examples:
• Password with a minimum of 8 characters;
• Resetting in case of suspected unauthorized use.

9. What are your rights?

In accordance with the GDPR, you can exercise the following rights at any time:

• Access to your data;
‍• Rectification or erasure;
‍• Opposition to processing (under certain conditions);
‍• Information on their use.

10. How to exercise your rights?

Contact our Data Protection Officer (DPO):

Mail: Lovys – DPO, 5 rue Pleyel – 93200 Saint-Denis (France)
‍
‍Email : dpo@otherwise.fr

‍
Your request will be processed within 1 month (renewable once). An identity verification may be requested if necessary.

If you encounter difficulties, you can file a complaint with the CNIL:
‍www.cnil.fr or CNIL – Complaints Service, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07.

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