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PRIVACY POLICY

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 * Privacy Policy

We take the privacy of our customers seriously and are committed to protecting
your privacy. This policy explains how we collect, use and transfer your
personal data, and your rights in relation to the personal data collected and
stored by us when you use our website or otherwise engage with our services.






This policy sets out the following:

 * What personal data we collect about you and how;
 * How the data is used;
 * Our legal basis for collecting your information; 
 * Who we share your data with;
 * Where we transfer your information; 
 * How long we retain your information;
 * Your rights and choices in relation to the data held by us;
 * How to make a complaint in relation to the data held by us;
 * How we use cookies on our website; and
 * How to contact us with any queries in relation to this notice, or the
   personal data held by us.


 WHO IS TMHCC?

Tokio Marine HCC is a trading name of HCC Insurance Holdings, Inc. and its
subsidiaries worldwide.  Please see here for further information:
http://www.tokiomarinehd.com/en/group/.  These companies are collectively
referred to in this privacy statement as “TMHCC”, “we”, “us” or “our”. 

For the purposes of European data protection laws, if you are visiting our
website www.tmhcc.com (our "Website") or otherwise engaging with our services
from the European Economic Area (or "EEA"), the data controller of your
information is TMHCC.


WHAT IS PERSONAL DATA?

In this privacy policy, references to “personal information” or “personal data”
are references to information that relates to an identified or identifiable
individual.  Some examples of personal data are your name, address and telephone
number but it may also include information such as your IP address and location,
in certain jurisdictions.


WHAT PERSONAL DATA DO WE COLLECT?

We collect personal data that you provide to us when you sign up for our
services, such as your contact information and financial information.  We may
also collect commercial information based on how you interact with our services,
such as the products or services you’ve purchased or other Internet or network
activity, such as your Website browsing history or mobile device information. 

Below are some more details on the type of personal data we collect.

INFORMATION THAT IS PROVIDED BY YOU

In order to provide services to you, we may ask you to provide personal
information.  This may include, amongst other things, your name, email address,
postal address, telephone number, gender, date of birth, passport number, bank
account details, credit history and claims history, citizenship status, marital
status depending on the service you are seeking.  The personal information that
you are asked to provide, and the reasons why you are asked to provide it, will
be made clear to you at the point at which we ask you for it.

Some of the information that you provide may be ‘Special category’ (or
‘sensitive’) personal data”.  Sensitive personal data relates to your racial or
ethnic origin, political opinions, religious or philosophical beliefs, or trade
union membership, genetic data, biometric data for the purpose of uniquely
identifying a natural person, data concerning health or data concerning a
natural person’s sex life or sexual orientation, and can sometimes be inferred
from other, non-sensitive, information that you have provided.

INFORMATION THAT WE COLLECT ON OUR WEBSITE 

When you visit our Website, we will seek your consent to collect certain
information from your device.  In some countries, including countries in the
EEA, this information may be considered personal information under applicable
data protection laws.

Specifically, the information we are seeking to collect includes information
like your IP address, device type, unique device identification numbers, browser
type, broad geographic location (e.g. country or city-level location) and other
technical information.  We may also collect information about how your device
has interacted with our Website, including the pages accessed and links
clicked.  

Collecting this information enables us to better understand visitors to our
Website, where they come from, and what content on our Website is of interest to
them.  We use this information for our internal analytics purposes and to
improve the quality and relevance of our Website to our visitors.

Some of this information may be collected using cookies and similar tracking
technology, as explained further under the heading “Cookies" below.

INFORMATION THAT WE OBTAIN FROM THIRD PARTY SOURCES

From time to time, we may receive personal information about you from third
party sources but only where we have checked that these third parties either
have your consent or are otherwise legally permitted or required to disclose
your personal information to us.

For example, if you are an individual who is obtaining insurance from us via an
insurance broker, we may obtain data about you from your broker in order to help
us prepare your quote and/or your insurance policy.  For information about how
your broker uses and shares your personal data, please refer to the broker’s own
privacy statement.

We may, where we are legally permitted to, also collect personal data from the
following sources in order to provide services to you:

 * Credit reference agencies;
 * Anti-fraud and other databases;
 * Government agencies;
 * Electoral register;
 * Court judgments; 
 * Sanctions lists;
 * Family members; and
 * In the event of an insurance claim: the other party to the claim, witnesses,
   experts, loss adjusters, solicitors and claims handlers.


