Privacy Notice for Maiden Life & General

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For Maiden Life & General it is extremely important that personal information should be protected. If we are to offer you our insurance policies or any of our other services we will use your personal data in the way which is set out below.

In this privacy notice you can read about how we gather and use your personal data. You will also be given information about the rights you have in your dealings with us and how you can use them.

We would advise you to read through this privacy notice carefully so you understand how and why we process your personal data before you begin using any of our services.

The terms ‘personal data’ and ‘personal information’ mean any information relating to an identified or identifiable natural person, i.e. you as an individual.

We (the UK branches of Maiden Life Försäkrings AB and Maiden General Försäkrings AB), are each registered with the Information Commissioner’s Office (the “ICO”) as controllers of personal data – which means that we decide the means and purposes for which personal data is processed. Our respective registration numbers with the ICO are ZB363709 and ZB363719.

In this policy these companies are jointly referred to as Maiden Life & General (or we, us etc.). We are each independently responsible for processing your personal data as described in this notice.

What personal information will we collect from you?

In your communication with us you may submit personal information about yourself to us in a variety of different ways. For example, when you take out a policy with us, contact us, or register a claim, or if you use another of our services where you provide personal information.

The following are the types of personal information about yourself which we will process if you submit them to us:

Personal and contact information — name, address, date of birth, national insurance number, passport number, e-mail address, mobile telephone number.
Information about your health, employment and/or vulnerability — whether you are in full-time employment, your occupation and how long you have been employed for, whether you are a vulnerable individual (due to health reasons or, for instance, other circumstances such as financial hardship or life events).
Information relating to claims for indemnification — where relevant, information about illness and other events which may create an entitlement under the policy.
Payment Information — bank account numbers.

All this personal information is necessary for us to process so we can conclude and implement our agreement with you. If you do not submit this personal information to us we may be prevented from offering you a policy or meeting your claim. We may also process other personal information about you:

Technical information in relation to usage of our website — derived from use of cookies: IP address, language setting, time zone, operating system, geographical location, response time for pages, download errors, notices.
Information about your contacts with us — how you use our services, including information about how you found us.

We may also gather personal information about you from other sources, as follows:
Financial information — information about the loans which you insure with us. Such information is gathered from the lenders and/or the insurance intermediary who arranged the policy.
Information about customer/member relations — that you are a customer or member of a specific company or organisation which has a group policy with Maiden Life & General, to establish that you are entitled to take out a specific policy. Such information is gathered from the insurance intermediary or from the party which has a group policy with us.

Why do we use your personal information and what do we use it for?

The personal information which you submit to us and which we otherwise gather about you is necessary so we can assess if you can have a policy with us or not, identify the premiums and conditions we can offer you and conclude and manage the insurance policy with you. Your personal information is primarily used for those purposes, but we may also process your personal information for other purposes as set out below.

Purpose for which your personal information will be processed (i.e. why we process your personal information)	Legal basis for processing your personal information (i.e. the basis under data protection laws on which process your personal information)
To manage your relationship with us (including confirmation of your identity and checking that your personal and contact details are correct) and your payment details, e.g. so we can fulfil our obligations to you as an insured and can provide the services which you require of us and provide information about them.	To conclude and implement a policy with you – i.e. it is necessary for the performance of a contract to which you are party (or in order to take steps at your request prior to entering into a contract) In addition, where we process information about your health, the lawful basis under data protection laws which we rely on is that it is necessary for the establishment, exercise or defence of legal claims, or where we do so in relation to our consumer duty requirements our lawful basis is that it is necessary for reasons of substantial public interest.
To manage our services and internal activities, including customer analysis, marketing analysis, trouble shooting, data analysis, testing, research and statistical purposes.	Our legitimate interests in developing our activities and services, which are not overridden by your own interests, rights or fundamental freedoms because this helps us provide a better service to you
To prevent any abuse of our services, including fraud, to manage risk and carry out our risk analysis.	To comply with the relevant legislation and our legitimate interest in identifying, asserting and pursuing legitimate claims
To ensure that content is presented clearly for you on-line (with the help, among other things, of cookies).	Consent (to the extent that we seek and obtain your consent) and/or our legitimate interest in the smooth and effective operation of the service (see also our cookie policy) which is not overridden by your own interests, rights or fundamental freedoms because it has a positive effect on how easy it is for you to use our website
To develop and improve our services with a view, for example, to generating new products and create new business opportunities.	Our legitimate interest in developing our activities, our services and the range of services we offer, which is not overridden by your own interests, rights or fundamental freedoms because this helps us provide a better and more appropriate service to you
To comply with the relevant legislation including legislation on measures to counter money-laundering (including establishing whether you are, or are connected to, a ‘politically exposed person’ – see further details below in this notice under ‘Politically exposed persons’ header), our consumer duty obligations, accountancy law, tax law and rules on the capital adequacy ratio requirements.	To comply with our legal obligations

We shall also use your personal information in our communications with you. Sometimes we carry out customer satisfaction surveys of services, for example after you have been in contact with our Customer Services. That communication may take place via electronic communication channels or by telephone. Our lawful basis for processing your personal information for these purposes is that it is in our legitimate interests of improving our services, and is not overridden by your own interests, rights and fundamental freedoms because it doesn’t have a negative impact on your policy with us and you do not have to take part in the survey if you do not wish to do so. If you do not want us to communicate with you in that way you can contact us by sending an e-mail to dataprotection@maideniis.com or unsubscribing from the e-mails we send to you.

