Privacy policy - Harbour Underwriting

Harbour is committed to protecting your privacy. This Privacy Policy sets out how we collect and use your personal data, your rights and how the law protects you.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and is not intended to override them.

We may update our Privacy Policy from time to time. This version was last updated on 25 September 2020.

1. Who we are and important information

Controller and contact details

The Harbour Group is made up of different entities. This Privacy Policy is issued on behalf of the Harbour Group so when we mention ‘Harbour’, ‘we’, ‘us’ or ‘our’ in this Privacy Policy, we are referring to the relevant entity in the group responsible for processing your data. Harbour Underwriting Limited is the controller and is responsible for this website.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your data privacy rights, please contact the data privacy manager using the below details.

Full name of legal entity: Harbour Underwriting Limited

Email address: info@harbourunderwriting.com

Postal address: 4th Floor, 8 Waterloo Place, London, SW1Y 4BE, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Links to other websites

Our website may contain links to other websites of interest, 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 other websites and cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites. Such sites are not governed by this Privacy Policy. We recommend you exercise caution and read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data including name, job title, date of birth, country of birth, domicile, nationality and passport number
Contact Data including postal address (this may be your home address if you have provided this to us), email address and telephone number
Profile Data including your password for password protected platforms or services used by us, your interests, preferences and feedback
Publicly Available Data including information collected from publicly available resources, integrity data bases and credit agencies
Legal Data including information about relevant and significant litigation or other legal proceedings against you or a third party related to you and interaction with you
Technical Data including internet protocol (IP) 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 how you use our website, meetings with our employees and visits to our premises
Marketing and Communications Data including your preferences in receiving marketing from us and your communications preferences

We may also collect and use aggregated data such as statistical or demographic data for various purposes. 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 Policy.

Special categories of personal data

If you register to attend an event or seminar, we may ask for information about your health for the purpose of identifying and being considerate of any disabilities or special dietary requirements you may have. We may also collect special categories of personal data in order to provide certain services for you such as securing an insurance contract. Any use of such information is based on your consent.

If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How do I update my personal data?

It is important that the personal data we hold about you it accurate and current. If any of the personal data that you have provided to us changes, such as your email address, or if you become aware that we have any inaccurate personal data about you, please contact us at info@harbourunderwriting.com.

3. How is your personal data collected?

We may collect personal data about you in a number of circumstances, including through:

Direct interactions: You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- seek a quote for insurance cover
- take insurance cover and pay premium
- browse, make an enquiry or otherwise interact on our website
- attend a seminar
- sign up to receive information from us
- offer to provide or provide services to us
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 cookies and similar technologies. Please see our Cookie Policy for further details.
Third parties or publicly available sources: In some circumstances, we may collect personal data about you from a third-party source. For example, we may collect Identity, Contact, Publicly Available and Legal Data from your organisation, other organisations with whom you have dealings, government agencies, a credit reporting agency, an information or service provider or from publicly available records.

4. 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:

Fulfilling contracts: where we need to perform the contract we are about to or have entered into with you
Legitimate interests: where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
Legal duty: where we need to comply with a legal obligation

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below a list of all the ways we may 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 in the table below.

To assess, monitor and manage any dispute insurance coverage
To provide other services requested by you or your organisation
To identify persons authorised to instruct Harbour and sign any relevant documentation

