Ascot Group Limited (‘Company’) and its subsidiaries, including Ascot Underwriting Limited writing for and on behalf of Syndicate 1414 at Lloyd’s, (together being the “Group”) gathers and uses certain information in the ordinary course of its business as an insurer and/or insurance intermediary. This information may also be used by other companies in the Group and so, in this notice, references to ‘we’ or ‘us’ mean the Company and the Group.
This Privacy Policy explains how we collect, use, disclose, transfer, and store personal information of policyholders, beneficiaries or claimants (as well as their agents or relatives) (“you”) during the course of the insurance lifecycle. You are encouraged to check periodically for any updates to these terms.
Insurance involves the use and disclosure of your personal information by various insurance market participants such as intermediaries, insurers and reinsurers. The London Insurance Market Core Uses Information Notice sets out those core necessary personal data uses and disclosures. Our core uses and disclosures are consistent with the London Market Core Uses Information Notice. We recommend you review this notice in conjunction with this Privacy Policy.
WHAT PERSONAL INFORMATION WE COLLECT
In order to deliver insurance services to you, we may collect the following information:
WHERE WE MIGHT COLLECT YOUR PERSONAL INFORMATION FROM
We might collect your personal information from various sources, depending on your circumstances, including:
HOW WE USE YOUR PERSONAL INFORMATION
In the course of providing our services, we may use your personal information for the following purposes:
CONSENT
In order to provide insurance cover and deal with insurance claims, we may need your consent in order to process certain categories of personal information, such as medical and criminal convictions records.
You may withdraw your consent to such processing at any time. However, if you do withdraw your consent this may impact our ability to provide insurance or pay claims.
SHARING YOUR PERSONAL INFORMATION WITH THIRD PARTIES
Further to the Purposes set out above, we may disclose personal information to our service providers, contractors, agents and to other companies within the Group that perform activities on our behalf. We will only disclose your personal information in connection with the insurance cover that we provide and to the extent required or permitted by law.
We may also need to transfer your data to insurance market participants or their affiliates or sub-contractors which are located outside of the European Economic Area (EEA). Those transfers would always be made in compliance with data protection legislation and we apply the same data protection safeguards that we would otherwise apply with the EEA. By providing us with your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
COOKIES
We only use cookies for session management, and we neither collect nor keep user personal data. In order to monitor the use of our website, we do use Google Analytics. Google Analytics does collect information on website trends, without identifying individual visitors. Google Analytics uses a different set of cookies for each website, and visitors are not tracked across multiple sites.
DOCUMENT RETENTION
We will keep your personal information only for so long as is necessary and for the purpose for which it was originally collected. In particular, for so long as there is any possibility that either you or we may wish to bring a legal claim under this insurance, or where we are required to keep your personal information due to legal or regulatory reasons.
YOUR RIGHTS
If you have any questions in relation to our use of your personal information, you should contact our Data Protection Officer. Under certain conditions, you may have the right to require us to:
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). Otherwise, we endeavour to deal with your request free of charge. However, where a request is manifestly unfounded or excessive, we may either charge a reasonable fee taking into account the administrative costs of providing the information or refuse to respond.
CONTACT US
If you have any questions or concerns about this Privacy Policy, or if you would like to access, correct or delete any of your personal information, or make a complaint, please contact our Data Protection Officer at:
YOUR RIGHT TO COMPLAIN
If you are not satisfied with our use of your personal information or our response to any request made by you to exercise any of your rights, or if you think that we have breached any relevant data protection laws, then you have the right to complain to the ICO. Contact details for the ICO can be found here:
Information Commissioner’s Office
CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS (EFFECTIVE 1/1/2020)
This section of our privacy policy supplements the information contained in our general privacy policy. At its current state, this applies only to those who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 and other laws that provide rights to specific California residents.
For more information, please go to: https://oag.ca.gov/privacy/ccpa
WHAT PERSONAL INFORMATION WE COLLECT In compliance with the California Consumer Privacy Act (CCPA) and other California privacy laws, we collect information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). We have collected categories of personal information from consumers within the last twelve (12) months. This does not mean that all examples of that category of personal information were in fact collected; we may collect all or just a few of these categories with regard to a particular consumer.
| Category | Examples | Collected |
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | NO |
| G. Geolocation data. | Physical location or movements. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | YES |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
USE OF PERSONAL INFORMATION
WHERE WE MIGHT COLLECT YOUR PERSONAL INFORMATION FROM
We might collect your personal information from various sources, depending on your circumstances, including:
HOW WE USE YOUR PERSONAL INFORMATION
In the course of providing our services, we may use your personal information for the following purposes:
Other purposes outside of the insurance lifecycle but necessary for the provision of insurance throughout the insurance lifecycle period:
If we are involved in any merger, acquisition, sale of company assets, transition of service to another provider, or insolvency, bankruptcy or receivership, we also reserve the right to transfer your personal information in connection with such transaction.
SHARING PERSONAL INFORMATION
Further to the purposes set out above, we may disclose personal information to our service providers, contractors, agents and to other companies within the Group that perform activities on our behalf. We will only disclose your personal information for business purposes if reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected – such as, in connection with the insurance cover that we provide and to the extent required or permitted by law. Additionally, when we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires both parties to keep that personal information confidential and not use it for any purpose except in the performance of the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
SALES OF PERSONAL INFORMATION
In the preceding twelve (12) months, we have not sold and will not sell any personal information.
YOUR RIGHTS AND CHOICES
If you have any questions in relation to our use of your personal information, you should contact our Data Protection Officer. Under certain conditions, you may have the right to request that we disclose certain information to you about our collection and use of personal information over the past 12 months. Subject to certain exceptions, California consumers may have the right to require us to:
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
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). The response we provide will also explain the reasons we cannot comply with a request, if applicable. Otherwise, we endeavor to deal with your request free of charge. However, where a request is manifestly unfounded or excessive (or repetitive), we may either refuse to respond or charge a reasonable fee, taking into account the administrative costs of providing the information. Please see the Contact Us section below for information about how to exercise these rights.
DELETION REQUEST RIGHTS
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request to delete your personal information, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers as permitted by law.
EXERCISING YOUR RIGHTS
To exercise any of the rights stated above, please submit a verifiable consumer request to us through either of the following methods:
You may make a verifiable consumer request for access or data portability twice within a 12-month period. The request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request, and cannot use for any other purposes.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
RESPONSE TIMING AND FORMAT
We endeavor to acknowledge a verifiable consumer request within 10 days and respond within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.
NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights, including by: (A) denying goods or services to the consumer; (B) charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties; (C) providing a different level or quality of goods or services to the consumer; or (D) suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.
CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this privacy notice at our discretion and at any time. Any amendments or modifications to this Privacy Policy will become effective immediately upon posting. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
CONTACT INFORMATION
If you have any questions or concerns about this Privacy Policy, or if you would like to access, correct or delete any of your personal information, or make a complaint, please contact CCPA Inquiries at:
55 West 46th Street, 26th Floor, New York, NY 10036
Email: USCompliance@ascotgroup.com
Toll Free Phone: +1(844)-589-1559
