Ariel Re Ltd. and its subsidiaries and affiliates (collectively “Ariel Re” or “we,” “us,” or “our”) respect your privacy. This Privacy Notice (the “Privacy Notice” or “Notice”) explains how Ariel Re collects, uses, shares, and safeguards the personal information that you submit to us and that we collect through our websites (“Sites”), our services and products (“Services”), and through other means and third-parties. It explains your rights in connection with that personal information as well as how to contact us with questions of concerns. It applies to the interactions Ariel Re has with you in connection with our Sites, Services, or wherever this Privacy Notice is referenced or displayed.
Please note that certain rights, requirements, and disclosures in this Privacy Notice may be subject to exemption or otherwise may not apply to you based, for example, on applicable law or regulations.
Personal Information We Collect
As described in more detail below in this Privacy Notice, we rely on a range of legal reasons and permissions (sometimes called “legal basis”) to collect and use personal information, including with your consent, uses based on a balancing of legitimate interests, that are necessary for entering into and performing contracts as well as complying with legal obligations.
We also may obtain personal information from third parties. We will use and protect this personal information collected from third parties according to the practices described in this Privacy Notice plus any additional restrictions imposed by the source of the personal information.
Categories of Personal Information
|Categories||Examples of Personal Information|
|Identifiers||Name, home and work address, phone number, social security number, driver’s license number, passport number, tax identification number, other government-issued identification numbers, alien registration number, email address, username and password, marital status, online identifiers (e.g., social media handle), signature, customer identification number, policy number, IP address.|
|Financial and insurance underwriting information||Financial account numbers and related financial or account information, account balance, transactions, account history, income, debt, assets, credit history, credit score, criminal history, risk profile, and other information in connection with assessing your insurability and to provide policy quotes.|
|Protected classifications under applicable law||Age, date of birth, sex, gender, national origin, citizenship, race, ethnicity, marital status, and information about your health and/or disability status.|
|Commercial information||Records of personal property, purchase history.|
|Internet or similar network activity||Browsing history, search history, clickstream data, session information, browser and operating system type, navigation paths, date/time stamps, cookie identifiers, and other information about device characteristics and how you interact|
|Geolocation data Sensory data||Physical location or device location, including Global Positioning System (“GPS”) data. Audio recordings, video recordings, and photographs.|
Special Categories of Personal Information
We generally do not collect or require special categories of personal information (such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health information, biometric data, or sexual orientation) to access or use our Sites. However, to provide some Services, we may request certain categories of information. For example, we may need to collect health-related information or information pertaining to criminal history in connection with underwriting an insurance policy. In the event we may need to collect such special categories of personal information to provide a specific Service to you, we will obtain your consent as required by applicable law.
We may create de-identified or anonymous data from personal information by removing data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through obfuscation or through other means. This anonymized and de-identified data is not personal information, and our use of it is not subject to this Privacy Notice.
We collect the above described categories of personal information from the following categories of collection sources and third parties.
Applications and Forms. We may collect personal information from you, your family members, individuals who may benefit directly from any of our Services, or your authorized representatives during the application, account, or policy creation or renewal process, through other forms or applications, or through discussions we have with you, your family, or your authorized representatives.
Communications and Interactions with Us. We may collect personal information from you, or your authorized representative communicating with us, when you contact customer support, submit inquiries, request information from us, or participate in a promotion, contest, or survey.
Account Administration and Transactions. We may collect personal information from you and from records we create in connection with administering your account, when you make transactions, or when you submit a claim.
Our Websites and Mobile Applications. We may collect personal information from you or your device when you visit or interact with our Sites.
Social Media, Online Forums, and Advertisements. We may collect personal information from third-party social media platforms and sites, when you engage with our social media pages, online communities and forums, and when you mention us on your own or other social media pages, online communities, or forums, or when you interact with advertisements related to our services. Please note that online forums may be publicly accessible and other users may view information you post in the forums. We encourage you to exercise care in deciding what information and content you wish to disclose on the areas of the Sites that are accessible to the public.
Ariel Re. We may collect personal information from our subsidiaries, joint ventures, and other companies under our common control.
Service Providers. We may collect personal information from our service providers or other third parties who are authorized to act on our behalf.
