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Website Privacy Notice

A. BACKGROUND

This notice provides you with information on how Ironshore (including its affiliates, subsidiaries, and parent company Liberty Mutual Group, collectively referred to as “Ironshore Group”) collects and processes your personal data through use of the Ironshore website (www.ironshore.com). This website privacy notice does not apply to electronic communications (such as direct emails).

If you are an individual who has purchased an insurance product from Ironshore, or if you are a claimant under an Ironshore policy, it is important that you read this website privacy notice together with our EU Privacy Policy http://www.ironshore.com/ironshore-privacy-notice.php or the privacy notice you received with your policy so that you are fully aware of how and why we are using your data.

For the avoidance of doubt, this website privacy notice supplements our Privacy Policy and is not intended to override the Privacy Policy.

Ironshore’s website is not intended for children and we do not knowingly collect data relating to children.

B. CONTROLLER

Ironshore is made up of different legal entities, details of which can be found on this website.

This website privacy notice is issued on behalf of the Ironshore Group so when we mention “Ironshore” “we”, “us” or “our” in this notice, we are referring to the relevant company in the Ironshore Group responsible for processing your data. For the purpose of this website, Ironshore Inc. is the controller.

C. YOUR QUESTIONS OR CONCERNS ABOUT YOUR PERSONAL DATA

We have appointed a Data Protection Officer. If you have any questions about this Privacy Policy or our processing activities, please contact the Data Protection Officer at dataprotection@ironshore.com or by submitting a request through the subject access link http://www.ironshore.com/subject-rights-access-form.php. While we would appreciate the opportunity to address your concerns first, you may have the right to make a complaint to the relevant national supervisory authority for data protection issues. If you are a resident of the UK, for example, you can make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk).

D. CHANGES TO THE WEBSITE PRIVACY NOTICE

This version of the website privacy notice was last updated on 25 May 2018. Ironshore reserves the right to change this Privacy Notice from time to time, and such changes will be effective immediately upon posting to this Web site. Under certain circumstances (for example, in connection with certain material changes, including changes to our data collection use policies and practices), we may also elect to notify you of changes or updates to our Privacy Notice, or to request your consent for such changes, by additional means, such as posting a notice on the front of our Web site.

E. THE DATA WE COLLECT ABOUT YOU

There will be times, such as when you request information or a publication, when we will need to obtain personally identifiable information directly from you or about you. To respond to your enquiry effectively, we may collect, use, store and transfer certain kinds of personal data about you which we have grouped together as follows:

  • Identity data including given names, title and gender.
  • Contact data including email address, telephone number(s) and address.
  • Technical data including your internet protocol address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage data including information about how you use and navigate our website.
  • Marketing and communications data including your preferences in receiving marketing from us and your communication preferences.

If you are applying for a position at Ironshore, we also collect contact information, employment, education history and other necessary from your application. All candidates in the EU will receive a specific Candidate Privacy Notice from us.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose.Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

In relation to your use of our website, we do not collect any special categories of sensitive personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

F. HOW IS YOUR PERSONAL DATA COLLECTED ON OUR WEBSITE?

We use different methods to collect data from and about you including through the following means:

  • Direct interactions. You may give us certain data including your identity and contact data by corresponding with us through the website.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using server logs.
  • Third parties or publicly available sources. We may receive personal data about you such as your IP address from various analytics providers such as Google based outside the EU.

G. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and where fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • If you are an existing customer, where we need to perform the contract we are about to enter into or have entered into with you.

H. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

Activity: Managing our Relationship with You

To manage our relationship with you when you make an enquiry to us via the website about your policy / cover with Ironshore.

Type of Data: To manage our relationship with you, we process

  • (a) Identity data
  • (b) Contact data
  • (c) Marketing and communication data

The lawful basis for our processing includes legitimate interest and

  • (a) Performance of a contract with you
  • (b) Necessary to comply with a legal obligation
  • (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services and policies)

Activity: Administering and Protecting our business and our Website

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

To help us improve our website so that it relevant to our existing and potential customers and to improve the products or services we offer

Type of Data: To administer and protect our business and website we process

  • (a) Identity data
  • (b) Contact data
  • (c) Technical data

The lawful basis for processing includes legitimate interest and

(a)-(c) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

Activity: Delivering relevant website content and advertisements to you

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

Type of Data: To deliver relevant content to you we process

  • (a) Identity data
  • (b) Contact data
  • (c) Profile data
  • (d) Usage data
  • (e) Marketing and Communications
  • (f) Technical data

The lawful basis for processing includes legitimate interest and

(a)-(f) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Activity: Using of Data Analytics

To use data analytics to improve our website, products / services, marketing, customer relationships and experiences.