HOW IS PERSONAL DATA USED?

We may need to use your personal data in order to carry out the following
activities:

 * To set you up as a new client (including carrying out ‘know your customer’
   checks);
 * To provide you with an insurance quote;
 * To provide our products and services to you;
 * To respond to your enquiries;
 * To accept payments from you;
 * To communicate with you about your policy;
 * To renew your policy;
 * To obtain reinsurance for your policy;
 * To process insurance and reinsurance claims;
 * For general insurance administration purposes;
 * To comply with our legal and regulatory obligations;
 * To model our risks;
 * To defend or prosecute legal claims;
 * To investigate or prosecute fraud;
 * To respond to your enquiries;
 * When you sign up for an online account
 * To secure our network and our Website, debug the Website and repair errors;
 * To conduct audits related to our interactions with you;
 * To make our products and services better and to develop new products and
   services; and
 * To send you notices and information regarding our products or services,
   including notifying you about special promotions or offers, where we are
   legally permitted to do so.


OUR LEGAL BASIS FOR COLLECTING YOUR INFORMATION

Our legal basis for collecting and using your personal data will depend on the
personal data concerned and the specific context in which we collect it. 

We will normally collect personal data where we need the information to provide
you with our services / perform a contract with you, where the processing is in
our legitimate interests and not overridden by your data protection interests or
fundamental rights and freedoms, or with your consent. 

In some cases, we may use your personal data for a legal obligation, e.g. in
order to complete ‘know your customer’ and money laundering checks before taking
you on as a new client. 

If we ask you to provide personal information to comply with a legal requirement
or to perform a contract with you, we will make this clear at the relevant time
and advise you whether the provision of your personal information is mandatory
(as well as of the possible consequences if you do not provide your personal
information).  You are under no obligation to provide personal data to us. 
However, if you should choose to withhold requested data, we may not be able to
provide you with certain services. 

Similarly, if we collect and use your personal information in reliance on our
legitimate interests (or those of any third party), we will make clear to you at
the relevant time what those legitimate interests are.

If you are a UK resident, we may collect and use your personal information,
including sensitive personal information, on the basis of the insurance
derogation in the UK Data Protection Act 2018.

If you are an EU resident, we may collect and use your personal information,
including sensitive personal information, on the basis of the substantial public
interest of insurance purposes, as regulated in the General Data Protection
Regulation (GDPR).   If you have questions about or need further information
concerning the legal basis on which we collect and use your personal
information, please contact us using the contact details provided under the
“Contact Us" section below.


WHO IS YOUR PERSONAL DATA SHARED WITH?

We may disclose your personal information with the following categories of
recipients.  

 * To our group companies, third party service providers and partners who
   provide data processing services (for example data hosting and storage
   companies, email marketing affiliates, and payment and claims processing
   companies) or who otherwise process personal information for purposes that
   are described in this Privacy Policy (see “How is personal data used?”).  A
   list of our current group companies is available at
   http://www.tokiomarinehd.com/en/group/ and a list of our current service
   providers and partners may be available upon request;
 * To any competent law enforcement body, regulatory, government agency, court
   or other third party where we believe disclosure is necessary (i) as a matter
   of applicable law or regulation, (ii) to exercise, establish or defend our
   legal rights, or (iii) to protect your vital interests or those of any other
   person;
 * To a potential buyer (and its agents and advisers) in connection with any
   proposed purchase, merger or acquisition of any part of our business,
   provided that we inform the buyer it must use your personal information only
   for the purposes disclosed in this privacy policy;
 * to any other person with your consent to the disclosure.

We do not sell (or exchange) your personal information for monetary
compensation.  

If you are a US resident, from time to time we may share your personal
information with third parties for a third party’s own direct benefit and this
type of sharing may be considered a sale under certain applicable laws.  For
more information on the type of information we may share in this manner, please
contact us. 


INTERNATIONAL TRANSFERS

Your personal data may be transferred to, and processed in, countries other than
the country in which you are resident.  These countries may have data protection
laws that are different to the laws of your country.