Insurance Market Participants & Business Partners. We may collect personal information from insurance market participants and intermediaries, such as brokers, insurance agents and cover holders, insurers and reinsurers, claims adjusters and handlers, and third-party administrators, and other business partners and third parties who are authorized to act on our behalf.
Consumer Reporting and Credit Reference Agencies. We may collect personal information from consumer reporting agencies and credit reference agencies.
Government Entities and other publicly-available sources. We may collect personal information from government entities and databases, such as anti-fraud databases, sanction lists, and court judgments, and from other publicly-available sources.
Cookies and Similar Technologies. We may collect certain personal information using cookies and other technologies, such as web beacons, device IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising. When you visit the Sites, we may also automatically collect certain data about your device, including information about your web browser, IP address, and time zone. Additionally, as you browse the Sites, we may collect information about the individual web pages or products that you view, what websites or search terms referred you to the Sites, and information about how you interact with the Sites.
How We Use Personal Information
We may use personal information for a variety of different business purposes as set out in further detail in this Privacy Notice. In some cases, we may ask for your consent so that we may process your personal information. However, in certain circumstances, applicable data protection laws allow us to process your personal information without needing to obtain your consent. Subject to applicable law, the purposes for which we use and process personal information, and the legal basis for such processing, are set forth in this section below.
Performance of Contract. We may process personal information to perform our contractual obligations to you or to take steps in response to information or inquiries you may submit prior to entering into a contract with us. The following are some examples of some specific business purposes that fall under this category:
- Fulfil your request for services
- Assess and administer claims
- Contact you in relation to any issues with the services
- Provide a policy quote or for underwriting purposes
Compliance with Legal Obligations. We may process personal information in order to comply with our laws and legal obligations, law enforcement and regulatory requests, court orders, subpoenas, or pursuant to legal process.
Legitimate Interests. We may use personal information to operate and provide services, other than our contractual obligations to you, for our “legitimate interests”, except where our interests are overridden by the interests or fundamental rights and freedoms of the data subject. The following are some examples of some specific business purposes that fall under this category:
- To maintain the Sites and provide the services, including technical support
- To administer claims and policies, verify your age or identity, or to authenticate and authorize access to the Sites and the services
- To address and respond to your requests, inquiries, and complaints
- To protect the confidentiality or security of information
- To develop, provide, and improve the Sites and services, including to better tailor the features, performance, and support of the Sites and services, and for statistical and analytics purposes;
- For our direct marketing purposes
- To send surveys in connection with our services
- For fraud, loss, and other crime prevention purposes, to assist in the investigation of suspected illegal or wrongful activity, to protect and defend our rights and property, or to protect the rights and safety of third parties
- To comply with laws, regulators, court orders, or other legal obligations, or pursuant to legal process
Protection of Individuals’ Vital Interests. We may use personal information where we believe it is necessary to protect the vital interests of you or of another person. The following are some examples of some specific business purposes that fall under this category:
- fraud, loss, and other crime prevention purposes
- to assist in the investigation of suspected illegal or wrongful activity
- to protect and defend our rights and property, and the rights or safety of third parties
Consent. In some cases where we are not already authorized to process the personal information under applicable law, we may ask for your consent to process your personal information.
- Where we are not relying on our legitimate interests or another legal basis for processing personal information, we may ask for your consent to contact you by telephone, SMS, post and/or email about other offers, products, promotions, developments, or services which we think may be of interest to you and for other marketing purposes.
- Special Categories of Personal information. In the event we may need to collect data that would constitute special categories of personal information in order to provide a specific service to you, we will obtain your consent as required by law.
How We Share Personal Information
We may disclose the above referenced categories of personal information to following categories of third parties for a business or commercial purpose.
Service Providers. We may engage third-party service providers or vendors to perform certain business purposes on our behalf. We may disclose personal information to our service providers to maintain and operate the Sites and provide, improve, and personalize the Sites or Services, including to fulfil requests for the Services, to administer your account and policies, and for other technical and processing functions, such as sending e-mails on our behalf, fulfilling orders, and technical support. We may also share personal information to service providers or other third parties to detect, protect against, and respond to security incidents or other malicious, deceptive, illegal or fraudulent activity or other threats and for legal compliance purposes or pursuant to legal process. We use reasonable efforts do so with the appropriate contractual protection in place to ensure that personal information is protected and used only in accordance with this Privacy Notice.
