PERSONAL DATA PROCESSED
We process information you provide us when you submit an inquiry on our Website.
When you visit our Website, you can submit an inquiry through our online contact form or through our chat-bot. When you contact us, you will be asked to provide information such as your name, email address, company name and the subject of your inquiry. We refer to this entire data as “Inquiry Information”.
We collect and process the contact information of your organization’s representative when you contact us for information about our service.
When a representative of an organization contacts us in order to use our e-learning cyber insurance platform (the “Service”), we collect that representative’s contact details such as name, email, company and information relating to the engagement between us and the organization. We refer to this entire data as “Contact Information”.
You do not have a legal obligation to provide us with your Inquiry Information or Contact Information; however, if you choose to not share this information with us we may not be able to respond to your inquiry or provide you with more information about our Services.
We also collect analytics information about your use of the Website.
When you visit the Website, we record and collect certain information about your interaction with the Website, including the IP address from which you access the Website, time and date of access, type of browser used, language used, links clicked, and actions taken while using the Website (“Analytics Information“).
HOW WE PROCESS PERSONAL DATA
To respond to and handle your inquiry.
We process your Inquiry Information to contact you about your inquiry and handle your inquiry.
To send you administrative communications.
We process your Contact Information to send you communications and administrative emails, to manage the provision of the Service to you and to provide you with further information and updates about our products and technology.
We use Analytics Information to improve and enhance the Website, our services and our email communications. We also use it for business administration purposes.
We use Analytics Information to improve the Website and enrich the content on the Website, our email communications and the products services we offer to customers. We also use the Analytical Information to adapt the Website, its content, and services and our email communications, to users’ preferences. Finally, we will use the Analytics Information to understand the market in which we operate and for managerial reporting and business planning.
WHO WE SHARE YOUR DATA WITH
We will not share your information with third parties, except in the events listed below or when you provide us your explicit and informed consent.
We will process information with our service providers helping us to operate our business.
We will process personal information with the assistance of our service providers who assist us with the internal operations of the Website and our business. These companies are authorized to use your personal information in this context only as necessary to provide these services to us and not for their own promotional purposes.
We will share information with competent authorities, if you abuse your right to use the Platform, or violate any applicable law.
If you have abused your rights to use the Website, or if you violated any applicable law, we will share information with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation or breach.
We will share your information if we are legally required to do so.
We will share information if we are required to do so by a judicial, governmental or regulatory authority.
We will share your Information with third-parties in any event of change in our structure.
If the operation of our Website is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), we will share information only as required to enable the structural change in the operation of the business.
What are cookies?
Cookies are text files, comprised of small amount of data, that are saved on your computer or other device (e.g. smartphone, tablet, etc.) when you use the internet and visit various websites.
The information that the cookies maintain is read by the website you visit, during the session of your visit to the website (these are called ‘session’ cookies), and when you return to visit it again (these are called ‘persistent’ cookies).
Necessary. Cookies that are strictly necessary for the functioning of the Website. The Website cannot operate properly without these cookies. You can set your browser to block or alert you about these cookies, but some parts of the Website may not function properly.
Statistics. Analytics cookies that help us understand how you and other users interact with our Website by collecting data that does not directly identify you.
You can always delete or disable cookies.
You can always delete the cookies saved on your device through the settings of your computer browser or device. You can also disable cookies for future use through the settings of your computer browser or device.
SECURITY AND DATA RETENTION
We will retain your Information for as long as we need it for business purposes, and thereafter as needed for record-keeping matters.
We will retain your Information for the duration needed to support our ordinary business activities operating the Website. Thereafter, we will still retain it as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our agreements.
We implement measures to secure your Information.
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure personal information, it is not guaranteed, and you cannot expect that the Website will be immune from information security risks.
INTERNATIONAL DATA TRANSFERS
We will internationally transfer information in accordance with applicable data protection laws.
If we transfer your personal data for processing at locations outside your jurisdiction, we will abide by data transfer rules applicable to these situations.
If you are an EU resident and we transfer your information from the EU to other jurisdictions outside the EU, we will do so using adequate safeguards determined by the EU Commission.
ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EU
Howden is the data controller of the personal information collected via our Website.
The following is the data controller for the purposes of the personal data we collect via the Website:
Howden Insurance Company Ltd.
[add address and contact details]
Contact details of our European representative.
Our European representative, for the purposes of this Policy, is [ADD NAME OF EU REPRESENTATIVE]. If you are within the European Economic Area, you may contact our European representative the at the following address:
[ADD ADDRESS OF EU REPRESENTATIVE]
Legal basis under EU law for processing your personal data.
The legal basis under EU law for processing your Analytics Information is our legitimate interest in providing, maintaining, developing and enhancing the Website.
The legal basis for collecting and processing your Inquiry Information is our legitimate interests in responding to your inquiry.
The legal basis under EU law for processing your data for the purpose of handling instances of abusive use of the Website is our legitimate interests in defending and enforcing against violations and breaches that are harmful to our business.
The legal basis under EU law for processing your data where we are legally required to share it, is our legitimate interests in complying with mandatory legal requirements imposed on us.
The legal basis under EU law for us processing your data in the event of a change in our corporate structure is our legitimate interests in our business continuity.
You have certain rights to access, update or delete your information, obtain a copy of your information, withdraw your consent and object or restrict certain data processing activities.
If you are in the EU, you have the following rights under the GDPR:
Right to Access your personal data that we process and receive a copy of it.
Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.
Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.
Right to Object, based on your particular situation, to using your personal data on the basis of our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise of defense of legal claims.
Right to Restrict the processing your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you oppose the erasure of the personal data and request instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but you require them to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.
Right to be Forgotten. Under certain circumstances, such as when you object to us processing your data and we have no compelling legitimate grounds to override your objection, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation that we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.
If you wish to exercise any of these rights, contact us at [ENTER EMAIL].
We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.
You have a right to submit a complaint to the relevant supervisory data protection authority.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
CHANGES TO THIS PRIVACY NOTICE
Last Update: July ____, 2020.