Specifically, the servers of HCC Insurance Holdings Inc. are located in the
United States.  However, other TMHCC group companies are registered elsewhere,
including in the EEA and operate around the world.  This means that when we
collect your information we may process it in any of these countries.

We have taken appropriate safeguards to require that your personal data will
remain protected in accordance with this privacy policy.  These include
implementing the European Commission’s Standard Contractual Clauses for
transfers of personal information between our group companies, which require all
group companies to protect personal information they process from the EEA in
accordance with European Union data protection law.  

Our Standard Contractual Clauses can be provided on request.  We have
implemented similar appropriate safeguards with our third party service
providers and partners and further details can be provided upon request.


HOW LONG IS PERSONAL INFORMATION RETAINED FOR?

We will keep your personal data on our records for as long as we have an ongoing
legitimate business need to do so.  This includes providing you with a service
you have requested from us or to comply with applicable legal, tax or accounting
requirements.  It also includes keeping your data for so long as there is any
possibility that you or we may wish to bring a legal claim under your insurance
contract, or where we are required to keep your data for legal or regulatory
reasons.  Please contact us using the contact details provided under the
“Contact Us" section below should you require further information on our record
retention procedures.

We may also retain your personal data where such retention is necessary in order
to protect your vital interests or the vital interests of another natural
person.


YOUR RIGHTS AS A DATA SUBJECT

You have the right to opt-out of marketing communications we send you at any
time.  You can exercise this right by clicking on the “unsubscribe” or “opt-out”
link in the marketing e-mails we send you or contacting us using the details
provided under the “Marketing” heading below ukmarketing@tmhcc.com.

If you are an EU resident, you will need to opt-in to receive marketing from us.
If you then wish to unsubscribe at any point you can do so by clicking on the
“unsubscribe” or “opt-out” link in the marketing e-mails we send you or
contacting us using the details provided under the “Marketing” heading below.

Similarly, if we have collected and processed your personal information with
your consent, then you can withdraw your consent at any time.  Withdrawing your
consent will not affect the lawfulness of any processing we conducted prior to
your withdrawal, nor will it affect processing of your personal information that
was lawfully collected on grounds other than consent.

You have the right to complain to a data protection authority about our
collection and use of your personal information.  For more information, please
contact your local data protection authority. (Contact details for data
protection authorities in the European Economic Area, Switzerland and certain
non-European countries (including the US and Canada) are available here.)

We respond to all requests we receive from individuals wishing to exercise their
data protection rights in accordance with applicable data protection laws.

You may exercise any of your rights in relation to your personal data by
contacting us using the details set out in the “Contact us” section at the
bottom of this page.  

If you are resident in the UK or EU, your principal rights under data protection
law are as follows:
a)the right to access;
b)the right to rectification;
c)the right to erasure;
d)the right to restrict processing;
e)the right to object to processing;
f)the right to data portability;
g)the right to complain to a supervisory authority; and
h)the right to withdraw consent.

If you wish to access, correct, update or request deletion of your personal
information, we will ask you to provide us with a copy of any two of the
following documents:  Driver’s licence; Passport; Birth certificate; Bank
statement (from the last 3 months); or Utility bill (from the last 3 months). 
With regards to your right of access, the first access request will be complied
with free of charge, but additional copies may be subject to a reasonable fee.

In addition, you can object to processing of your personal information, ask us
to restrict processing of your personal information or request portability of
your personal information.

If we have collected and processed your personal information with your consent,
then you can withdraw your consent at any time.  Withdrawing your consent will
not affect the lawfulness of any processing we conducted prior to your
withdrawal, nor will it affect processing of your personal information conducted
in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our
collection and use of your personal information.  For more information, please
contact your local data protection authority. In the table below we have listed
the contact details of the data protection authorities where we have local
branches:

Country

Data protection supervisory authority contact details

UK

Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, UK

Tel: +44 (0) 303 123 1113

Email:dpo@ico.org.uk

Website: http://www.ico.org.uk

Belgium

Autorité de la protection des données -Gegevensbeschermingsautoriteit (APD-GBA)

Address: Rue de la Presse 35 – Drukpersstraat 35, 1000 Bruxelles - Brussel
Tel.: +32 2 274 48 00
email:contact@apd-gba.be
Website:https://www.autoriteprotectiondonnees.be/-https://www.gegevensbeschermingsautoriteit.be/

Germany

Die Bundesbeauftragte für den Datenschutz und die Informationsfreiheit
Address: Husarenstraße 30,53117 Bonn
Tel.: +49 228 997799 0; +49 228 81995 0
email:poststelle@bfdi.bund.de
Website:http://www.bfdi.bund.de/

The local German data protection authorities' contact details are availablehere.

