Navigators International

Privacy Policy

Page 1 of 5

Contents

1.The Persons to which this Privacy Policy applies

2.Privacy Policy

3.Details of each Navigators International company to which this Privacy Policy applies

4.The personal data Navigators International may collect about you, how we use your personal data and the lawful basis to do so

5.Consent

6.Profiling

7.Your Rights

8.Transmission, storage and security of your personal information

9.Retention of your personal data

10. Changes to our Privacy Policy

11. Contact details for data protection queries

12. Your right to complain to the Information Commissioners Office (“ICO”)

1.The Persons to which this Privacy Policy applies

This Privacy Policy applies to policyholders, employees, clients, suppliers, advisers, service providers, enquirers, beneficiaries or claimants and their agents and relatives (“You”).

2.Details of each company to which this Privacy Policy applies

This Privacy Policy applies to Navigators International, which is comprised of the following entities:

  • Navigators Underwriting Agency Limited;
  • UK Branch of Navigators Insurance Company;
  • Navigators International Insurance Company Ltd;
  • Navigators Management (UK) Ltd;
  • Navigators Underwriting Limited; and
  • Navigators N.V.

3.Privacy Policy

Personal data is information, or a combination of pieces of information that could reasonably allow You to be identified. Navigators International (or “we”) is committed to protecting personal data, which identifies and relates to You and is committed to complying with data protection laws.

This Privacy Policy therefore sets out how Navigators International use, share and secure personal data when we provide our services as an insurance and reinsurance business, as well as setting out the rights that You have in relation to your personal data.

4.The personal data Navigators International may collect about You, how we use your personal data and the lawful basis to do so

Navigators International conducts its business as a participant within the insurance market. In order to do so and to provide insurance quotes, insurance policies, and/or deal with any claims or complaints, Navigators International needs to collect and process personal data about You. The types of personal data that are collected and processed may include:

Individual Details / Name, address, other contact details (e.g. email and telephone numbers), gender, date and place of birth, nationality, employer, job title and employment history, and family details, including their relationship to You.
Identification Details / Identification numbers issued by government bodies or agencies, including your national insurance number, passport number, tax identification number and driving license number.
Financial Information / Bank account or payment card details, income or other financial information.
Special Category Data / Certain categories of personal data have additional protection under the General Data Protection Regulation (the “GDPR”). The categories are health, criminal convictions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric, or data concerning sex life or sexual orientation.
Risk Details / Information about You which we need to collect in order to assess the risk to be insured and provide a quote. This may include data relating to your health, criminal convictions, or other special categories of personal data.
Policy Information / Information about the quotes You receive and policies You purchase.
Credit and fraud data / Credit history, credit score, sanctions and criminal offences, and information received from various anti-fraud databases relating to You.
Claims history / Information about previous and current claims, (including other unrelated insurances), which may include data relating to your health, criminal convictions, or other special categories of personal data and in some cases, surveillance reports.

Insurance involves the use and disclosure of personal data by various insurance market participants such as

intermediaries, insurers and reinsurers. The London Insurance Market Core Uses Information Notice (which can be found here: sets out those core necessary personal data uses and disclosures. We recommend you review this notice as it details the flows of personal data through the insurance lifecycle.

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

  • Where it is necessary for our legitimate interests (or those of a third party) and where your interests and fundamental rights do not override those interests;

•Where we need to comply with a legal or regulatory obligation;

•If you have a policy with us or otherwise benefit from a policy which a third party (such as an employer or family member) has entered into with us, where we need to perform the contract we are about to enter into or have entered into with You or the relevant third party.

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 personal data.

5.Consent

In certain circumstances, we may need your consent to process certain categories of information about you (including special categories of personal data such as information about your health and any criminal convictions you may have). Where we need your consent, we will ask you for it separately. You do not have to give your consent and you may withdraw your consent at any time. However, if You do not give your consent, or You withdraw your consent, this may affect our ability to provide the insurance cover from which you benefit and may prevent us from providing cover for You or handling your claims.

6.Profiling

When calculating insurance premiums we may compare your personal data against industry averages. Your personal data may also be used to create the industry averages going forwards. This is known as profiling and is used to ensure premiums reflect risk.

7.Your Rights

Data protection laws give You rights in relation to the personal information we hold about you, which may include the right to require us to:

  • provide You with further details on the use we make of your personal data, including any special category of data;
  • provide You with a copy of the personal data that you have provided to us;
  • update any inaccuracies in the personal data we hold;
  • delete any personal data, including anyspecial category of data, that we no longer have a lawful ground to use;
  • transfer your personal data to a third party in a standardised machine readable format;
  • where processing is based on consent, to withdraw your consent so that we stop that particular processing;
  • object to any processing 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 your 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).

If You would like to discuss or exercise such rights, please contact us at the details in Section 10 of this Privacy Policy. We encourage You to contact us to update or correct your information if it changes or if the personal data we hold about You is inaccurate.

8.Transmission, storage and security of your personal information

Unfortunately, no data transmission over the internet is guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal data in accordance with applicable data protection laws, and evaluate these safeguards on a regular basis to ensure compliance with such laws.

All information within our control is stored on our secure servers (or secure hard copies) and accessed and used subject to our security policies and standards.Where Navigators International discloses your personal data to a third party, we require that third party to have appropriate technical and organisational measures in place to protect your personal data.

Your personal information may be accessed by staff or authorised third parties and, transferred to, and/or stored at, a destination outside the European Economic Area (EEA) where the data protection laws may be of a lower standard than in the EEA. Regardless of location or whether the person is an employee or contractor we will impose the same data protection safeguards that we deploy inside the EEA.

9.Retention of your personal data

We will keep your personal data 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 data due to legal or regulatory reasons.

We maintain a data retention policy which we apply to all personal data in our care. Where your personal data is no longer required we will ensure it is securely deleted.

10.Changes to our Privacy Policy

We may change the content of this Privacy Policy at any time in the future. We therefore encourage you to review it from time to time to stay informed of how we are using your personal data. This Privacy Policy was last updated in May 2018.

11. Contact details for data protection queries

We have a Head of International Compliance who supervises how we use personal data. You can contact him about any issues outlined in this Privacy Policy by:

• sending an email to ;

• writing to the Head of International Compliance, Floors 7-8, 6 Bevis Marks, London EC3A 7BA.

12.Your right to complain to the Information Commissioners Office (“ICO”)

If you are not satisfied with our use of your personal data or our response to any request by you to exercise any of your rights, or if you think that we have breached UK or EU data protection regulation, then you have the right to complain to ICO. Please see below for contact details of the ICOs in the relevant jurisdictions.

If You are unsure of the authority that supervises our processing of your personal information then please contact us for further guidance.

England
Information Commissioner'sOffice
Wycliffe House, Water Lane
Wilmslow
CheshireSK9 5AF
Tel: 0303 123 1113 (local rate) or01625 545 745 (national rate)
Email: / Scotland
Information Commissioner’s Office
45 Melville Street
EdinburghEH3 7HL
Tel: 0131 244 9001
Email: / Wales
Information Commissioner’s Office
2nd floor, Churchill House
Churchill way
CardiffCF10 2HH
Tel:029 2067 8400
Email: / Northern Ireland
Information Commissioner's
Office
3rd Floor, 14 Cromac Place
BelfastBT7 2JB
Tel: 0303 123 1114 (local rate) or028 9027 8757 (national rate)
Email

Page 1 of 5