Data Privacy Policy UK - CargoCorp UW

DATA PRIVACY POLICY UK AND EUROPE

1. INTRODUCTION

In compliance with legal requirements under EU General Data Protection Regulation (“EU GDPR”) and the UK GDPR, this policy is implemented for the use of data we collect from officers, employees, customers, claimants, Third Party service providers that are part of the CargoCorp UW database, its parent company, branches, subsidiaries, and other companies of the business group as Data controller, hereinafter CargoCorp UW.

2. OBJECTIVE AND SCOPE

Set the criteria for collection, storage, use, circulation and disposal and other treatments that will be granted to the personal data handled by CargoCorp UW in its condition as Data controller. This policy applies to all personal data logged in CargoCorp UW’s databases.

3. DEFINITIONS

CONSENT: It is the specific and free consent that data owner gives to CargoCorp UW for the handling or processing of their data, prior to the use.
SENSITIVE DATA: It is understood as the data that affects the privacy of the data owner or that improper use may generate discrimination.
DATA CONTROLLER: CargoCorp UW as Data controller for the database will decide on it and / or on the use of the data provided by the data owner, in accordance with Law 1581 of 2012 and its regulatory decrees.
DATA OWNER: Natural or legal person whose data is subject to use by CargoCorp UW
USE: It consists in the collection, storage, use, circulation, or disposal of non-sensitive data that CargoCorp UW uses for its commercial activity

4. DATA CONTROLLER CONTACT INFORMATION

CargoCorp UW Inc. is a US company with offices located in London and Hamburg.

London Office: CargoCorp UK Ltd. is an incorporated commercial company located in Floor 30th 122 Leadenhall St, London EC3V 4AB.
- Phone: +44 0 7311201683
Hamburg Office: CargoCorp Underwriters (EU) GmbH Hohe Bleichen 8, 20354 Hamburg
- Phone: +49 176 32352295

Web Site: www.cargocorpuw.com

Contact information of the Data Protection Officer: compliance@cargocorpuw.com

5. USE AND PURPOSE OF DATA COLLECTION

CargoCorp UW will obtain personal data by collecting it directly or through third parties duly authorized to provide such information for commercial purposes to fulfill its corporate purpose. CargoCorp UW will guarantee the safe storage of the information contained in the database, as well as its non-sale or supply to third parties other than its parent company, subsidiaries and other companies of the corporate group.

The data collected will be used for commercial purposes, marketing, statistics, data updates, satisfaction surveys, trend analysis and in general other technical studies useful for the products and services of CargoCorp UW and the purposes indicated below:

Perform the activities foreseen in the development of the labor and/or contractual relationship with employees, third party service providers.
To process the binding request as intermediary, policyholder, insured and/or beneficiary of the reinsurance contract.
Make decisions regarding the negotiation, placement, renewal and execution of policies with capacity providers (reinsurers) in accordance with underwriting policies, including the determination of premiums and risk management.
Based on legal obligations, control, prevent, detect and investigate crimes, including fraud and money laundering, and analyze and manage other risks applicable to the company operation.
Consultation, storage, management, transfer, processing of information to central information or databases duly constituted concerning money laundering or economic sanctions for the prevention of financial crimes, terrorism and fraud.
Execute and comply with reinsurance contracts, as well as the assessment, processing, settlement, adjustment and payment of claims, when appropriate, manage disputes over claims, through lawyers or specialized external third parties.
Manage premium collection activities, payment reminders, expirations and renewals through e-mails, phone contact and others.
Reply to requests or inquiries from business partners such as capacity providers, intermediaries or regulators.
Manage business infrastructure and operations; comply with internal policies and procedures, including auditing, finance, accounting, IT systems, data hosting, websites, business continuity; records and document management.
Resolve complaints and handle requests for data access or modification.
To ensure the security of individuals and property within the facilities, for this purpose, video surveillance cameras may be used.
Transfer the information to third parties appointed by CargoCorp UW at local or international level to fulfil the purposes informed to the information owner, such as technology providers where the hosting of our servers is located, with our group of companies, service providers, adjusters, investigators, insurance intermediaries, among other business partners and companies of the group.

Personal data provided will be stored for a period determined based on the following criteria: (i) the legal storage obligation; and (ii) the data subject’s deletion request, when applicable.

