Privacy Policy

1. Changes to the Privacy Protocol and your duty to inform us of changes

We updated this Privacy Policy to comply with the Data Protection Act 2018. Please ensure that you have read this updated version and we encourage you to check back periodically for any further changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. Application of this protocol

RiverStone Holdings Limited and Advent Capital (Holdings) Limited, together with their respective subsidiaries, including but not limited to RiverStone Insurance (Malta) SE, RiverStone Insurance (UK) Limited, RiverStone Management Limited and RiverStone Managing Agency Limited and RiverStone International Ireland DAC (together the “RiverStone International Group” or “we” or “us“) are committed to compliance with data protection laws. This protocol (“Privacy Protocol“) sets out the RiverStone International Group’s personal information collection and sharing practices in relation to the personal information relating to policyholders or claimants and their agents and relatives (“you“) that we collect and use for the administration of (re)insurance policies and products that we insure or reinsure.

We take your privacy very seriously. Please read this Privacy Protocol carefully as it contains important information about the RiverStone International Group and explains how and why we may collect, store, use and share information relating to you. It also explains your rights relating to your personal data and how to contact us.

This Privacy Protocol is intended to explain our privacy practices and covers the following areas:

• what personal information about you we may hold or collect;
• how we may use your personal information;
• who we may disclose your personal information to;
• how we protect your personal information;
• contacting us and your rights to access and update your personal information; and
• how changes to this Privacy Protocol will be made.

A summary of this information is contained in the table in section 4 below.

The RiverStone International Group’s website at www.rsml.co.uk (the “Site“) may contain links to other third party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you provide any personal information to such third-party websites.

3. Information we may collect about you

It is important that you read this privacy protocol together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy protocol supplements the other notices and is not intended to override them.

We may collect and process the following personal information about you:

• information that you provide by filling in forms or uploading onto the Site;
• information including your name, address, contact details, details relating to a claim (which depending on the nature of the claim may include medical reports and reports of criminal convictions or crime reports (“Claim Details”)) that you, your employer or an organisation who we insure or a third-party claimant provides to us in relation to the administration of an insurance / reinsurance policy that we insure or reinsure;
• information relating to a complaint made by you, including your name, address and contact details; if the complaint relates to a claim this may also include Claim Details;
• information relating to any request for assistance or support, including your name, address, contact details and details of any vulnerabilities (which may include medical reports) and financial information to support the claim;
• information relating to any criminal or fraudulent activities provided to us by you or third parties (such as anti-fraud agencies or other insurers);
• if you contact us, we may keep a record of that correspondence or details of any conversation we may have with you; and
• details of your visits to the Site and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

4. Uses made of your personal information

We have set out below, in a table format, a description of all the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest	Disclosure
Policy administration	Personal data: – Individual details – Policy information Special categories of personal data: – Risk Details – Previous claims – Current claims	Personal data: – Perform contract – Legitimate interests (to correspond with clients, beneficiaries and claimants in order to facilitate the placing of and claims under insurance / reinsurance policies) Special categories of personal data: – Substantial Public Interest
Claims processing – Managing (re)insurance claims including fraud, credit and anti-money laundering and sanctions checks – Defending or prosecuting legal claims – Investigating & prosecuting Fraud	Personal data: – Individual details – Identification details – Financial information – Policy information Special categories of personal data: – Credit and anti-fraud data – Risk Details – Previous claims – Current claims – Health data – Criminal records data – Other sensitive data	Personal data: – Perform contract – Legitimate interests (to assist our clients in assessing and making claims) – Legitimate interests (to assist with the prevention and detection of fraud) Special categories of personal data: – Legal claims – Perform contract – Substantial Public Interest	– Claims handlers – Solicitors – Loss adjustors – Experts – Third parties involved in the Claim – Cedants / Retrocessionaires – Private Investigators – Police – Third parties involved in the investigation or prosecution – Other insurers / reinsurers – Anti-fraud databases
Throughout the (Re)insurance lifecycle – Transferring books of business, company sales and reorganisations – General risk modelling & underwriting – Complying with our legal or regulatory obligations	Personal data: – Individual details – Identification details – Financial information – Policy information Special categories of personal data: – Credit and anti-fraud data – Risk Details – Previous claims – Current claims	Personal data: – Legitimate interests (to build risk models that allow placing of risk with appropriate insurers) – Legitimate interests (to build risk models that allow accepting of risk with appropriate premiums) – Legitimate interests (to structure our business appropriately) – Legal obligation Special categories of personal data: – Substantial Public Interest	– Courts – Purchaser – PRA, FCA, the CBI, ICO and other regulators – Other insurers / reinsurers – Professional Advisors
Complaints – To investigate any complaint made by you	Personal data: – Individual details – Financial information – Policy information Special categories of personal data: – Claim details (including details of injury and criminal records)	Personal data: – Legitimate interests – Performance of a contract with you – Legal obligation Special categories of personal data: – Substantial Public Interest	– Financial Ombudsman – Professional Indemnity Insurers – PRA, FCA, the CBI, and other regulators
Recovery of payments – To recover any payments due to us and where necessary to enforce such recovery through the engagement of payment collection agencies or taking other legal action (including the commencement and carrying out of legal and court proceedings).	Personal data: – Individual details – Financial information	– Legitimate interests (to recover money owed by third parties and due to us)
Customer service – To analyse it in order to better understand the service we provide and in order to better understand our business; – to notify you about changes to our services; and – to ensure that content from our – Site is presented in the most effective manner for you and for your device	Personal data: – Individual details – Policy information	– Legitimate interests (to improve the services we provide to you)	– Web development company (for the purpose of hosting our website)

