Privacy Policy
About Us
This Website (iquw.com) is made available to you by IQUW Syndicate Management Limited (registered in England and Wales No. 426475), Managing Agent of IQUW Syndicate 1856 at Lloyd’s and ERS Syndicate 218 at Lloyd’s, which is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority, registered number 204851 (“IQUW”, “we”, “our” or “us”). Our registered office is at: 30 Fenchurch Street, London EC3M 3BD and we are a subsidiary of IQUW UK Limited which is the intermediate holding company for the IQUW Group’s UK companies (together the ‘IQUW UK Group’). The IQUW UK Group’s ultimate holding company is IQUW Holdings Bermuda Limited which is domiciled and incorporated in Bermuda. The main activity of the IQUW UK Group is underwriting general insurance and reinsurance business at Lloyd’s through its participation on Syndicates 218 and 1856. Syndicate 218 offers a broad range of specialist motor insurance products under the ERS brand to personal lines and commercial market segments predominantly in the United Kingdom. Syndicate 1856 underwrites a mixture of reinsurance, property, marine, energy and professional lines business, as well as a range of specialty lines including terrorism and political risks, and trades through the Lloyd’s worldwide licences. For more information, click here: https://group.iquw.com/about-u…
We are the controller of personal data obtained via our Website.
When you browse the web, you leave a digital footprint. It is information about your device and the way you use it online. We just want to let you know that we will collect this information about you. Most websites do this. Given the nature of our Website, we do not expect to collect personal data relating to children.
This privacy policy describes the way in which we use your personal information in connection with your use of our Website and provides details of your rights. It contains important information so please make sure you read it carefully. We may update this notice from time to time.
Who does this Privacy Policy apply to?
This privacy policy describes how we handle personal information about the following people:
- Users of our Website, including people who participate in our marketing promotions
We process personal information in line with the UK’s Data Protection laws and other relevant laws that apply.
The personal information we may collect about you and where we collect it
We collect information when you use our Website. When you view our Website we can see:
- What you click
- What you view
- How long you spend on pages
- Your device and internet connection details such as: type of device you’re using, IP address and details about your internet connection, technical details such as your screen size and the software you are using, such as your web browser
- Your country or region (not exactly where you are unless we ask permission)
- Your unique advertising or other identification numbers allocated to your browser or device.
If you follow a link to this Website, we know the last site you visited. You may have reached this Website by following a link from an email. When you open an email from us, we may be able to tell:
- That you have opened it
- What links in the email you click on.
When you fill in a form on our Website, we can see what you type (for example, your name, company details, email address, ‘phone number, other contact details and marketing preferences). If you send us a message or respond to surveys, competitions and promotions, we may collect information you tell us. Some of this data is collected by:
- Our partners: These may be website hosts
- Cookies and similar technology: These are set on your device by us and our trusted partners. For further information please refer to our Cookie Policy.
We do not often know exactly who you are from this data. But sometimes we may connect this data with other information we hold about you.
How and why we use and disclose your personal information
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
If we need your consent to use any specific information, we will make that clear at the time we collect the information from you. You are free to withhold your consent or withdraw it at any time, but if you do so it may impact upon the functionality of the Website and/or our ability to provide a service to you.
Below is a summary of how and why we use and disclose your personal information.
What we use your personal data for
To administer this Website and our business (including troubleshooting, data analysis, testing, audits, quality checks, system maintenance, support, reporting and hosting of data).
Lawful basis for processing
Necessary for our legitimate interests (for running our business, provision of administration and IT services)
Using data analytics to improve our Website, products/services, marketing, customer relationships and experiences
Depending on the circumstances:
—your consent as gathered by the Cookie notice on our homepage (for further details please see our Cookie Policy)
—where we are not required to obtain your consent and do not do so, for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Retaining and evaluating information on your recent visits to our Website and how you move around different sections of our Website for analytics purposes. This helps us to understand how people use our Website so that we can make it more intuitive or to check our Website is working as intended
Depending on the circumstances:
—your consent as gathered by the Cookie notice on our homepage (for further details please see our Cookie Policy)
—where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you
To customise our Website and its content to your particular preferences based on a record of your selected preferences or on your use of our Website
Depending on the circumstances:
—your consent as gathered by the Cookie notice on our homepage (for further details please see our Cookie Policy)
—where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you
To enforce legal rights or defend or undertake legal proceedings
Depending on the circumstances:
—to comply with our legal and regulatory obligations
—in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
Protecting the security of systems and data
To comply with our legal and regulatory obligations
We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant.
