Privacy Policy Probitas 1492 | Probitas 1492

Who Are We

Probitas Syndicate 1492 is a syndicate of Lloyd’s underwriters.

The underwriting of Probitas Syndicate 1492 at Lloyd’s is managed Probitas Managing Agency Ltd (“PMA”). The staff is employed by Probitas 1492 Services Ltd (‘Probitas’, ‘we’, ‘us’, ‘our’), which also maintains the underwriting records. Probitas is PMA’s Appointed Representative for regulatory purposes. Both Probitas and PMA are registered data controllers. Any personal data being processed in the course of the Syndicate’s business are controlled primarily by Probitas.

Probitas’ business address is 88 Leadenhall Street, London, EC3A 3BP. We also have an office in Mexico City.

Probitas Syndicate 1492 acts as the underwriters of your insurance or reinsurance policy. To find out more about how information might be used within the London Insurance Market, please visit www.londonmarketgroup.co.uk/gdpr .

Our Privacy Policy

Probitas is committed to protecting information which identifies and relates to you or other individuals (“personal data” including with respect to criminal conviction/offences or “special category personal data”) and complying with data protection laws.

This privacy policy sets out our personal data collection and sharing practices in relation to the personal data that we collect and use for the administration of insurance policies and reinsurance contracts.

The persons to which this privacy policy applies

Including: Policyholders, insureds, reinsureds, clients, suppliers, advisers, service providers, enquirers, beneficiaries or claimants and their agents and relatives (“you” or “our”).

Layered approach

Data protection laws require us to provide you with a lot of information about how we collect and use your personal information – and it is easy for all this information to become confusing.

We use a layered approach to providing you with the information required by law. This means that we may provide the information required in a number of different formats and documents. It means that in our initial contact with you, we may provide you only with the most important information about how we will use your personal information; but we will always provide you with easy access to all the further information you need about our privacy practices.

As an example, if you buy an insurance policy from us, then we may use this three layer approach:

A short form privacy notice in your policy related documentation that refers to this privacy policy
Access to this privacy policy online or by post
Access, via this privacy policy, to an insurance market standard information notice that explains in more detail how the insurance market works and uses personal information to provide (re)insurance cover.

What information do we collect about you

In order to deliver our (re)insurance services to you, we may collect the following information:

information you provide by filling in forms or upload forms
contact details such as your name, address, date of birth, email, details of additional people who you are including on the proposal or policy and your relationship with them
financial information such as bank details, salaries, details of insured items or cover required including the location of those items where applicable
personal injury details or medical conditions if relevant to your product or claim
details of previous insurance cover and details about any claim submitted under current/previous insurances which may include special category personal data
information about any criminal convictions or offences such as or County Court judgements or instances of bankruptcy or internal investigations
credit, fraud and anti-money laundering and sanctions checks
details of any complaints you raise
if you contact us, we may keep a record of that correspondence, voicemail or details of any conversation we may have with you
details of transactions you carry out through our portals, including the quotations obtained for insurance services and the insurance policies
information that is available from publicly available sources including social media websites and from other third parties

How and Why We Use Your Information

We may use your personal data for:

Quotation and inception purposes
- To make decisions on whether to provide (re)insurance
- to set you up as a client, including identity, fraud, credit and anti-money laundering and sanctions checks
- evaluating the risks to be covered and matching to appropriate policy / premium
Policy administration
- collection and refund of premiums
- general client care, including communicating with you regarding administration and requested changes to your policy
- sending you your policy documentation
Claims processing
managing insurance claims
defending or prosecuting legal claims
investigating and prosecuting fraud
Renewals
- contacting you in order to renew your insurance policy
Insurance lifecycle
- general risk modelling and underwriting
- complying with our legal or regulatory obligations
- transferring books of business, company sales, mergers or acquisitions
to recover any payments due to us and where necessary to enforce such recovery through the engagement of debt collection agencies or taking other legal action
to analyse it in order to understand the service we provide and in order to improve our business
to manage our infrastructure, business operations and comply with internal policies and procedures
to monitor transactions to ensure service quality, compliance with procedures, compliance with procedures, to combat fraud and ensure compliance with UK/EU and international sanctions
to notify you about changes to our service or otherwise to fulfil your requests and respond to your queries
for marketing purposes by post and email

We will never process your personal data where these interests are overridden by your interests.

We may process your personal data because:

it is necessary for the performance of a contract: where we have a contract with you or a third party on your behalf, we will process your information in order to fulfil that contract and provide you with our services
it is necessary for the performance of a task carried out in the public interest: for example, claims analysis in order to calculate insurance risk ratings and premiums
it is in our or a third parties’ legitimate interests: for example, for the prevention and detection of fraud and claims analysis and any sale, merger or acquisition of all or part of the Probitas group
to meet our legitimate interests, for example to improve our services, to ensure we price our products appropriately, to manage risk, to manage our business efficiently, to perform audits, and to maintain accurate records. When we process personal information to meet our legitimate interests we always balance these against your fundamental rights and freedoms and put in place robust safeguards to ensure that your privacy is protected
we have your consent. If we require your consent, it will be made clear at the time your information is collected
to enhance the security of our network and information systems
to exercise, defend and protect our legal rights or other rights of third parties
to maintain our accounts and records
to modify, personalise or otherwise improve our services/ communications
to comply with foreign law, law enforcement, court and regulatory bodies’ requirements
to defend or make claims
to operate and expand our business activities
for research and development of new products
to correspond with clients, beneficiaries and claimants in order to facilitate the (re)insurance policies
to comply with a legal obligation and to cooperate with regulatory bodies to which we are subject
to protect your vital interest or the interest of another individual
to gather market intelligence, communicate with and tailor offers to individuals
for training and quality purposes
to conduct data analysis, which helps us assess risks, price our products appropriately, and improve own services

