- 1. Important information and who we are
Purpose of this Privacy Notice
K2 International respects your privacy and is committed to protecting your personal data.This Privacy Notice applies to any individual whose personal information we process while providing insurance or related services or operating our business, including website users; individuals enquiring about career and employment opportunities; employees of intermediaries, and third-party suppliers; policyholders; prospective policyholders and beneficiaries and claimants under our insurance policies.
Insurance involves the use and disclosure of your personal information by various insurance market participants. The London Insurance Market Core Uses Information Notice, which can be found at https://www.londonmarketgroup.co.uk/gdpr describes how the insurance market participants process your personal information during the insurance lifecycle. We recommend you review this Core Uses Notice as well as this Privacy Notice.
It is important that you read this Privacy Notice together with any other Privacy Notice or fair processing notice we may provide you on specific occasions when we are collecting or processing your personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them.
Controller
For the purpose of data protection legislation, the data controller is K2 Group Holdings Limited (a company registered in England and Wales under number 12492816) whose registered office is at 5th Floor, 35 Great St. Helen’s, London EC3A 6AP.
If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please email us using the details set out below.
Contact Details
Data Controller: K2 Group Holdings Limited
Contact email: compliance@k2insinternational.com
Postal address: 5th Floor, 35 Great St. Helen’s, London EC3A 6AP
Telephone number: +44(0)20 7039 3777
- 2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Individual details
Name, address (including proof of address), other contact details (for example e-mail address and telephone numbers), gender, marital status, date and place of birth, nationality, employer, leisure activities and interests, family details including the relationship of family members to you.
Identification details
Identification numbers issued by government bodies or agencies, including your national insurance number, passport number, tax identification number and driving licence number.
Data from fraud prevention, law enforcement or government agencies
Other publicly available databases and data sources used to prevent or detect fraud or provide details to us about criminal convictions or offences.
Data in relation to regulatory issues from HM Treasury and other authorities
For example, when someone is subject to a financial sanction, they will appear on HM Treasury’s asset freezing list.
Information relating to underwriting insurance policies
Managing and processing insurance claims, such as previous insurance records and claims histories, and in some cases, surveillance reports.
Employment and career information
Your employment history, job title, salary, employment benefit options, educational background and any professional qualifications and licences.
Usage Data
Information about how you use our website, products, and services.
The type of information we may collect and process about you will depend, in some circumstances, upon the type of insurance which we are offering or underwriting.
We may also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
- 3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your name, address, company, and email address by filling in forms or by corresponding with us by email. This includes personal data you provide when you:
- request further information on K2 International; or
- give us some feedback.
- Information relating to underwriting insurance policies
- Employment and career information
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
- Third parties or publicly available sources. We may receive data about you from various third parties and public sources as set out below:
- analytics providers such as Google based outside the EU;
- search information providers such as Google, Bing based outside of the EU.
- 4. Purposes for which we will use your data
We use your personal information to meet our obligations in our contracts of insurance and to operate our business. We must have a legal basis to process your personal information. We and our other group companies use your personal information in the following ways and for the following reasons:
- To provide insurance services
We may use your personal information to issue quotes for, and administer, policies of insurance. We can use your information in this way to fulfil our contractual obligations or to take steps before entering into a contract.
- To do what we are required to do by law
We may use your personal information to comply with legal obligations and to cooperate with regulatory bodies to which we are subject. This includes the prevention and detection of fraud, money laundering, terrorism and other crimes; the carrying out of background checks where these are required and lawful; fulfilling due diligence and reporting obligations; and responding to binding requests from regulators.
We can use your information in this way because we are obliged to comply with legal and regulatory requirements including the Financial Services and Markets Act 2000 and the regulation of the Prudential Regulation Authority and the Financial Conduct Authority.
- To review, process and manage insurance claims
We may use your personal information to manage the investigation and payment of claims made under our insurance policies, including conducting fraud, anti-money laundering and sanctions checks and bringing or defending legal claims which relate to the policy of insurance.We can use your information in this way to fulfil our contractual obligations, to comply with legal and regulatory requirements and because it is in our legitimate interests to exercise our rights and bring or defend claims made against us.