Ariel Re Entities. We may share personal information with our subsidiaries, joint ventures, and other companies under our common control. Personal information shared with other Ariel Re entities will be done so under our intercompany data sharing agreement and will be used in accordance with the provisions of this Privacy Notice.
Insurance Market Participants & Business Partners. We may share personal information with insurance market participants and intermediaries, such as brokers, insurance agents and cover holders, insurers and reinsurers, claims adjusters and handlers, and third-party administrators, to offer, promote, and provide our Services, including, for example, for claims administration and underwriting purposes.
Marketing, Advertising, and Analytics Providers. We may share personal information with third-party providers for marketing, advertising, and analytics purposes.
Government Entities. We may share personal information with government entities and agencies, regulators, law enforcement, and other third parties, including to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or pursuant to legal process, and to establish or exercise our legal rights or for fraud- or crime-prevention purposes.
Professional Service Firms. We may share personal information with professional service firms in connection with our legal and regulatory obligations and to establish or exercise our rights and defend against claims, including, for example, auditors, law firms, and consultants.
Corporate Transactions. Subject to applicable law, we reserve the right to transfer some or all personal information in our possession to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets. If any such transaction occurs, the purchaser will be entitled to use and disclose the personal information collected by us in the same manner that we are able to, and the purchaser will assume the rights and obligations regarding personal information as described in this Privacy Notice.
A “cookie” is a small text file that a web server stores in browser software. A browser sends cookies to a server when the browser makes a connection to the server (for example, when requesting a web page from the same domain that created the cookie). The purpose of cookies is to remember the browser over time and distinguish one browser instance (or user) from all others. Some cookies and other technologies may serve to track personal information previously entered by a web user on the Site. Most browsers allow you to control cookies, including whether to accept them or not, and how to remove them. Cookies can remember login information, preferences, and similar information.
There are generally four categories of cookies: “Strictly Necessary,” “Performance,” “Functionality,” and “Targeting.” We may use all four categories of cookies on our Sites. You can find out more about each cookie category below.
- Strictly Necessary Cookies. These cookies are essential, as they enable you to move around our Sites and use features, such as accessing logged in or secure areas, and documenting certain system and browser preferences (including cookie based opt-out preferences).
- Functionality Cookies. These cookies allow us to remember how you have logged in to an account on our Sites. These cookies also allow us to tailor our Sites to provide enhanced features and content for you. The information these cookies collect may be anonymous, and they are not used to track your browsing activity on other sites or services.
- Targeting Cookies. Ariel Re and our authorized advertising partners may use these types of cookies to deliver advertising that is relevant to your interests. These cookies can remember that your device has visited a Site and may also be able to track your device’s browsing activity on other websites. This information may be shared with third-parties we have engaged with, such as advertisers and/or advertising networks to deliver the advertising, and to help measure the effectiveness of an advertising campaign.
Cookies, as well as other tracking technologies, such as HTML5 local storage, and Local Shared Objects (such as “Flash” cookies), and similar mechanisms, may record information such as a unique identifier, information you enter in a form, IP address, and other categories of data.
We may also use web beacons or “pixels,” and in certain circumstances may collect IP address, screen resolution and browser software and operating system types, clickstream patterns, dates and times that our site is accessed, and other categories of data.
If you want to block the use and saving of cookies from our Sites on to the computer’s hard drive, you should take the necessary steps within your web browser’s settings to block all cookies from the Sites and external serving vendors, or use the cookie control system, if available upon first visit, which is available here. Please note that if you choose to erase or block your cookies, certain parts of our Sites may not function correctly. For information on how to disable cookies, refer to your browser’s documentation.
Interest-based advertising is advertising that is targeted to you based on your web browsing and app usage over time and across websites or apps. You have the option to restrict the use of information for interest-based advertising and to opt-out of receiving interest-based ads.
The opt-outs for interest-based advertising require that strictly necessary cookies are not blocked by the settings in your web browser. We support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance in the U.S., the Canadian Digital Advertising Alliance in Canada, and the European Digital Advertising Alliance in the EU. If you live in the United States, Canada, or the European Union, you can visit Ad Choices (US), Your Ad Choices (Canada), or Your Online Choices (EU) to find a convenient place to opt-out of interest-based advertising with participating entities for each region. These websites also provide detailed information about how interest-based advertising works. Opting out does not mean that you will no longer receive advertising from us, or when you use the Internet. It just means that the data collected from our website will not be used for interest-based advertising and that the advertising you see displayed on websites will not be customized to your interests.
Your Rights Regarding Your Personal Information
This section describes the rights you have with respect to your personal information as well as how to exercise those rights.
Description of Rights
Depending on your jurisdiction and on our specific collection and use of your personal information, you may have certain rights under applicable law. Where we are processing your personal information, subject to applicable law, you may have the right to:
- Request access to or a copy of your personal information. You have the right to know what personal information we have collected about your, and/or request access to or copy of the personal information we collect, use, or disclose.
- Request to correct or modify your personal information. You have the right to request that your personal information be corrected, updated, or modified.
- Request deletion of your personal information. You have the right to request that we delete the personal information that we have collected about you.
- Request to opt-out of the sale of your personal information. We do not sell your personal information. For more information see the California Privacy Section below.
- Request restriction of processing. You have the right to request that we restrict processing of your personal information in certain circumstances, such as where you believe that the personal information we hold about you is inaccurate, or our processing is unlawful.
- Object to processing. In certain circumstances, you may have the right to request that we stop processing your personal information, such as a request to stop sending you direct marketing communications. In most cases, we need to process some of your personal information in order to fulfil our contractual obligations to you and for our legitimate interests. Where the basis of processing is legitimate interests, you have a right to object to the processing of your personal information. Please note that, subject to applicable law, we may continue to process your personal information even where you object if there are compelling legitimate grounds for processing that override your interests and rights, or where processing is necessary to establish, exercise, or defend legal claims. To opt-out of direct marketing communications, please see the instructions below.
- Data portability. In certain circumstances, you may have the right to receive the personal information concerning you that you provided to us or to request that we transmit your personal information to another data controller.
- Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.
- Lodge a Complaint. You have the right to lodge a complaint with a supervisory authority.
Depending on your jurisdiction of residence, you may be entitled by law to exercise the above-described rights. For individuals whose jurisdiction does not afford these rights, we may offer them voluntarily and at our discretion, and we reserve the right to limit or revoke any such rights at any time, as may be permitted by applicable laws.
How to Exercise Your Rights.
To exercise any of your applicable rights, please contact us by mail at the address listed below.
Existing customers may also access and update certain personal information within their account. You may also authorize someone to exercise the above rights on your behalf. You may also exercise the above rights on behalf of your minor child, if applicable.
As permitted by law, certain data elements may not be subject to access, modification, portability, restriction, and/or deletion. Furthermore, where permissible, we may charge for this service. To protect your privacy and security, we may take steps to verify your identity in order to respond to your request.
We will respond to authorized and verified requests as soon as practicable and as required by law. The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under the law. Under certain circumstances, we may be unable to implement your request, pursuant to applicable law. We will advise you of any reason for denying or restricting a request to the extent permitted by law.
Withdrawing Consent. Where consent is the basis of processing, you may at any time withdraw the consent you provided for the processing of your personal information for the purposes set forth in this Privacy Notice by contacting us at the address listed below, if we are not required by applicable law or professional standards to retain such information. Please note that if you do not provide consent, if you withdraw your consent or object to processing, or if you choose not to provide certain personal information, we may be unable to provide some or all of the services to you.
Marketing Opt-Out. If you would like to stop receiving newsletters or other marketing or promotional messages, notifications, or updates, you may do so by following the unsubscribe instructions that appear in these e-mail communications, or you may contact us as set forth below to opt-out of direct marketing, if applicable. Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us, including legal notices.