Type of Data: to do data analytics we process

  • (a) Technical data
  • (b) Usage data

The lawful basis for processing includes legitimate interest and

(a)-(b) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Activity: Making suggestions and recommendations

To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of Data: To recommend other goods and services we process

  • (a) Identity data
  • (b) Contact data
  • (c) Technical data
  • (d) Usage data
  • (e) Profile data

The lawful basis for processing includes legitimate interest and

(a)-(e) Necessary for our legitimate interests (to develop our products / services and grow our business)

I. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

J. SHARING OF YOUR PERSONAL DATA

If you have provided personal information on our website, we may need to share that information with authorised third parties, if necessary to service your request.

We may also transfer data to our affiliates within the Ironshore Group from time to time for our legitimate business purposes or to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of Ironshore's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceedings.

We may also transfer data to appropriate third parties as required by applicable laws, rules and regulations, in response to a lawful request from governmental authorities, or to comply with legal process.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

K. INTERNATIONAL TRANSFERS

We share your personal data within the Ironshore Group and our authorised external third parties. The Ironshore Group and these third parties are located across the world. Some of these countries may be subject to additional or different data protection requirements. Where this is the case, we will take appropriate measures to protect your personal information in accordance with this notice and all applicable data privacy laws.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • We may transfer data to them if they are part of the U.S. Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
  • They have EU approved binding corporate rules or other EU approved certifications.

Please contact us if you want further information on the specific mechanism we use when transferring your personal data to another country.

L. MARKETING ACTIVITIES THROUGH PERSONAL DATA OBTAINED VIA THE WEBSITE

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and in each case, from 25 May 2018 we will always ask for your consent to opt-in to marketing communications from us.

M. THIRD-PARTY LINKS

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

N. THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the Ironshore Group for marketing purposes.

O. CHOICES ABOUT THE COLLECTION AND USE OF YOUR INFORMATION

If you do not wish to have your contact information used by us to promote our own or third parties' products or services by direct mail advertisements, you can opt-out by emailing your request to info@ironshore.com.

P. COOKIES

What is a cookie? Cookies are sets of information that our web server assigns to you when you visit our web site. Cookies are used in limited areas of our site for maintaining information between pages. These cookies simply carry forward information that you submitted on one screen to the next screen, eliminating the need for redundant entry. We may use IP addresses to derive certain other information concerning businesses visiting our websites as described in this policy, but we do not analyse this information in a way which would reveal the identity of the individual browsing our websites. In particular, Ironshore only uses cookies to maintain the PHP session information for each user. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Q. DATA SECURITY

Ironshore maintains physical, electronic, and procedural safeguards that comply with applicable regulations to guard your personal data. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business-need to-know. They will only process your personal data on our instructions. We have put in place procedures to deal with any suspected unauthorized access or loss of personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

R. DATA RETENTION

By law we have to keep basic information about our customers (including Contact, Identity / Identification and Financial Data) for a required period of time even, in some circumstances, after your relationship with Ironshore has ended. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Please contact us if you require specific information about the retention period of your personal data.

S. YOUR LEGAL RIGHTS

Under certain conditions, you may have the right to require us to:

  • provide you with further details on the use we make of your personal data;
  • provide you with a copy of the personal data you have provided to us;
  • update inaccuracies in the personal data we hold;
  • delete personal data we no longer have a lawful ground to use;
  • where processing is based on consent, to withdraw your consent so that we stop that particular processing;
  • object to any processing of your personal data that we do based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
  • restrict how we use your personal data whilst a complaint is being investigated.

In certain circumstances, we may need to restrict the above rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that your personal data is not disclosed to any other person. We may also ask you for further information to clarify your request.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

If you wish to exercise any of the rights, please contact our Data Protection Officer by submitting the data subject request form found http://www.ironshore.com/subject-rights-access-form.php.

While we would appreciate the opportunity to address your concerns first, you may have the right to make a complaint to the relevant national supervisory authority for data protection issues. If you are a resident of the UK, for example, you can make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk).