Privacy policy

PRIVACY: NOTICE CONCERNING PERSONAL INFORMATION

Our privacy policy is intended to establish, in an era where technology increasingly facilitates the flow and exchange of information, rules governing the collection, use and communication of personal information about policyholders (beneficiaries, claimants). These rules and procedures take into account the right of individuals to privacy with respect to their personal information and the need to collect, use or disclose this personal information for purposes that a reasonable person would consider acceptable in circumstances.

ACCOUNTABILITY

We are responsible for all personal information under our control, whether provided to us by a broker, directly by customers or by a third party or provided by us to a third party for processing. We have established policies and procedures to comply with our notice and have appointed a privacy officer responsible for ensuring that we comply with applicable privacy legislation. If you need to contact our Privacy Officer regarding specific privacy questions or concerns, please see the contact details at the end of this policy. Personal information means any information about an identified or identifiable person. Personal information that is collected for clear and lawful use and disclosure generally includes the following: • Identification and contact details (name, address including postcode, country, phone number, email address, month and date of birth, driver's license, employer, job title, work history, family details) • Policy information (policy number, amounts and policy conditions) • Application information (application number, information about a potential or existing application) • Payment information (credit card details, bank account details, credit score) • Other information relating to insurance coverage or a claim only for legitimate business purposes Personal information does not include “business contact information”, which is information that enables an individual to be contacted at a place of business. Contact information includes a person’s name, business address, business telephone number, business fax number and business email address. We will not use personal information for marketing purposes, and we will not sell personal information to other parties.

DETERMINING THE PURPOSES OF COLLECTING INFORMATION

By purchasing insurance, a client provides explicit consent to the broker for the collection, use and disclosure of personal information. Meaningful consent is subject to the customer understanding the nature, purpose and consequences of the collection, use or disclosure of their personal information.

Information is generally collected, used, disclosed and stored in order to provide the insurance products that the policyholder has requested, including to: • Identify and provide the insurance cover • Communicate with the policyholders • Calculate, collect or refund premiums • Underwrite policies and facilitate policy administration • Evaluate and process claims • Detect and prevent fraud, carry out anti-money laundering and sanctions checks • Investigate and prosecute fraud • Meet our regulatory and other legal obligations • Enforce terms or exercise rights under the insurance contract • Analyze insurance risk and business results • Improve our services and offerings • Provide general client care • Defend or prosecute legal claims • Renew your insurance policy • Transfer of books of business, company sales and reorganizations • Or as may be otherwise required or authorized by law

YOUR INFORMATION MAY BE SHARED AND DISCLOSED

In order to fulfil the purposes described in this Privacy notice, we may share your personal information with other third parties that we have engaged to provide services on our behalf, or who otherwise assist us in providing you with services, such as affiliated organizations, sub-contractors, agents/ coverholders, legal counsel, insurers, brokers, reinsurers, loss adjusters and other service providers. We will limit this disclosure to only the Personal Information that is reasonably necessary for the purpose or service for which the third party or affiliate will provide. We will use contractual and other means to provide a comparable level of protection while the information is being processed by these service providers, including limiting such providers to using your Personal Information solely to provide Lloyd’s with the specific service for which they were engaged, and for no other purpose. You can obtain more information about our policies and practices with respect to the use of Personal Information by Third Party Service Providers by contacting us as described below, under the section “How to Contact Us” at the end of this document.

We may also share or transfer your Personal Information where reasonably required in the context of a sale, merger or amalgamation of all or part of our business or the insurance or securitization of our assets. In any such case, the recipient parties will be contractually required to keep the information confidential and use it only for the purposes of the transaction, or proposed transaction, in question. In the event a business transaction is affected, assignees or successors of JUSTe’s or our business or assets, or those of our affiliated entities, may use and disclose Personal Information only for the purposes as set out in this Privacy notice, unless further consent is obtained.

We may also share your Personal Information with law enforcement, national security agencies or other governmental officials, as required or permitted by law, such as in response to a court order or a verified request relating to a criminal investigation or alleged illegal activity, where we are legally obligated to contribute information to compulsory insurance databases, or where required to detect, prevent or prosecute fraud.

CONSENT

When you share information with us for particular purposes, such as providing you with insurance, you give us explicit consent to collect, use and disclose your information for those purposes. Canadian law also authorizes us to collect, use and disclose personal information without consent in certain circumstances prescribed by law, which may include the following: • Detecting or suppressing fraud • Investigating or preventing financial abuse • For communication with the next to kin or authorized representative of an injured, ill or deceased individual • Investigating a breach of an agreement or a contravention of the laws of Canada or a foreign jurisdiction where obtaining consent would compromise the availability or accuracy of the information • Witness statement necessary to assess, process or settle insurance claims • Information that is produced in the course of an individual’s employment, business or profession

There may be situations where we need your additional consent to collect, use, and disclose information about you. In those situations, we will ask you for consent separately. You do not have to give your consent and, subject to legal and contractual restrictions, you can withdraw your consent to us collecting, using and disclosing your information at any time. However, withdrawing your consent may affect our ability to provide you with insurance cover or other services.

RETENTION AND SECURITY

We retain personal information for as long as necessary to provide you with insurance cover and meet the other purposes for collection, use and disclosure described in this Privacy notice, or as otherwise required or permitted by law. When your Personal Information is no longer required, we will make all reasonable efforts to ensure all electronic and hard copies of such information is either destroyed, made anonymous, or archived from operating systems to a secured, limited access site.

We use various physical, technical and administrative security measures, appropriate to the sensitivity of the personal information, that are designed to protect against loss, theft, unauthorized access, disclosure, copying, use or modification by. Although we will take reasonable measures to protect personal information, the transmission of information through the internet or other electronic means is not guaranteed to be secure and may create risks for the privacy and security of your information.

HOW TO ACCESS YOUR PERSONAL INFORMATION

Subject to certain exceptions provided by applicable law, you have the right to access your personal information, request corrections about your personal information if you identify any inaccuracies, and request that we delete your information. If you would like to exercise any of these rights, please contact us at info@just-unerwriting.com.

CHANGES

We may amend this Privacy notice from time to time as our business evolves, in response to legal developments, as new technologies become available, or as we introduce new features, products or services. When we make changes to wording of this Privacy notice we will revise the “last updated” date at the bottom of this Privacy notice. You should check back here periodically to find out if any changes have been made to this Privacy notice. If we make substantial changes we will, as appropriate prominently post these changes to our Site or notify registered Users directly.