A supplier of household appliances would like to subscribe an agreement with an insurance company in order to distribute to its customers insurance coverages for the risk of breakdown, loss of, or damage to the household appliances.
The distribution of the insurance coverages would take place also through the stipulation of group policies between the insurance company and the supplier, to which customers could join.
The amount of the premium paid by the customer for the insurance does not exceed the amount of EUR 600 established by art. 1, paragraph 3, lett. b), of IDD.
Usually the supplier distributes the insurance coverage through distance selling techniques (website and call center), but it would distribute the ancillary insurance coverages to its customers (who have previously purchased household appliances) also at a later stage through third parties, such as authorized service centers (pursuing the provision of assistance, repair and maintenance of the products originally sold by the exempted ancillary intermediary) and related employees, with the prior authorization of the related insurance company.
The supplier asks to confirm whether the exemption pursuant to art. 1, paragraph 3, IDD applies also when the exempted ancillary insurance intermediary (the supplier) makes use of third parties for the distribution of insurance coverages to its customers and when the insurance is sold at a later stage after the purchase of the good sold by the supplier as principal professional activity.
In particular, the supplier asks to confirm if the exemption referred to in art. 1, paragraph 3 can be automatically extended to the above mentioned third parties.