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For example, the proposal prohibits the processing and storage of data using terminal equipment (such as those used to gather data for motor insurance telematics products) in many cases and does not contain a clear exemption allowing insurers to process data in this way in order to offer a telematics insurance policy. Without such an exemption, insurers would face legal uncertainty and may have to withdraw such products, which can enable drivers to access more tailored insurance coverage.
Insurance Europe is therefore calling for the proposal to be properly scrutinised to ensure that unintended consequences are avoided, and that the framework is robust, fit for purpose and achieves it aims, which insurers support.
Moreover, the ePrivacy proposal should be aligned with existing rules, such as the General Data Protection Regulation, and must serve a specific, legitimate purpose and bring added value to consumers.