Data Privacy Notice

We collect information: (i) you give us; (ii) information generated during the provision of our services and; (iii) information provided to us by third parties.

Types of information we may collect or hold about you include:

• Identity details: Your name, date of birth, nationality, PPS number (where applicable)
• Contact details: address, phone number, email
• Insurance information: policy numbers, insured assets, claim details
• Financial information: bank account or payment details
• Risk related information: vessel ownership history, inspection reports etc
• Special category data: in relation to claims involving injuries (only if strictly necessary)

We may collect this information directly from you via telephone, online forms/website use, emails and face to face interactions.

We may collect this information indirectly from:

• Insurance brokers/agents
• Surveyors/claims adjustors
• Regulatory authorities/port authorities
• Publicly available sources

We use, and share, your data where:

• use is necessary to provide a service or fulfil a contract that you have entered into (e.g. to provide you with insurance services) or because you have asked for something to be done so you can enter into a contract with us;
• use is necessary because we have to comply with a legal obligation (e.g. complying with our obligations to report to regulatory authorities or law enforcement, etc.);
• use is necessary to protect your “vital interests” in exceptional circumstances;
• use for our legitimate interests such as managing our business and fraud or crime prevention. This may include things like training and quality assurance, strategic planning, and statistical analysis of our service provision. You may object to your personal information being used for these purposes.

In the course of providing our services to you, complying with legal obligations or pursuing our legitimate interests, we may share your personal data with the following categories of recipients:

• third parties with whom: (i) we need to share your information to facilitate transactions/services you have requested, and (ii) you ask us to share your information;
• service providers who provide us with support services to enable delivery of our services;
• statutory and regulatory bodies and law enforcement authorities;

All third parties are required to handle your data securely and lawfully. We don't transfer personal data outside of the EEA.

How long we hold your data for is subject to a number of pieces of legislation and regulations - as a general rule, we will keep your data for 6 years after the end of our relationship with you or the last service provided. We will however endeavor not to keep any of your personal data longer than is necessary to fulfil the relevant purpose and/or comply with a specific legal retention period.

You have several rights in relation to how we use your information.

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing– where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to judicial review - in the event that we refuse your request under rights of access, we will provide you with a reason as to why.
• Right to object to automated processing, including profiling
• Right to withdraw consent - in the event that processing is based on consent you may withdraw consent at any time.
• Right to lodge a complaint with a supervisory authority.

If you wish to exercise any of your data rights, you can contact us by writing to the address above or emailing us.

If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests) we may extend this period by a further two calendar months and shall explain the reason why. If you make your request electronically, we will try to provide you with the relevant information electronically.

If you are not happy with any aspect of how your data is used, you also have the right to complain to the Data Protection Commission in Ireland. You can contact the Office of the Data Protection Commission at:

• Telephone: +353 (0)761 0100 or Lo Call Number 1800 437 737
• Online Contact Form: https://forms.dataprotection.ie/contact
• Postal Address: Data Protection Commission, 6 Pembroke Row, Dublin 2, D02 X963

If you do not provide certain information we may not be able to provide the requested services to you.

We will tell you when we ask for information which is not a contractual requirement or is not needed to comply with our legal obligations.

We may analyse your information using automated means to:

• help us understand your needs and develop our relationship with you;
• to assist in compliance with our legal obligations.