Purpose/Activity	Lawful basis	Legitimate interests
Managing our operations
To assess, monitor and manage any dispute insurance coverageTo provide other services requested by you or your organisationTo identify persons authorised to instruct Harbour and sign any relevant documentation	Fulfilling contracts Legitimate interests Legal duty	Fulfilling our legal obligations Complying with rules and guidance from regulators
Providing you with a better service
To analyse and improve our services and communications Keeping you up to date on the latest news, announcements, events and other information which we feel would be of interest to you Customer surveys and marketing campaigns or other promotional activities or events Collecting information about your preferences to create a user profile to personalise our communication and interaction with you (for example, by way of newsletter tracking or website analytics)	Consent Fulfilling contracts Legitimate interests Legal duty	Keeping our records up to date, working out which of our products and services may interest you and telling you about them Developing and improving our products and services Developing future business initiatives Seeking consent when we need it
Business management
To manage and administer your or your organisation’s business relationship with Harbour including processing payments, accounting, auditing, billing and collection and support services	Legitimate interests Legal duty Fulfilling contracts	Complying with rules and guidance from regulators Fulfilling our legal obligations
Managing security, risk and crime prevention
To comply with screening or identity verification obligations (e.g. anti-money laundering, fraud and crime prevention purposes); these may include automated checks of personal data or other information you provide about your identity against applicable sanction lists To protect the security of and managing access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities To comply with our legal and regulatory obligations and requests, in the UK and elsewhere in the world, including reporting to and/or being audited by national and international regulatory bodies To comply with court orders and exercises and/or defend our legal rights	Fulfilling contracts Legitimate interests Legal duty	Meeting our regulatory and legal obligations such as anti-money laundering and fraud prevention Complying with rules and guidance from regulators Fulfilling our legal obligations
Processing special categories of personal data
To identify and be considerate of any disabilities or special dietary requirements you may have when attending an event or seminar To provide certain services to you such as securing an insurance contract	Consent Legal duty Fulfilling contracts Legitimate interests	Complying with rules and guidance from regulators Fulfilling our legal obligations Seeking consent when we need it

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.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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, obtained insurance from us, referred potential customers to us or otherwise provided us with your details and, in each case, you have not opted out of receiving that marketing.

Third party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at info@harbourunderwriting.com.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us for a different purpose.

Cookies

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. For more information about the cookies we use, please see our Cookie Policy.

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 incompatible 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 us at info@harbourunderwriting.com.

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.

5. Who we share your personal data with

We may share your personal data with:

other Harbour entities as joint controllers or processors who are based in the United Kingdom, British Virgin Islands, Cayman Islands, Germany and the United States of America on a confidential basis where required for the purpose of providing litigation funding, investment services, other products and services, administration, billing and other business purposes
external professional advisers acting as processors or joint controllers on a need to know basis including lawyers, consultants, bankers, insurers, auditors and other experts based in the United Kingdom, British Virgin Islands, Cayman Islands, Germany, the United States of America, Australia, Bermuda, Brazil, Canada, Hong Kong, Isle of Man, Jersey, New Zealand, St Kitts & Nevis, the Netherlands and other jurisdictions in which other Harbour entities fund cases or may consider funding cases in the future (“Countries of Operation”) who provide consultancy, banking, legal, insurance, accounting and other services
external service providers acting as joint controllers or processors based in the United Kingdom, Cayman Islands and Republic of Ireland including for services relating to fund administration, money laundering and other fraud and crime prevention purposes
courts, law enforcement authorities, regulators or attorneys or other parties acting as processors or joint controllers based in our Countries of Operation who require reporting of processing activities in certain circumstances
external service providers acting as processors based in our Countries of Operation who provide IT, system administration and marketing services and who Harbour have instructed to process personal data on our behalf and in accordance with our instructions only.

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.

If you provide personal data to us about someone else (such as one of your directors or employees, someone with whom you have business dealings or a party to legal proceedings) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Policy. In particular, you must ensure the individual concerned is aware of the various matters detailed in this Privacy Policy.

6. International transfers

We share your personal data within the Harbour Group. This will involve transferring your data outside of the European Economic Area (EEA). We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the General Data Protection Regulation (GDPR) or other relevant laws, such as ensuring service providers use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us at info@harbourunderwriting.com if you want further information on the specific mechanism used by us with transferring your personal data out of the EEA.

7. Data security

We are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, 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 and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Please contact us at info@harbourunderwriting.com for details of retention periods for different aspects of your personal data.

In some circumstances you can ask us to delete your data: see ‘Your legal rights’ below for further information.

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.

9. Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you to be corrected, although we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully objected to the processing of your data, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data if:
- you want us to establish the data’s accuracy;
- use of the data is unlawful but you do not want us to erase it;
- you need us to hold the data although we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to do any of the above please contact us at info@harbourunderwriting.com.

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 could refuse to comply with your request in these circumstances.

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 personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.