Your rights

Your rights	What does this mean?
Right of access	You are entitled to access the personal information we have about you and you can request a copy of it from us. You can usually request a copy at no charge, but if you require multiple copies or ask repeatedly we may charge a fee.
Right to correction	It is important that we should have correct information about you and we advise you to let us know if any of your personal information is out of date or otherwise incorrect, for example if you have changed your name or moved. You can correct information about yourself which is incorrect or incomplete at any time.
Right to deletion	If your personal information is no longer needed for the purpose for which they were gathered, you are entitled to require that they be deleted. That right to have details deleted is known, amongst other things, as the ‘right to be forgotten’. In some cases we may be under a legal obligation which prevents us from deleting your personal information immediately. That may involve, for example, obligations under legislation on accountancy, tax or money-laundering, or the legislation and regulations which apply to insurance companies. In such cases we ensure that access to your personal information is restricted in such a way that it is only used to allow us to fulfil our legal obligations and our contractual obligations to you.
Right to restrict	From the moment when you request that we correct your personal information or object to its processing and until we have successfully examined the matter or confirm that your personal information is correct (or have changed them in accordance with your instructions) you will be entitled to restricted processing. That means that (with the exception of storage) we shall only be entitled to process your personal information with your consent, if it is necessary with reference to legal claims, in order to protect someone else’s rights or there is a significant public interest in processing it. You are also entitled to request that we restrict the processing of your personal information if the processing is unlawful but you do not want us to delete the personal information.
Right to object	You are entitled to object to direct marketing at any time. If you should otherwise consider that we have no right to process your personal information , you are also entitled to object to our processing your data. In that event we only have the right to continue processing if we can show compelling reasons which outweigh your own interests, rights and freedoms. However, we are at all times entitled to process your personal information if it is necessary to establish, exert or defend legitimate claims.
Right of data portability	You are entitled to have the personal information which you have submitted to us, and which we process on the basis of your consent or in order to conclude and/or implement our contract with you, disclosed to you or another party at your direction in a structured and machine-readable format.
Right to withdraw consent	If we process your personal information based on your consent, you have the right to withdraw your consent at any time. The withdrawal will not have any retrospective effect, and will not therefore have any impact on processing which has already taken place.
Right to complain	If you are not satisfied with the way in which we handle your personal details you can contact our data protection officer and we shall look into your complaint: dataprotection@maideniis.com If you are not satisfied with our answer or consider that we are processing your personal details in an illegitimate or unlawful way you may lodge a complaint with the UK Information Commissioner’s Office https://ico.org.uk/global/contact-us/

Whom do we share your details with?

To work effectively we may need to share your personal information with third parties: within our corporate group of companies and with our contractors, as described below. Some of the third parties process your personal information on our behalf as our processors (in which case we remain responsible for their processing of your personal information) and others are controllers of personal information in their own right (in which case they are responsible for the processing of your personal information).

It should be noted that we shall never sell your information to a third party without your express approval.

We shall share your details with contractors and sub-contractors (including companies within the Maiden Life & General Group) in order to implement our contract with you and for other purposes which will be apparent from this privacy notice. Such contractors include suppliers of insurance administration, claim adjustment, and IT contractors. If the contractor/sub-contractor processes your personal data on behalf of Maiden Life & General as our processor, Maiden Life & General will ensure that the contractor/sub-contractor has undertaken to process your details in accordance with Maiden Life & General’s data protection policy and other regulations.

We shall also share your details with the insurance intermediary you have contact with when taking out an insurance policy and with a reinsurance company which reinsures our policies. Some of these re-insurance companies are within the Maiden Life & General Group. This applies to any information which we need to allow the insurance intermediary/reinsurance company to manage your insurance policy and our own reinsurance policy and to fulfil their undertakings in accordance with the law, the Regulation and the rules of our regulators. These entities will process your personal information as controllers in their own right, and we disclose your personal information to them in order to perform our contract with you and/or for the legitimate interests of enabling your policy to be reinsured (which are not overridden by your own interests, rights and fundamental freedoms because this enables us to provide a better service to you).

We shall also release your details to the authorities, including the Police, the Tax Service, and other authorities if we are obliged to do by law or with your consent (to the extent that we seek to obtain your consent). One example of when the law obliges us to release information is in the case of measures designed to combat money laundering and funding for terrorism. The information which is shared is subject to the authority’s data protection policy as the authority is a controller of your personal information in its own right.

Lastly, Maiden Life & General will share your details with third parties in connection with the purchase or sale of business or assets. Your details may then be shared with prospective vendors or purchasers as such sharing is the legitimate interests of the purchaser of business/assets to continue the relevant business following their acquisition, and in our legitimate interests to be able to sell our business or assets to a purchaser, these interests are not overridden by your own interests, rights and fundamental freedoms because it enables the purchaser to continue to provide you with services). In the event that Maiden Life & General or a significant part of Maiden Life & General’s business or assets should be acquired by a third party your details may then be shared with it.

Privacy Notice for Maiden Life & General

What personal information will we collect from you?

Why do we use your personal information and what do we use it for?

Your rights

Whom do we share your details with?

Where do we process your details?

How long shall we keep your information?

Cookies and similar technology

Politically exposed persons

Contacting us