We may process your special category personal data or details of criminal convictions/offences because:

it is necessary for the provision of (re)insurance
it is necessary for reasons of substantial public interest
it is necessary for the defence of legal claims against us
we have your explicit consent
we are otherwise authorised by local law

How we collect your information

Depending on which of our services you use, we may collect information about you from various sources, including:

directly from you
from the policyholder of the policy you benefit from
your family members, employer or representative such as an insurance broker
other (re)insurance companies, coverholders or business partners;
credit reference agencies
anti-fraud databases, sanctions lists, court judgements and other publically available databases
government agencies such as the DVLA and HMRC
open electoral register
our overseas office(s)
in the event of a claim, third parties including the other party to the claim (claimant / defendant), witnesses, experts (including medical experts), loss adjustors, solicitors, and claim handlers

Who do we share your information with and why

We may share your information with:

our third parties’ suppliers who help deliver products and services on our behalf, such as payment card providers, claim handlers, data storage providers, event organisers
within the Probitas group of companies, including with PMA, to administer your policy and any related claims
national anti-fraud databases
auditors, regulators including Lloyd’s and ombudsman when required by regulatory or legal obligations
third parties in the event of any or all of the Probitas group being sold, merged or acquired
reinsurers and reinsurance brokers

Probitas may transfer your information to a country outside of the European Economic Area in order to deliver our services. Probitas ensure this transfer and processing is carried out with the appropriate safeguards and in compliance with data protection laws, such as being protected by the necessary contractual terms.

If we share your personal data it is only for the purposes set out in this privacy policy and we remain responsible for the management and security of personal information. Where Probitas 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.

We will share your information if we are required to by law. We may share your information with enforcement or public and governmental authorities if they ask us to, or to a third party in the context of actual or threatened legal proceedings, provided we can do so in compliance with data protection laws.

How Long Do We Keep Your Information

Probitas retains your personal information for as long as is reasonably necessary for the purposes for which it was originally collected and allowed by data protection laws. The length of time we keep your personal information is determined in accordance with the following criteria:

your relationship with us and the types of products and service you have with us
the length of time it is reasonable to keep records to demonstrate that we have fulfilled our obligations to you under the law
any limitations periods within which claims might be made
any retention periods prescribed by law, by regulators, professional bodies or associations
the existence of any relevant proceedings

Where your personal data is no longer required we will ensure it is securely deleted.

How do we keep your information secure

We are committed to keeping your information secure. Unfortunately no data transmission over the internet or any website can be guaranteed to be secure. We have put in place physical, electronic and operational procedures intended to safeguard and secure the information we collect. All Probitas staff have a legal duty to respect the confidentiality of information, and access to confidential information is restricted to only those who have a reasonable need to access it.

Where we have given you (or where you have chosen) a password which enables you to access any portal we operate, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

Your rights relating to your information

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 information
provide you with a copy of the personal information we hold about you
update any inaccuracies in the personal information we hold about you
delete any of your personal information that we no longer have a lawful ground to use
where processing is based on consent, stop that particular processing by withdrawing your consent
object to any processing based on our legitimate interests unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights
object to direct marketing
restrict how we use your personal information whilst a complaint is being investigated
transfer your personal information to a third party in a standardised machine-readable format
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)

These rights are not absolute and we will let you know in our correspondence with you whether we think they apply to you.

We may, in response to a request, ask you to verify your identity and to provide information that helps us to understand your request better. Once we have the necessary information from you and have concluded your request is valid, we will respond to you within one month of the receipt of a request.

Consent

Your consent to our processing of your personal information for certain purposes may be necessary to comply with applicable data protection laws; and where this is the case we will ask you for your consent in accordance with those laws.

You may withdraw your consent to such processing at any time. However, if you withdraw your consent in relation to (re)insurance cover that we have provided then this is likely to impact our ability to provide (re)insurance cover and pay claims under the cover.

Cookie Policy

Probitas only use cookies for session management, and we neither collect or not 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 against multiple sites.

Complaints Procedure

If you wish to exercise any of your rights, please make your request in writing to our Data Protection Manager whose contact details can be found below in the How to contact us section.

If you are unhappy with our response to your request, or you believe the way we have processed your information is not in keeping with data protection laws, we would like to hear from you so we can either fix the problem or further explain our decision.

Alternatively, you may contact our data protection regulator, the Information Commissioner’s Office (ICO) for guidance and advice, or to lodge a complaint. The ICO may be contacted at:

Online: www.ico.org.uk

Post: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113 (local rate)

How to Contact Us

If you have any questions, comments, complaints or wish to exercise your data protection rights, please contact the Probitas Data Protection Manager, Kate Stephens at:

kate.stephens@probitas1492.com

Or by post to the following address:

The Data Protection Manager
Probitas Syndicate 1492
88 Leadenhall Street
London
EC3A 3BP

Changes to Our Privacy Policy

We keep our privacy notice under regular review and the latest version will be available on this website. This privacy notice was last updated in May 2023.