EFFECTIVE DATE: February 26, 2021
SiriusPoint Ltd. is a Bermuda-domiciled holding company whose operating companies offer reinsurance and insurance products for a rich variety of classes and serve clients and brokers throughout the world.
By visiting the Site, or using any of our Services, you acknowledge, and if you are in Canada, Singapore or the US you agree, that your personal information will be handled as described in this Policy. If you are in Canada, Singapore or the US, your use of our Site or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Sirius Terms of Service are incorporated by reference into this Policy. You have the right to complain to the relevant privacy commissioner and have their dispute addressed by the Commissioner.
The Information We Collect About You
We collect information about you directly from you and from third parties, and automatically through your use of our Site or Services. Where required by applicable law, we will obtain your consent upon or before collecting, disclosing and otherwise using your personal information.
Information We Collect Directly From You. The information we collect from you depends on how you use our Site and Services. If you choose to contact us through the Site, we will collect your name, company address, your business contact information, and your communications with us.
Information We Collect From Other Entities. Like many companies, we are active on social media platforms. We may collect information about you when you interact with us on social media platforms. For example, if you follow our social media accounts or if you message us or tag us in a social network post, we will collect information about your message or the post we are tagged in. We do not collect personal information from other publicly-available sources.
Information We Collect Automatically. We automatically collect information about your use of our Site and Apps through cookies, web beacons, and other technologies. The information we automatically collect includes: your domain name; your browser type and operating system; web pages you view on the Site; links you click on the Site; your IP address; the length of time you visit our Site; and the referring URL, or the webpage that led you to our Site. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
Why We Use Your Information
We use your information, including your personal information, where we have a legitimate business interest to do so follows:
- Service Provisioning/Transactional Purposes: We use your personal information to respond to your requests. If you do not provide the requested information, we may not be able to communicate with you about your use of our Site and Services, to respond to your inquiries, or for other customer service purposes.
- Personalizing our Communications: We use your personal information to develop our business and our relationship with you, to tailor the content and information that we may send or display to you, to provide personalized help and instructions, and to otherwise personalize your experiences while visiting the Site or using the Services.
- Marketing Communications: With your consent where required under applicable law, we may use your information:
- To send you marketing communications about our products and services.
- To send you news and newsletters.
- To send you marketing communications about products and services of our affiliated entities
Where applicable law requires us to obtain your consent prior to sending you any marketing communications, we will do so. You may withdraw your consent easily at any time. See, What Choices Do I Have Regarding Promotional Emails? for more details about how to opt-out of marketing e-mail communications. To opt-out of other communications, see Contact Us.
- Advertising: In accordance with applicable laws, we may use your information as follows:
- With respect to information collected on our Sites, to assist us in determining relevant advertising content and media.
- To evaluate the success of our advertising campaigns (including our online targeted advertising and offline promotional campaigns).
See also the Ad Networks section discussed below.
- Site and Product Improvement/Research: We may use your information as follows:
- To better understand how users access and use our Sites and Services, both on an aggregated and individualized basis. For example, we will evaluate which features of our Sites and Services are more (or least) used by users, and we will use this information to update or add new features to our Sites and Services. We may also use feedback provided by users to update our Services or develop new products and services.
- To administer surveys and questionnaires, such as for market research or customer satisfaction purposes.
- To create aggregated, anonymized, pseudonymized or de-identified data sets. We may use such data sets for research, product improvement and development, marketing, advertising, trend analysis and other purposes.
- Legal Purposes: We strive to conduct our business in compliance with the laws of Bermuda, where we are incorporated and organized, and other applicable laws, as well as with our internal policies, in order to protect our reputation and the integrity of our business. If you do not provide requested information that is required by applicable law, we may not be able to respond to your request or perform our obligations to you. We may use your information:
- To comply with legal obligations and act in accordance with legal authorizations, as part of our general business operations, and for other business administration purposes, including to comply with our legal and regulatory requirements, authenticating your identity, maintaining customer records, to monitor your compliance with any of your or your organization’s agreements with us, to collect debts owed to us, to safeguard our business interests, and to manage or transfer our assets or liabilities, for example in the case of an acquisition, disposition, amalgamation or merger, as described below under “Sharing your Information/Business Transfers.
