Privacy policy

1. Controller and scope

The controller responsible for data processing is:

This policy applies to the website insercle.com including all subpages, in particular the programme, registration and claims pages.

Within our programmes, depending on the programme and contractual set-up, we act either as controller or on behalf of an insurer, warranty provider or programme partner. In the latter case, that partner's privacy policy applies in addition. You can always address requests concerning your data to us, and we will forward them where necessary.

2. Legal basis

We process personal data in accordance with the Swiss Federal Act on Data Protection (FADP). Where the EU General Data Protection Regulation (GDPR) applies, we rely on the following legal bases:

• Performance of a contract or pre-contractual measures (Art. 6(1)(b) GDPR), for example when administering a warranty contract or handling a claim
• Compliance with legal obligations (Art. 6(1)(c) GDPR), for example retention obligations
• Legitimate interests (Art. 6(1)(f) GDPR), for example the secure operation of the website, answering enquiries and assessing claims
• Consent (Art. 6(1)(a) GDPR), where we ask you for it in a specific case

3. Visiting the website

Server log files

When you access our website, your browser automatically transmits information to the server, including IP address, date and time, the page requested, referrer URL and browser and operating system details. We use this data solely to provide the website, ensure its security and resolve faults. It is not combined with other data.

Cookies and tracking

We do not use analytics, advertising or tracking cookies, nor any third-party services that analyse your browsing behaviour. Fonts and graphics are loaded from our own server. Technically necessary storage, such as your chosen language, remains on your device and is not transmitted to us.

4. Contacting us

If you contact us via the contact form, by email or by phone, we process the information you provide, such as your name, company, email address, phone number and the content of your message. We use this data to answer your enquiry and discuss any next steps.

5. Programmes: contract administration and claims handling

For our warranty, residual value and service programmes, we process personal data throughout the entire contract lifecycle:

• Registration and activation of warranties and contracts
• Contract administration, such as issuing certificates, amendments, renewals and terminations
• Claims handling, from notification and assessment to payment
• Vehicle return and remarketing, for example within residual value programmes
• Billing and reporting to insurers, warranty providers and programme partners

In doing so, we process in particular the following data:

• Contact details of customers, vehicle owners, dealers and contact persons
• Contract data such as product, term, contract or warranty number, price and proof of purchase
• Vehicle data such as vehicle identification number (VIN), registration number, first registration date, mileage and residual value
• In the event of a claim: description of the damage, photos, cost estimates, invoices, diagnostic reports and service records
• Bank details (IBAN, account holder) for payments
• Correspondence with all parties involved

We often receive this data not directly from you but from the dealer, importer, lessor or partner through whom you concluded the contract. We use the data to administer contracts, assess and settle claims, make payments, communicate with the parties involved, account for the programmes and detect fraudulent claims. Please only submit third-party data if you are authorised to do so.

6. Use of AI and automated decisions

We use artificial intelligence systems throughout our programme processes, from reviewing registrations and administering contracts to handling claims. These systems check information, photos and documents against the contract terms, validate values and costs, prepare proposed decisions, draft correspondence and monitor deadlines and replies.

In clear-cut cases, a decision may be made without prior review by a person, for example if a vehicle does not meet the requirements for a warranty, there is no coverage, or a claim is reported after the notification deadline. In such cases, you have the right to state your position and to request that the decision be reviewed by a person (Art. 21 FADP, Art. 22 GDPR). A short reply to our message or an email to info@insercle.com is sufficient.

Complex cases, in particular technical damage, are assessed by our specialists. Our AI service providers do not use your data to train general models.

7. Business partners

In the course of our cooperation with insurers, manufacturers, importers, leasing companies, dealers and other partners, we process the contact details of the relevant contact persons and information about the business relationship in order to initiate, perform and maintain contracts.

8. Service providers and recipients

We only disclose personal data to the extent necessary for the purposes described. Recipients may include:

• Insurers, warranty providers and risk carriers and their reinsurers
• Programme partners such as importers, dealers, tyre retailers and leasing companies, insofar as they take part in the respective programme
• Workshops, assessors, technical experts and logistics partners, for example to assess damage or collect a vehicle
• Banks to execute payments
• Authorities and courts, where we are legally obliged to do so

We also use carefully selected service providers who process data on our behalf and in accordance with our instructions:

• united-domains GmbH, Germany: website hosting
• Google (Google Workspace): email, document storage and storage of contract and case data
• Anthropic PBC, USA: AI-supported review and processing of programme transactions and drafting of correspondence

9. Disclosure abroad

Our service providers may process data in the EU, the EEA and the USA. Programme partners may be located in Europe or overseas. Where data is disclosed to countries without an adequate level of data protection, we ensure its protection through appropriate safeguards, in particular the European Commission's standard contractual clauses in the form recognised by the Swiss Federal Data Protection and Information Commissioner (FDPIC), or the recipient's certification under the Swiss-U.S. or EU-U.S. Data Privacy Framework. In individual cases, we rely on statutory exceptions, for example where disclosure is necessary to perform a contract with you.

10. Retention

• Server log files are stored only for a short period and then deleted.
• Contact enquiries are kept as long as necessary to handle them and for any resulting business relationship, as a rule no longer than two years after the last contact.
• Contract, programme and claims data are kept for up to ten years after the end of the contract or the closure of the case, unless a longer statutory obligation applies or the data is needed to establish or defend legal claims.

Once these periods expire, the data is deleted or anonymised.

11. Data security

We protect your data with appropriate technical and organisational measures. These include encrypted transmission (HTTPS), role-based access rights, protected access to our systems and contractual obligations of confidentiality and data protection for our service providers.

12. Your rights

Within the scope of applicable law, you have in particular the right to:

• Access the data we process about you
• Have inaccurate data corrected
• Have data deleted or its processing restricted
• Receive or transfer your data
• Object to processing based on legitimate interests
• Withdraw consent at any time with effect for the future
• Have automated decisions reviewed by a person (see section 6)

Please contact info@insercle.com. We may ask for proof of identity. Statutory retention obligations or overriding interests may prevent deletion.

You may also lodge a complaint with a supervisory authority: in Switzerland with the Federal Data Protection and Information Commissioner (FDPIC, www.edoeb.admin.ch), in the EU with the authority of your place of residence or work.

13. Information for individuals in Canada

For individuals in Canada, we process personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, the privacy laws of the Province of Quebec. Your information may be processed outside Canada, in particular in Switzerland, the EU and the USA, and may be accessible to authorities there under local law. Please send requests for access or correction to info@insercle.com. Complaints may be submitted to the Office of the Privacy Commissioner of Canada or, in Quebec, to the Commission d'accès à l'information.

14. Changes

We update this policy when our data processing or the legal requirements change. The version published on this page applies.