Other Important Privacy Information
Do Not Track
Please note that our Sites do not alter their behavior or use practices when we receive a “Do Not Track” signal from browser software. You can learn more about Do Not Track here: https://allaboutdnt.com/
Social Network Widgets
Our Sites may include social network sharing widgets that may provide information to their associated social networks or third-parties about your interactions with our web pages that you visit, even if you do not click on or otherwise interact with the plug-in or widget. Information is transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where widget appears. If you use social network tools or visit social networking sites, we encourage you to read their privacy disclosures to learn what information they collect, use, and share.
Links To Other Sites
Our Sites may contain links or otherwise provide access to another website, mobile application, or Internet location (collectively “Third-Party Sites”). Please note that we have no control over and are not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Notice does not apply to Third-Party Sites. We encourage you to read the privacy policies of any Third-Party Site with which you choose to interact.
Information from Children
We do not target or knowingly collect information from children. If you become aware that a child has provided us with personal information, please contact us at the address below. If we become aware that a child has provided us with personal information, we will take steps to remove the data in accordance with applicable law.
Transfer of Data to the U.S.
Please note that if you are visiting the Sites from outside of the United States, your information may be transferred to, stored, and/or processed in the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. If you are located outside of the United States, the transfer of personal information may be necessary to provide you with the requested information, products, and services and/or to perform any requested transaction.
We will retain your personal information for as long as is necessary to fulfil the purposes for which we obtained the personal information, including to provide the services, or for such longer period as may be required or permitted by applicable law. We will also retain your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and policies. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the purposes for processing your personal information and associated legal bases; (iii) the existence of a legal obligation as to the retention period; (iv) our contractual obligations; and (v) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).
We implement technical and organizational security measures designed to secure and protect personal information. Please note, however, we cannot fully eliminate security risks associated with the storage and transmission of personal information.
California Privacy Rights
California Consumer Privacy Act (CCPA)
The following provision supplements our Privacy Notice and applies to you if you are a California consumer who uses our Sites or Services.
Personal Information We Collect. In operating our Sites or providing our Services, we may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.
Categories of Personal Information. We collect the categories of personal information from you as described above in this Privacy Notice.
Categories of Sources from Which Personal Information is Collected. We collect personal information from you from the categories of sources described above in this Privacy Notice.
Business or Commercial Purposes for Collecting Personal Information. We may use the personal information we collect from you for the business purposes describe above in this Privacy Notice. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing additional notice.
Disclosure of Personal Information for a Business Purpose. We may disclose personal information to the third parties or others as described above in this Privacy Notice, for any of the business purposes described above in this Privacy Notice. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Sale of Personal Information. We do not disclose your personal information in a manner that would be considered a sale as defined by the CCPA or other applicable laws.
Right to Know. You have the right to request that we disclose certain information about our collection and use of your personal information over the previous 12 months. Once we receive and confirm a request, we will disclose:
- The specific pieces of personal information we have collected
- The categories of personal information we collected
- The categories of sources from which the personal information we have collected
- Our business or commercial purpose for collecting or selling that personal information
- The categories of third parties with whom we share that personal information
Right to Delete. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may not be able to honor your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise our free speech or ensure the rights of other consumers to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the business’ deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Right to Know and Right to Delete. To exercise the specific rights described above, please submit your request to the mailing address below.
Response Timing and Format. Where possible, we will respond to a verified California consumer request within forty-five (45) days of its receipt; however, if we require more time, we will inform you of the reason and extension period. Any disclosures we provide under the CCPA will only cover the 12-month period preceding the verified California consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable California consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
- Provide you a different level or quality of goods or services
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or service
California Shine the Light.
Under Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information (as defined by California law) the business shares with third parties for those third parties’ direct marketing purposes, and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by mail at the address below with “Request for California Privacy Information” in the subject line and in the body of your message. Please be sure to provide in the request enough information to properly identify you and/or the members of your family.
Updates to this Privacy Notice
This Privacy Notice is reviewed and updated periodically. The most recent version of the Privacy Notice is reflected by the version date located at the bottom of this page. We encourage you to review this Privacy Notice often to stay informed of how we may process your information.
For more information or if you have questions or concerns about our privacy practices, please contact us by mail using the details provided below:
Global Data Protection Officer
29 Richmond Road
Data Protection Officer
14 – 16 Dowgate Hill
London, EC4R 2SU
Last Updated: 6/9/2021