- For other purposes we may inform you about from time to time. Where required by applicable laws, and regulations, we will obtain your consent if we wish to use your personal information for purposes requiring such consent.
Sharing Your Information
We may share your information, including personal information, as follows:
- Service Providers. We disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf. These service providers include hosting services and marketing agencies.
- Affiliates. We disclose the information we collect from you to our affiliates or subsidiaries. For example, we may direct your inquiries to an affiliate who is best able to respond to your inquiry.
- Managing Agents and Underwriters. We work with managing agents and managing underwriters in certain markets to underwrite coverage and manage claims. We may share your information and communications with us with the managing agent or managing underwriter in your location to respond to your inquiry, for relationship management purposes, and to manage your insurance policies and claims.
We also use and share your personal information for the following purposes:
- Business Transfers. If (i) we or our affiliates are or may be acquired by, amalgamated or merged with, financed by, or are invested in by another company, or (ii) if any of our assets are or transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company or company group. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.
- In Response to Legal Process. We may disclose your information to comply with the law, a judicial proceeding, court order, a law enforcement request, or other legal process, such as in response to a subpoena.
- To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our agreement(s) with you or this Policy, or as evidence in litigation in which we are involved or may become involved.
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to allow us to track your activities at our Site and when using Services. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a Site or Services session. This allows us to process your online activities as you move through our Site and Services.
- Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your device’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and Services to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Our Sites and Services may contain links to non-affiliated websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those non-affiliated websites. We are not responsible for the information practices of such non-affiliated websites.
Security of Personal Information
We have implemented appropriate safeguards to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee absolute security.
What Choices Do I Have Regarding Promotional Emails?
With your consent where required by applicable law, we will send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. We will process optout requests in accordance with applicable law. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services (including the Services) you have requested or received from us.
Our Services are not designed for persons under 18. If we discover that someone under 18 has provided us with personal information, we will delete such information from our systems.
If you have questions about our use of your personal information or this Policy, or if you would like to make a complaint, please contact us at [email protected].
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site. Where required by applicable law, we will obtain your consent to such changes before implementing them.
Additional Information for Individuals in Bermuda
In this section, we provide additional information to individuals in Bermuda as required under PIPA. An individual has certain rights for limiting the use of, and for accessing, rectifying, blocking, erasing and destroying, their personal information which we use in Bermuda. In general, and subject to certain limited exceptions, the options for exercising such rights are:
- Accessing – You may make a written request for access to (i) personal information about you in our custody or under our control; (ii) the purposes for which your personal information has been and is being used by us; and (iii) the names of the persons or types of persons to whom and circumstances in which your personal information has been and is being disclosed. On receipt of your request, we shall provide you with such access, unless we are entitled or required not to provide such access. In certain circumstances, the information we provide in response to your access request may be redacted. If we are unable to comply with your access request, we will inform you of such.
- Rectifying – You may make a written request to us to correct an error or omission in any of your personal information which is under our control. On receipt of such request and the correct information, we shall, in most cases, update the personal information we use.
- Blocking – You may make a written request that we cease, or not begin, using your personal information for the purposes of advertising, marketing or public relations. On receipt of such request, we shall cease, or not begin, using the personal information for the purposes of advertising, marketing or public relations. Similarly, you may request that we cease, or not begin, using your personal information where the use of that personal information is causing or is likely to cause substantial damage or substantial distress to you or to another individual. On receipt of such request, we shall either cease, or not begin, using the personal information that you have identified in your request, or provide you with written reasons as to why the use of such personal information is justified.
- Erasing and destroying – You may a written request that we erase or destroy personal information about you where that personal information is no longer relevant for the purposes of its use. On receipt of such request, we shall erase or destroy the personal information that you have identified in your request, or provide you with written reasons as to why the use of such personal information is justified.
If you make a request to us in respect of your personal information which we use in Bermuda and we do not comply with your request for whatever reason, you have a right to ask the Bermuda Privacy Commissioner for a review of our decision, action or failure to act. Further, where you believe an obligation has not been performed, a right not observed or personal information used not in compliance with PIPA, then you can initiate a complaint against us with the Bermuda Privacy Commissioner, though we kindly ask that you provide us with the opportunity to first address your concerns.