To comply with our legal and regulatory obligations
Marketing our services to existing and former customers.
—For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers. This includes administering promotions and delivering prizes.
—your consent – see ‘Marketing’ below for further information
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency
In such cases information will be anonymised where possible and only shared where necessary
Depending on the circumstances:
—to comply with our legal and regulatory obligations
—in other cases, for our legitimate interests or those of a third party, i.e. to protect, realise or grow the value in our business and assets
Our Group Companies and Suppliers
Like most organisations, we uses a variety of companies, including members of our group, to provide services on our behalf. We enter into contracts with those service providers to make sure they protect your personal information using appropriate security measures and we prohibit them from using your personal data other than as instructed by us.
Below is a list of service providers that have access to personal information to help operate this Website or assist with activities relating to this Website:
Third Parties
Administrative Support
Reason
We employ third party suppliers to manage inbound and outbound correspondence (i.e. scanning, referencing post, cheque processing, printing and postal services) and other administrative tasks. Members of our group assist with the administration of the Website and with communications with users of the Website. We also use third parties such as website analytics providers to help us gather information about how people use the Website.
Marketing
Members of our group assist with our marketing promotions.
Document Management
Document storage, tape storage, document destruction.
Professional Advisers
Legal advisers, accountants, auditors, project managers and other professional advisers.
IT and Related Providers
Software licenses/subscriptions, outsourced infrastructure support, IQUW insurance systems, payment platform providers, telephony infrastructure and recordings. Data maybe shared with third party suppliers on payment platforms in order to enhance the servicing proposition for customers.
Facilities
Cleaning and security services.
Law enforcement agencies, courts, tribunals and regulatory bodies
To comply with our legal and regulatory obligations.
International Transfers
Some of the partner organisations and service providers we work with may be located in other countries. ERS uses service providers located in the USA and Republic of Ireland. As a result, your information may be processed outside the UK and European Economic Area. In all cases we will make sure that your information is adequately protected.
Under data protection laws, we can only transfer your personal data to a country outside the UK where:
- the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR;
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
- a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where such is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law.
For further information about such transfers and the safeguards we employ, including to obtain a copy of the standard data protection clauses, please contact our Data Protection Officer.
Marketing
We will ask your permission before carrying out any marketing. You have the right to opt out of receiving marketing at any time. You can use the unsubscribe option that is included in all our marketing emails or contact us using the details given below.
In very limited circumstances and only where you have given us your express consent, we may pass your data to a third party so that they can contact you for marketing purposes. In such circumstances we may act as data processor in collecting your consent and sending it to the third party, and the third party will be a data controller in respect of the relevant data. You should refer to the relevant third party’s privacy policy for further information on how they use your data. We may also use your personal information if you take part in our marketing promotions, to administer the promotion and to deliver any prizes.
Security
We will use a range of measures to keep your information safe and secure, such as encryption.
Retention
We will keep your personal data only for as long as is necessary for the purpose for which it was collected. In particular, we will retain your information where we are required to keep your information for legal or regulatory purposes. We have various different retention periods for different types of claims and other records. If you would like more information about this, please contact us at the address shown below.
We may keep anonymised data for longer periods for analysis and modelling purposes.
Your Rights
You have rights under the Data Protection laws including the right to access the information we hold about you and receive a copy of that information (subject to any legal restrictions that may apply), to have the information corrected if it is inaccurate, and to have it updated if it is incomplete.
We may ask for proof of your identity before we can respond to your request.
In certain circumstances you may also have the following rights:
- The right to restrict or object to the processing of your personal data;
- Where you have provided personal data voluntarily, or otherwise consented to its use, the right to withdraw your consent;
- The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you;
- The right to receive a copy of the personal information which you have provided to us, in a structured, commonly used and machine-readable format or to request that we transfer that information to another party (known as “data portability”).
How to contact us
If you wish to exercise any of your rights, please contact us at:
Simon Mahaffey
Data Protection Officer
IQUW
30 Fenchurch Street
London
EC3M 3BD
dpo@iquw.com
If you are not satisfied with our use of your personal data or our response to any request by you to exercise your rights in relation to your personal data, please contact DPO@iquw.com
You also have a right to make a complaint to the Information Commissioner:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate)
