Privacy Policy
Howden Re consists of a number of reinsurance and capital markets & advisory intermediaries (including TigerRisk Partners, LLC and its subsidiaries, as well as Howden Reinsurance Brokers Ltd and Howden Capital Markets Ltd) (“Howden Re”, “we”, “our” and “us”) that may need to collect and process personally identifiable information in order to deliver our products and services.
This Privacy Policy applies to you in the event that we have collected personally identifiable information from or about you in our role as a ‘data controller’. It explains when, why and how we collect and process your personally identifiable information, the third parties with which we may need to share it and why, what your rights are, and how you can enforce these rights with us. Unless explicitly provided herein, this Privacy Policy does not apply to the practices of companies that we do not own or control, or to people that we do not employ or manage. Except as described in this Privacy Policy, we do not sell, rent, share or disclose your personally identifiable information to or with any other organizations.
We may revise this Privacy Policy from time to time in order to reflect any changes in how we process personally identifiable information, or to satisfy any new requirements under applicable privacy laws. If we make any significant changes we will let you know directly, otherwise we encourage you to check our website (“Site”) regularly as the most current version of this Privacy Policy will govern our use of your personally identifiable information whether collected through our Site or through our other dealings with you.
1. TYPE AND USES OF INFORMATION WE COLLECT FROM YOU:
We or vendors operating on our behalf may need to collect and use information about you for a range of purposes, such as when you apply for a job, request information from us or when we provide you, or a business you represent, with a reinsurance, capital markets or strategic advisory service (“Services”). This information may include your name, title, date of birth, email address, phone number, residential address, as well as information relating to your profession. In certain circumstances, we may need to collect more sensitive personal information about you but only where this is strictly necessary for the purpose in question and where we have a valid legal basis to do so as explained under Section 3.
Children
We do not solicit, collect, or maintain personally identifiable information from individuals who we have actual knowledge are under the age of 13. If you are a parent or guardian, please contact us if you believe information regarding a child has been collected by us through our Site.
2. INFORMATION AUTOMATICALLY COLLECTED:
When you visit our Site we may collect some information automatically, for example through the use of cookies as explained below. By collecting this information we get a better understanding of your needs and what products and services we can develop to meet those needs. All the information we gather helps us understand your preferences and how well our Site is functioning so we can continually improve your online experience with us. We may also use such information to improve our products and services, and to provide you information and advertisements regarding those products and services.
Links, Embedded Content, and Buttons
We may keep track of how you interact with links across our Site or how you interact with our email notifications. We do this to help improve our services, provide information and advertising, or to analyse how many times a particular link was clicked. Our Site may contain links to other websites, content embedded in our Site that comes from or relates to other websites and services, and buttons from other websites and services such as social media websites like Facebook, Twitter, and LinkedIn, and these third parties may use cookies or other tracking devices to collect and track information about you across the Internet. You should check the privacy and cookie policies of these other websites and entities, particularly when providing personally identifiable information, or to find out what other information they collect from users, whether while on their platform or website or in relation to links, buttons, or embedded media on this Site or elsewhere.
Information From Your Computer
We may ourselves, or through our third-party service providers, collect information about your computer, such as the browser, operating system, IP address, country and other geolocation data, date and time of visit, whether you are using a mobile device and what type, referring websites, the search engine queries you used to get to our Site, the pages of our Site you visit and your activities on our Site such as what images, videos, or other imbedded media you view, as well as the amount of time spent on our pages, and the number of pages visited. Some of this information may be collected using cookies, as further explained below. This information is used for a variety of purposes to improve our Site and its content, including without limitation to gather broad demographic data, identify trends and statistics, help diagnose problems with our server, and to administer our Site and its content. We may collect and share information between pages of our Site for the proper functioning of our Site, as well as authentication. We may also use this information to provide you with information and advertising regarding our products and services.
Our Site may use “cookies” to provide information on your computer. Cookies are pieces of data that a website can send to your browser, which may then be stored on your device. We may use both session and persistent cookies on our own or through our third-party service providers as described below. Cookies may save your preferences while you are at our Site, such as allowing for persistent login on pages that require logging in, and we may use them to provide you with tailored information as you use our Site. Cookies help us, among other things, to determine which areas of our Site are popular by tracking hits to those areas, which may in turn allow us or our third-party providers to provide you with targeted information or advertising regarding our products and services.
You can select which non-essential cookies (such as advertising cookies) you are happy to agree to by selecting these through our cookie banner. Alternatively you can modify your preferences from within your browser settings.
Web Beacons
We may employ Web beacons (also called single-pixel gifs), which are customized links or similar technologies, on the Site and when sending you messages, newsletters, or promotional emails or in using third party service providers. Web beacons allow us to (a) determine whether you have opened, or acted upon, a promotional email and which links you have clicked on in order to deliver to you more focused communications and other content, (b) allow us to count the number of users who have visited certain webpages and effectively deliver services, and (c) enable us to compile aggregated statistics and determine the efficacy of promotions by using Web beacons from third parties.