6. HOW WE OBTAIN DATA CONSENT

CargoCorp UW require the free, prior, express and informed consent from the data owner for the collection, storage, use, circulation or disposal of personal data in instances where the company directly obtains the information, as occurs in the process of hiring an employee or when there is a third-party service provider who is a natural person. For this purpose, CargoCorp UW as Data controller for the processing of personal data, has a consent form that will be shared to the data owners prior to their engagement, and will keep it as evidence of the consent.

Due to the CargoCorp UW business model, for certain business lines and products personal data may be obtained, in this scenario CargoCorp UW acts as attendant, considering that the intermediary is the one who makes the contact with the data owner and obtains the consent for the handling of data in the cases where regulation requires it and is empowered to transfer this information to CargoCorp UW for the quotation of reinsurance products. If required by any regulatory or supervisory body, proof of consent will be requested from the intermediary or insurer.

7. SPECIAL CATEGORY PERSONAL DATA

In the onboarding process of new employees, the company may obtain data about criminal history or consult binding and non-binding restrictive lists as part of the process of preventing money laundering and terrorist financing. The company may also obtain sensitive data if the data owner voluntarily provides it (for example, expresses preferences regarding medical use based on religious beliefs, gender issues, etc.).

It is possible to collect biometric data such as images and/or video recordings of the data owners as routine security of the facilities; this data will be kept under

appropriate measures to ensure proper custody. We inform you that the consent for the use of sensitive data is voluntary, therefore, unless these data are essential for the conclusion or execution of the contractual relationship with CargoCorp UW, the owners are not obliged to authorize their use. In those cases, in which they are required for the formalization of the contractual relationship and the data owner does not agree to provide them, it will be understood that he/she does not intend to be bound by the company, and he/she will be informed accordingly.

8. RIGHTS OF DATA OWNER

Data owners have the right to:

Request information about personal data, including information such as the source and categories of data, reasons for processing, recipients (or categories of recipients) and the retention period
Update or correct personal data so that it is always correct
Have personal data supplied in an electronic format
Request that your personal data be deleted from our systems, once it is no longer required for the above-mentioned purposes
Restrict the processing of your personal data under certain circumstances
Withdraw the consent at any time, if personal data is being processed with consent, without this affecting the lawfulness of the processing that took place before your consent was withdrawn
File a complaint with us or the relevant data protection authority.

9. DUTIES OF CCUW AS DATA CONTROLLER

Guaranteeing the Data owner the full and effective rights
Request and keep a copy of the respective consents granted by the Data owner, which is understood to be included in the offers submitted by the company
Keep the data under security conditions to prevent its loss, use or unauthorized access
Rectify or update the data when it is not accurate
To inform at the request of the Data owner about the use given to their personal data.

10. COMPLAINT HANDLING FOR INQUIRIES AND CLAIMS

The data owner may enforce the rights set forth in this policy as follows: By means of written communication to the offices mentioned in section 4 or by e-mail requesting information about the personal data held in the database managed by CargoCorp UW and exercise the rights set forth in section 8.

The communication may be addressed to Compliance to the following email; Compliance@cargocorpuw.com, Inquiries will be answered by the same means in which it was filed, within a maximum period of ten (10) working days from the date of receipt thereof. When it is not possible to attend the consultation within such a term, the interested party will be informed, stating the reasons for the delay and indicating the date on which the consultation will be attended, which in no case may exceed five (5) working days following the expiration of the first term.

For filing and attention of requests, the following information is requested:

Full name and surname
Contact details (e-mail address and contact telephone numbers)
Reason(s)/fact(s) giving rise to the claim with a brief description of the right you wish to exercise (know, update, rectify, revoke, delete, access to data).
Means to receive a response to your request
Signature and identification number.

If the data owner or the person duly authorized for the exercise of their rights, consider that the data contained in the database should be corrected, updated or deleted, they may file a claim with CargoCorp UW which will be processed according to the following rules:

The maximum term to resolve a request will be fifteen (15) business days from the day following the date of receipt. If it is not possible to remediate the request within said term, the interested party will be informed of the reasons for the delay and the date on which their claim will be attended, which in no case may exceed eight (8) business days from the first term date.
If the related data is not completed, the interested party will be contacted within five (5) days following receipt of the request to complete the data. After two (2) months from the date of the request, without the applicant presenting the required data, it will be understood that he has withdrawn the request
If the person who receives the request is not able to resolve it, he or she will send it to the corresponding unit within a maximum term of two (2) business days and will inform the interested party of the situation.
Once the complete request has been received, it will say “request in process” and the reason for it will be included in the database within a term of no more than two (2) business days. This legend will be maintained until the claim is decided.