France

Commission Nationale de l'Informatique et des Libertés- CNIL
Address: 3 Place de Fontenoy,TSA 80715 – 75334 Paris, Cedex 07
Tel.: +33 1 53 73 22 22
Website:http://www.cnil.fr/

Spain

Agencia Española de Protección de Datos (AEPD)
Address: C/Jorge Juan, 6, 28001 Madrid
Tel.: +34 91 266 3517
email:internacional@aepd.es
Website:https://www.aepd.es/

Italy

Garante per la protezione dei dati personali
Address: Piazza di Monte Citorio, 121, 00186 Roma
Tel.: +39 06 69677 1
email:garante@garanteprivacy.it
Website:http://www.garanteprivacy.it/

Luxembourg

Commission Nationale pour la Protection des Données
Address: 1, avenue du Rock’n’Roll, L-4361 Esch-sur-Alzette
Tel.: +352 2610 60 1
email:info@cnpd.lu
Website:http://www.cnpd.lu/

Netherlands

Autoriteit Persoonsgegevens
Address: Bezuidenhoutseweg 30, P.O. Box 93374, 2509 AJ Den Haag/The Hague
Tel.: +31 70 888 8500
Website:https://autoriteitpersoonsgegevens.nl/nl

Contact details for other data protection authorities in the European Economic
Area, Switzerland and certain non-European countries (including the US and
Canada) are available here.

We respond to all requests we receive from individuals wishing to exercise their
data protection rights in accordance with applicable data protection laws.

If you are based in the UK, you may exercise any of your rights in relation to
your personal data by contacting us using the email dpo@tmhcc.com.

If you are based in the EU, you may exercise any of your rights in relation to
your personal data by contacting us using the email DPO-TMELux@tmhcc.com

Alternatively you can use the details set out in the “Contact us” section at the
bottom of this page.

If you are resident in the US, applicable law may entitle you, upon verifiable
request, to receive disclosures relating to: 

 * The categories and specific pieces of information we have collected;
 * The categories of sources from which the personal information is collected;
 * The business or commercial purpose for collecting personal information; and
 * The categories of third parties with whom we share personal information.

If you are based in the US, you may exercise any of your rights in relation to
your personal data by contacting us here or by calling us toll free
at 888-688-0775. 

If you wish to exercise any of the rights described above, we will ask you to
verify your identity.  We generally will not charge to reply to your request,
but we may charge a reasonable fee or refuse your request if the request is
unjustified or excessive.  


AUTOMATED DECISION MAKING

In some instances, our use of your personal information may result in automated
decisions being taken (including profiling) that legally affect you or similarly
significantly affect you.  

Automated decisions mean that a decision concerning you is made automatically on
the basis of a computer determination (using software algorithms), without our
human review.  For example, in certain instances we may use automated decisions
to establish whether we will offer insurance coverage to a prospective insured. 
We have implemented measures to safeguard the rights and interests of
individuals whose personal information is subject to automated decision-making.

When we make an automated decision about you, you have the right to contest the
decision, to express your point of view, and to require a human review of the
decision.


MARKETING

As mentioned above, we may use your personal data to send you marketing
materials. 

If you are a UK or EU resident, you will need to opt-in to receive marketing
from us. If you then wish to unsubscribe at any point you can do so by clicking
on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you or
contacting us using the details provided under the “Marketing” heading below, or
at ukmarketing@tmhcc.com.

If you are resident in the US, you do not need to opt-in to receive marketing
materials from us, and you have the right to opt-out of receiving such
communications. If you would like to stop receiving marketing information from
us, please unsubscribe by clicking the “unsubscribe” link in the relevant
marketing email, email us at marketing@tmhcc.com or write to us at:

Tokio Marine HCC
Attn: Marketing Department
13403 Northwest Freeway
Houston, TX 77040
Telephone: (713) 690-7300


SECURITY

TMHCC is committed to keeping our customers’ data safe.  We have security
measures in place designed to protect against the loss, misuse and alteration of
personal data under our control.  For example, our security and technology
policies are periodically reviewed and enhanced as necessary and only authorised
personnel have access to user information.  We use Secured Socket Layer (SSL) to
encrypt financial information you input before it is sent to us.  The servers we
use to store personal data are kept in a secure environment.