Combining of Information
Except as set forth in this Privacy Policy, we generally do not combine information about you that is collected on the Site with information we have related to you that is collected through means other than through the Site.
3. LEGAL BASES AND PURPOSES OF PROCESSING
Our subsidiaries situated in the United Kingdom (UK) and European Union (EU) only collect and use personal information where one of the legal bases below can be satisfied:
- Where the use of personal information is necessary to achieve a legitimate business interest; for example, to arrange and administer Services for our clients (who may be your employer), to respond to third party claimants, to provision you with access to one of our proprietary systems, to maintain accurate records in our systems, to identify opportunities for improving Services through the use of data analytics, to facilitate internal reporting between Howden Re subsidiaries, to respond to both internal and external queries, or to send you marketing in professional context;
- Where the use of personal information is necessary to enter into, or perform, a contract; for example, to take steps towards entering into an employment contract with you;
- Where the use of personal information is necessary to comply with a legal obligation; for example the rules set by our supervisory authorities, to detect and prevent fraud, money laundering and other financial crimes, to fulfil any rights you may have under applicable privacy laws, to handle complaints, to handle legal claims, and to comply with other legal requirements including those set by our regulators; or
- Where the use of personal information is based on consent; for example, if you permit us to contact you for marketing purposes.
With respect to sensitive personal information, which may include health-related information, our UK and EU subsidiaries only collect and process this type of information where one of the more narrow conditions below can be satisfied:
- You have provided us with your explicit consent to use this information;
- The use of this information is necessary to establish, exercise or defend a legal claim;
- The use of this information is necessary to carry out employment obligations, provided that there is a basis for this in law; or
- The use of this information is necessary for reasons of substantial public interest, with re(insurance) activities being a lawfully recognised reason across the UK and parts of the EU.
4. SHARING OF YOUR INFORMATION
Limited disclosure of information collected through the Site
We do not sell, rent or lease your information to others without your consent, except as provided in this Privacy Policy. In general, the information you provide will be used to support your relationship with us and to enhance and improve our Site, products, services, and advertising. We may engage third party service providers, consultants, and independent contractors to perform functions and provide services for us including without limitation those third-party service providers mentioned below. We may share the information we collect through our Site with these service providers so that they can perform services for us in relation to the Site and our business. For example, we may share your information with our advertising and email vendors so that they can provide services to us such as emailing you about our products and services and for supporting employment opportunity listings on the Site.
In addition to the situations described above, we may use and disclose visitor information in special instances when we have reason to believe disclosing this information is necessary to investigate, identify, contact, or bring legal action against someone who may be causing injury to or interfering with our rights or property, other Site visitors, or anyone else. We may disclose visitor information when subpoenaed, for government investigations, and when we otherwise believe in good faith the law requires it.
Third-Party Service Providers used on our Site
We may use a variety of third-party services to help provide our services, to help us understand the use of our services, provide information and provide advertising regarding our Site and our products and services and to process employment applications, among other services.
Third party services providers may include, but are not limited to, Google Analytics. These third-party service providers may collect, store, and share information as further dictated by the privacy policies and disclosures of those third parties. Google, Inc. may utilize the data collected to track and examine the use of this Site, to prepare reports on its activities and share them with other Google, Inc. services. Google, Inc. may also use the data collected to contextualize and personalize the ads of its own advertising network. You can reject the use of Google Analytics data either through our cookie banner or as instructed here, and you can view Google’s privacy policy here.
Disclosures of information collected through means other than through the Site
More generally, and where applicable, we may disclose personal information to reinsurers, intermediaries, and agencies, and to third-party vendors for a variety of legal and security risk management services, such as credit reference, criminal record, fraud prevention, data validation and other professional advisory services, and where necessary to prevent and detect fraud, money laundering, government sanctions laws and terrorist financing. We may also disclose information to our third party service providers who help us manage our IT and back office systems, or who provide platforms to us that we then use or make available to you.
Business Transfers
In the event that we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets or change in our ownership or control, your information may be sold or transferred as part of that transaction.
Internal sharing
Depending on our relationship with you and the Services you may receive from us, we may share your personal information with other companies in Howden Re or the Howden Group more widely. This sharing will generally be for the following purposes, and on the condition that only the minimum amount of personal information is shared:
- To receive administrative support from those companies, such as the receipt of IT, HR, Finance and Compliance services;
- So that these companies can provide market insight to (re)insurers on a confidential basis, but only where personal information has been aggregated or anonymised; and
- So that we can offer you services that may be available from another company in the Howden Group, but only if permitted under electronic marketing laws.
5. SHARING OF YOUR INFORMATION
For business purposes, to help prevent/detect crime or where required by law, we may need to transfer your personal information to parties based overseas. Where we do this, we will ensure that your personal information is protected in accordance with applicable laws, which may include ensuring that the overseas party is based in a country considered to be adequate by the country in which the sending party is based, or by otherwise ensuring that the overseas party enters into a formal and enforceable legal agreement that reflects any statutory requirements.