Additional Information for Individuals in Canada
Additional Information for Residents of Singapore
In this section, we provide additional information to Singapore residents about how we handle their personal information.
If you are a resident in Singapore and you have any complaints or queries or wish to exercise your rights in relation to your personal information, please contact us at the following:
- Email address: [email protected]
- Telephone number: +65 6435 0052
Your rights – Rights to access and correct your personal information; other rights
You have the right to request access to the personal information that we hold about you and to obtain information about the ways in which such personal information may have been used or disclosed by us in the year before your request. You also have the right to request that we correct any errors or omissions in your personal information. In certain situations, you may also have a right of data portability, where you may request the transfer of your personal data which is in our possession or under our control to another organization (to the extent that this is permitted under applicable law).
We reserve the right to charge a reasonable fee where permitted by law. In the event that exercising your rights generates expenses, we will clearly state the basis for the expenses incurred.
We may ask you for additional personal information to verify your identity or for security purposes before disclosing the personal information requested to you. We also reserve the right to refuse your requests in accordance with applicable law.
We will generally respond to requests as soon as possible and in any event within thirty days. However, if a response will require more than the standard amount of time, we will inform you of the additional amount of time required to process your request.
Additional Information for Califronia Residents
In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.
Categories of Personal Information Under the CCPA (Last Updated: February 26, 2021) While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about consumers in the prior 12 months (from the Last Updated date above).
Categories and Sources of Personal Information Collected. The table below identifies, generally, the categories of personal information (as defined by the CCPA), we have collected about California residents. For more information about the business or commercial purposes for which we collect and use personal information, please see the Why We Use Your Information section above.
Categories of Personal Information & Description
Identifiers Includes direct identifiers, such as name, email address, phone number, address and other contact information. Usage Data Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, and our marketingemails and online ads. Inferences Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to customers, so that we can better reach them with relevant offers.
Sources of Personal Information. As further described in the Information We Collect About You section above, we may collect personal information from the following sources:
Disclosures of Personal Information. In the table below, we identify the categories of personal information we have disclosed for a business purpose or that we have “sold” as defined by the CCPA, as well as the categories of third parties to whom we may disclose or sell such personal information. For more information about the business and commercial purposes for which we may disclose and sell (as defined under the CCPA) personal information, please see the Sharing Your Information section above.
Categories of Personal Information Do We Disclose for a Business Purpose? Do We Sell? Categories of Third Parties to Whom Information is Sold or Disclosed Identifiers YES YES • service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers Usage Data YES YES • service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers YES YES • service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers
California Residents’ Rights
CCPA Rights. In general, California residents have the following rights with respect to their personal information:
- Do-not-sell (opt-out): California residents have the right to opt-out of our “Sale” of their personal information. California residents may opt out of sales of their personal information by us, by submitting a request to our privacy officer.
- Right of deletion: California residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.
- Right to know: with respect to the personal information we have collected about them in the prior 12 months, California residents have the right to require that we disclose the following to them (up to twice per year and subject to certain exemptions):
- categories of personal information collected;
- categories of sources of personal information;
- categories of personal information about them we have disclosed for a business purpose or sold;
- categories of third parties to whom we have sold or disclosed for a business purpose their personal information;
- the business or commercial purposes for collecting or selling personal information; and
- a copy of the specific pieces of personal information we have collected about them.
- Right to non-discrimination: California residents have the right not to be subject to discriminatory treatment for exercising their rights under the CCPA. Submitting CCPA Requests. California residents may submit CCPA requests to opt out of sales, requests to know (access) and requests to delete their personal information through one of the following methods:
- Online at [email protected]
- By phone at 1.888.313.4360
In addition, California residents may opt out of “sales” of their personal information by us by to opt out of “sales” via third party tags and cookies on our Sites, or by contacting [email protected].
When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must complete all required fields on our webform (or otherwise provide us with this information via the above toll-free number). In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual [by contacting us at [email protected]; authorized agents will be required to provide proof of their authorization and we may also require that the relevant California
resident directly verifies their identity and the authority of the authorized agent].
Your Privacy Rights Under California Shine the Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code §1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us at [email protected], and include in your request a current California address and your attestation that you are a California resident.
For more information about our privacy practices, you may contact us as set forth in the Contact Us section above.