Although we cannot ensure or guarantee that loss, misuse or alteration of data
will not occur, we use our best efforts to prevent this.  If you have any
concerns that your TMHCC account or personal data has been put at risk, please
contact us.


COOKIES

Our sites use cookies (a small piece of information that is placed on your
computer when you visit certain websites) to distinguish you from other users,
to track your browsing pattern and to build a profile of how you and other users
use our sites. This helps us to provide you with a good experience when you
browse any of our sites and also allows us to improve our sites. If you have an
online account with us, TMHCC also uses cookies to recognize you to pre-fill
forms to save you time. TMHCC does not mandate Cookies for you to access our
sites and you may freely set your browser to reject all Cookies or prompt you to
accept or reject them. Some of the cookies we use are session cookies and only
last until you close your browser, others are persistent cookies which are
stored on your computer for longer. We may collect information through web
beacons about your web browsing activities such as the address of the page you
are visiting, the address of the referrer page you had previously visited, the
time you are viewing the page, your browsing environment and your display
settings. We do this in order to optimize your browsing experience, the use of
web-based services and provide you with relevant information on TMHCC products
and services when you have opted-in to receiving such correspondence.  For
further information about TMHCC’s use of cookies, see TMHCC's Cookie Policy. 


TRACKING

TMHCC will not respond to Web browser “do not track” signals.  If you would like
additional information about online tracking and various opt-out mechanisms,
please see https://youradchoices.com/  

Because we link to social media sites, and from time to time may include
third-party advertisements, other parties may collect your personally
identifiable information about your online activities over time and across
different web sites when you visit this Site.

Please note that not all tracking will stop even if you delete cookies.


CHILDREN’S DATA

Our websites and applications are not directed to children under 16 and we do
not knowingly collect any personal information directly from children under 16.
If you believe that we are processing personal information pertaining to a child
inappropriately, we ask you to contact us using the information provided under
the “Contact Us” section.


CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in response to changing
legal, technical or business developments. When we update our Privacy Policy, we
will take appropriate measures to inform you, consistent with the significance
of the changes we make.  We will obtain your consent to any material Privacy
Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the “effective
date” displayed at the top of this Privacy Policy. 

Any changes will be effective only after the effective date of the change and
will not affect any dispute arising prior to the effective date of the change.


CONTACT US

If you have any questions about this Privacy Policy, please contact us using the
following contact details:

For residents in the UK:

Data Protection Officer
TMHCC
1 Aldgate
London
EC3N 1RE
DPO@tmhcc.com

For residents in the EU:

Data Protection Officer TMHCC-Tokio Marine Europe SA 33, Rue Sainte Zithe,
L-2763 Luxembourg DPO-TMELux@tmhcc.com
 
For residents in the US:

Data Protection Officer
TMHCC
1 Aldgate
London
EC3N 1RE
DPO@tmhcc.com

Residents in the US can also call us toll free at: 888-688-0775

 



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COOKIE MANAGEMENT

We use cookies that allow for the best experience and functionality of our
website. To guarantee that our website functions properly, essential cookies are
mandatory. However, non-essential cookies can be configured by you. For more
information about the cookies we use, please see our Cookies Management Policy
on the following link: Web Cookie Policy

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device. If you do not allow these cookies, you will experience less relevant
advertising.

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These cookies are necessary for our business and the website to function and
cannot be switched off. They can be set in response to actions made by you which
amount to a request for services, such as setting your privacy preferences,
logging in, filling in forms, or visiting a page on our website. Statistical
information these cookies collect is aggregated and therefore anonymous. You can
set your browser to block or alert you about these cookies, but some parts of
the site will not then work. These cookies do not store any personally
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Performance Cookies

These cookies allow us to measure and improve the performance of our site. They
help us assess the performance of our marketing programs and see how visitors
move around the site. All information these cookies collect is aggregated and
therefore anonymous. If you do not allow these cookies, we will not be able to
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