6. RETENTION OF PERSONAL INFORMATION
The length of time during which Howden Re retains personal information depends upon the nature of the information obtained, the purpose for which information has been obtained, and the means by which the information has been obtained. In most cases we will retain your personal information for 7 years following the end of our relationship with you in order to ensure we can sufficiently handle any disputes, claims or complaints that may arise in connection with the relationship. In some cases we may need to retain your personal information for longer than this period, for example if a relevant policy allows for a longer claim notification window, and in some cases we shall only retain your personal information for a shorter period, for example if you ask us to provide you with a quote but then choose not to proceed.
7. POTENTIALLY APPLICABLE RIGHTS
Data protection and privacy laws around the world give you rights relating to your personal information. We have described below a list of rights commonly found in many data protection laws, including those in the UK and EU, however their applicability will generally depend on the location of the Howden Re entity that you have a relationship with and the reason for which your personal information is being used. Should you wish to enquire into the applicability of a right, enforce a right (generally at no cost to you) or make a data protection complaint, please use the contact details set out under Section 9.
Subject to legally permissible considerations, we will make all reasonable efforts to fulfil your request within one month of receipt, or to request additional information from you in order to fulfil your request. Please be advised, however, that under certain circumstances, including where we have a duty of confidentiality to other persons, we may be required and/or entitled to not fully address certain requests. If we cannot fully address your request, we will contact you as soon as is reasonably practicable to provide an explanation:
Right | Description |
Access | You have a right to request a copy of the personal information that we hold on you, along with meaningful information on how it is used and who we share it with, however there are some instances where we may not be able to provide you with some or all of the information we hold. Where this is the case we will explain to you why when we respond to your request, unless the relevant laws or regulations prevent us from doing so |
Rectification | You have a right to ask us to correct inaccurate or incomplete personal information that we hold about you. We will either confirm to you that this has been done, or if there is a valid reason that this cannot be done, we will let you know why |
Erasure | You can request that we delete your personal information in certain circumstances, for example if we no longer need the personal information for the purpose(s) for which we collected it. We will either confirm to you that this has been done, or if we are unable to delete it due to a compelling overriding reason we will let you know why |
Restrict Processing | You can ask us to restrict the processing of your personal information in certain circumstances. If you do so, we will either confirm that this has been done, or if we are unable to do so, we will let you know why |
Data Portability | In certain circumstances you have the right to request that your personal information be transferred to yourself or a nominated third party in a common, machine readable format. If you request this, we will either act upon your instruction and confirm to you that we have done so, or if there is a valid reason that this cannot be done, we will tell you why |
Object | You can object to us using your personal information to send you direct marketing. You can do this by simply clicking on the unsubscribe link in any email you receive from us or alternatively getting in touch with us. You can also object to us processing your personal information to achieve a legitimate business interest of ours as explained under Section 3. If you do so, we will either confirm to you that the processing has stopped, or explain why we believe our interest in the relevant activity outweighs your interest |
Automated Decision-Making | You have the right to object to decisions undertaken by purely automated means which produce legal or similarly significant effects about you. If you do so, we will arrange for someone to assess the automated decision and confirm the outcome of this assessment to you |
If you are located
in the UK or EU, you have the right to report complaints and concerns to a data
protection supervisory authority should you be unhappy with how we have responded
to a query, request or complaint. Please see below for the applicable contact
details:
| Location | Howden Re Data Controller(s) | Supervisory Authority Contact |
| UK | TigerRisk Partners (UK) Ltd TigerRisk Capital Markets & Advisory (UK) Ltd Howden Reinsurance Brokers Ltd Howden Capital Markets Ltd |
Click here |
| EU | TigerRisk Partners (Europe) BV | Click here |
8. SECURITY
We take commercially reasonable steps to protect data transmitted through our Site, and we rely upon our third-party vendors to supply security for the services they provide. We cannot and do not ensure or warrant the security of any information you transmit to us or from our online products or services. You transmit information to us at your own risk and should take all necessary precautions regarding the information you transmit, either to our Site and its related vendors or elsewhere on the Internet. In the event of an unforeseen compromise of any data in our possession, Howden Re will comply with all applicable laws regarding reporting such an event to the appropriate parties.
Subject to Terms of Use
This Privacy Policy is further subject to the terms set forth in any website terms of use (see https://howdenre.com/terms-of-use/) or legal disclaimers including without limitation all provisions regarding warranty disclaimers, limits of liability, and dispute resolution mechanisms such as the jurisdiction and forum provisions.
9. CONTACTING US
If you wish to discuss this Privacy Policy, or wish to enforce one of your rights or have any other related questions or concerns, you may contact us by emailing [email protected]. Alternatively you can contact us in writing at the following addresses:
- Howden Re, 100 First Stamford Place, 4th Floor West, Stamford, CT 06902, USA
- Howden Re, 1 Creechurch Place, London, EC3A 5AF, United Kingdom
10. California Personnel Privacy Notice