- To operate and audit our business
We may use your personal information to fulfil our contractual obligations to third parties; to perform administrative activities in connection with our services; to conduct data analysis which helps us assess risks, price our insurance appropriately and improve our services; to research and develop new insurance products.
We can use your information in this way because it is in our legitimate interests to improve our services and manage our business efficiently, to ensure we manage risk and price our insurance appropriately, and to maintain accurate records and perform audits. When we process your personal information on the basis that it is in our legitimate interests to do so we balance our interests with your rights and freedoms and keep the information used and the processing to the minimum required to meet those legitimate interests.
- To exercise our legal rights
We may use your personal information to exercise, defend and protect our legal rights or the rights of third parties where it is necessary to do so. For example we may bring or defend claims or recover debts which are due to us.
We can use your information in this way because it is in our legitimate interests to exercise our rights to collect money which is owed to us and to bring or defend claims made against us.
- For recruitment
We may use your personal information to assess your suitability for employment and make recruitment decisions.
We can use your information in this way because it is in our legitimate interests to recruit suitably qualified employees and carry out our responsibilities in relation to recruitment.
- 5. Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get any additional information on this, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- 6. Who do we share your personal information with?
We may share your personal information with third parties and other companies within our group in the following circumstances:
K2 Group companies – we operate as an international business so we may share your personal information with group companies who may use this information for the purposes described in this Privacy Notice.
Insurance market participants – including insurance and reinsurance companies, other coverholders, intermediaries, and business partners. We may share your personal information with these third parties should they need to use your personal information in connection with the provision of insurance and processing of claims.
Service providers – we may share your personal information with service providers that perform services and other business operations for us, for example, software and analytics providers, professional advisors and auditors.
Potential purchasers – we may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Privacy Notice.
Companies who are our customers – we may share your personal information with your company or employer in certain circumstances, for example, if your company or employer has a corporate insurance policy with us and you make a claim under that policy.
Any law enforcement agency, court, regulator, or government authority. We may share your personal information with these parties where this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
- 7. Will we share your personal information overseas?
We may need to transfer your personal information to other insurance market participants, our group companies, and service providers, contractors and agents who perform services on our behalf and are located outside of the UK.
We will put agreements in place with the people we send information to so that these transfers will be made in compliance with data protection legislation, and they will be required to treat your personal information with the same degree of protection that would apply within the UK. For more information on the appropriate safeguards in place, please contact us at the details below.
In some cases we might need to share information to carry out the services we have promised to carry out, for example if you require urgent assistance abroad. In such an urgent situation we may not always have the time to put in place the type of agreement we would normally want to.
- 8. How long will we keep your personal information?
We will keep your personal information only for so long as is necessary and for the purpose for which it was originally collected. In particular, for so long as there is any possibility that either you or we may wish to bring a legal claim or complaint under an insurance policy, or where we are required to keep your personal information for legal or regulatory reasons.
- 9. Security
We maintain appropriate security standards and procedures with a view to preventing unauthorised access, use, alteration, or destruction of personally identifying information. We use leading technologies such as (but not limited to) data encryption, fire walls and server authentication to protect the security of your personally identifying information.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- 10. Your legal rights
You have rights under data protection laws in relation to your personal data, including:
- Request information on how we process your personal data
- Request access to your personal data – please complete the online SAR form
- Request rectification of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data (data portability).
- Right to withdraw consent
- Challenge automated decision making
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. If you elect a representative to act on your behalf, we will have to verify their authority to represent you and their identity.
Time limit to respond
We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you of our intention to extend this period within the first 30 days and keep you updated throughout the process.
Changes to the Privacy Notice and your duty to inform us of changes
We keep our Privacy Notice under regular review. This version was last updated on 1st February 2023.
It is important that any personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website includes links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website to click to a third-party website, we encourage you to read the Privacy Notice of every website you visit.