Processing your data in relation to an insurance / reinsurance policy:

We may use your personal information in the following ways:

• to decide whether to enter into any proposed transaction with you or your employer or organisation that we insure and to administer (re)insurance products where you are the policyholder or a person involved in any claim, including in certain circumstances, disclosing such information to third party anti-fraud agencies for the purposes of detecting and preventing fraud and crime (as further set out below);
• to identify you and to carry out any identity checks as may be required by applicable law and regulation and best practice at any given time;
• to recover any payments due to us and where necessary to enforce such recovery through the engagement of payment collection agencies or taking other legal action (including the commencement and carrying out of legal and court proceedings).

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures to third parties

We may also permit selected third parties and agents to use your personal information, for the purposes set out in paragraph 4 above who will be subject to obligations to process such information in compliance with the same safeguards that we deploy. Specific examples are set out in paragraphs 6 below but do not in any way limit this paragraph 5. All such disclosures will only be made in accordance with applicable laws, including banking secrecy laws.

6. Fraud prevention

If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies or other insurers and may be recorded by us or by them.

Law enforcement agencies may access and use this information.

We and other organisations may also access and use this information to prevent fraud and other crimes, for example when:

• deciding whether to make a payment to you under an insurance / reinsurance policy;
• taking steps to recover payments due to us (as outlined in paragraph 4 above); and
• checking details of job applicants and employees.

We, and other organisations that may access and use information recorded by fraud prevention agencies, may do so from other countries.

We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or in order to enable the RiverStone International Group to comply with its regulatory requirements or dialogue with its regulators as applicable.

7. Transmission, storage and security of your personal information

No data transmission over the internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with applicable data protection legislative requirements.

All your information is stored on our secure servers (or secure hard copies) and accessed and used subject to our security policies and standard.

Your personal information may be accessed by staff or suppliers in, transferred to, and/or stored at a destination outside the European Economic Area (“EEA“) in which 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.

We will retain your personal information for as long as is necessary for the processing purpose for which they were collected. Certain claims details and correspondence may be retained until the time limit for any legal challenges to the claims has expired or in order to comply with regulatory requirements regarding the retention of such data. Data may also be retained for or included in analysis carried out by the RiverStone International Group with respect to its own business.

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

8. Your rights

Your legal rights

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time but only where we are relying on consent to process your personal data. Withdrawing you consent will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer whose details are set out below.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Contacting us

A member company of the RiverStone International Group is the data controller in respect of your personal information processed by us under this Privacy Protocol. That member company has delegated the administration of its data protection duties to RiverStone Management Limited for the purposes of corresponding with individuals whose personal information the RiverStone International Group holds and uses.

We can be contacted in relation to your rights or any questions you may have in respect of this Privacy Protocol or our processing of your personal information at the following addresses:

Post:
Data Protection Officer
RiverStone Management Limited
Park Gate
161-163 Preston Road
Brighton
East Sussex
BN1 6AU

Email: DPO@rsml.co.uk

10. Changes to our Privacy Protocol

We may change the content of our website or services without notice, and consequently our Privacy Protocol may change 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 personal information.

11. Access to our Privacy Protocol

If you would like to receive this Privacy Protocol in another format (for example audio, large print or braille) then please contact us as set out in paragraph 9 above.