CCPA Privacy Notice

We are Vave, part of Canopius Group Limited which has its head office in Jersey and operates in the UK, Netherlands, Bermuda, Australia, USA and Singapore. The Canopius group is made up of a number of trading companies. For more information, please visit our website at www.canopius.com.

We act as the underwriters of your insurance policy. To find out more about how we might use your information within the London Insurance Market, please visit www.londonmarketgroup.co.uk/gdpr.

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

In particular, we may have collected the following categories of personal information from consumers within the last twelve (12) months:

• Category A – Identifiers
  • Examples: real name, postal address, IP address, email address, account name, social security number, driver’s license number, passport number.

• Category B – Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Examples: Name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, health insurance information, bank account number, credit card number, debit card number, or any other financial information, physical illness, mental illness or disabilities.

• Category C – Protected classification characteristics under California or federal law
  • Examples: sex/gender, marital status, medical conditions, military or veteran status, national origin, citizenship status, disability, AIDS/HIV status, requests for leave for own illness, being aged 40 and above;

• Category D – Commercial information
  • Examples: Records of personal property, products or services purchased, obtained or considered.

• Category F – Internet or other similar network activity
  • Examples: Access history and information on your interaction with our website.

• Category I – Professional or employment-related information
  • Examples: Occupation, employer information.

• Category J – Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
  • Examples: Education level, school attended.

• Category K – Inferences drawn from other personal information
  • Examples: Consumer characteristics

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from third parties.
  • For example, insurance brokers, other insurance companies, credit-reference agencies, government agencies, anti-fraud databases, sanctions lists, court judgments, other claims parties, legal advisors, witnesses and claims handlers.
• Directly from you, your family members or an appointed representative.
• Directly and indirectly from you when using our Services or visiting our website.
  • For example, usage details collected automatically in the course of your interaction with our website.

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To provide a quotation and set up your policy
  • To set you up as a client, including to carry out fraud, credit, anti-money-laundering and sanctions checks
  • To evaluate the risks you want to cover and match you to the appropriate policy and premium

• To manage your policy
  • To collect and refund your premiums (if this is necessary)
  • To provide general client care, including communicating with you about managing your policy and making any changes you ask for
  • To send you your policy documents

• To process claims
  • To manage insurance claims
  • To defend or prosecute legal claims
  • To investigate and prosecute cases of fraud

• To renew your policy
  • To contact you in order to renew your insurance policy

• For general insurance purposes
  • To assess general risks and provide insurance
  • To meet the obligations we have by law and under any regulations that apply
  • To transfer books of business if we are selling or reorganising all or part of our company

• For profiling purposes
  • When calculating insurance premiums, we may compare your personal information against industry averages and use it to update the industry averages

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 you with notice.

We may disclose your personal information to a third party for a business purpose. 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.

In the preceding twelve (12) months, we have disclosed the categories of personal information mentioned in “What information we collect about you” for a business purpose:

We disclose your personal information for a business purpose to the following categories of third parties:

• third parties who help deliver products and services on our behalf, such as payment-card providers, claims handlers and data-storage providers;
• other companies in the Canopius group to manage your policy and any related claims;
• national anti-fraud databases;
• auditors, regulators and law enforcement agencies if we must do this by law or under any regulations that apply; and
• any third party that takes over all or some of our assets, in which case we may transfer your personal information to the third party.

In the preceding twelve (12) months, we have not sold any personal information.

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.

Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights

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 verifiable consumer request, we will delete (and direct our relevant service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us, or our service providers, 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.
• Exercise free speech, ensure the right of another consumer 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 ).
• 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 information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Use the information for internal purposes 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 Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at privacy@canopius.com.

Only you or a person registered with the California Secretary of State, that you authorise to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

The verifiable consumer request must:

• Provide sufficient information to allow us to take reasonable steps to verify that you are the person about whom we collected personal information or an authorised representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavour to respond to a verifiable consumer request within 45 days of its receipt.

If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable 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 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 use of our Services.
• Provide you a different level or quality of Services.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. You are responsible for periodically visiting the Canopius website and this Privacy Notice to check for any changes.

This Privacy Notice was last updated on 17^th September 2020.

Contact Information

If you have any questions or comments about this Privacy Notice, or to exercise any of your privacy rights, you may contact us via email at privacy@canopius.com

If you have any questions or comments about this Privacy Notice, or to exercise any of your privacy rights, you may contact us via email at privacy@canopius.com

We reserve the right to amend this Privacy Notice at our discretion and at any time. You are responsible for periodically visiting the Canopius website and this Privacy Notice to check for any changes.

This Privacy Notice was last updated on 27^th September 2021.