Privacy Notice

1. Introduction

At Global Litigation, we collect, use and process Personal Information on individuals, including the following individuals who are covered by this Privacy Notice (“Notice”):

  • (prospective) insured persons, insurance applicants and policyholders (“Insureds”);

  • beneficiaries and other persons named in the insurance policy (“Beneficiaries”);

  • persons filing a claim under an insurance policy (“Claimants”);

  • collectively (“Insurance Contacts”);

  • individuals working for one of our business partners (“Business Contacts”);

  • individuals who otherwise interact with us online or offline, for instance filing a general request for information via our website (“General Contacts”);

  • individuals who use and visit our website (“Website Visitors”). 

This Notice does not apply to Global Litigation employees, job applicants or insurance brokers.

Global Litigation takes its responsibility to protect your Personal Information. In that respect, we are committed to handle your Personal Information in accordance with all applicable data protection laws and be transparent as to how we collect, process and share that information.

This Privacy Notice is designed to inform you how Global Litigation collect and use Personal Information when providing services as an insurance business. It explains how, why and when we collect, use, retain and disclose your Personal Information, as well as your own rights in relation to that information.

2. Who are we?

Global Litigation is an insurance Managing General Agent. As part of our core activities, we underwrite insurance business via delegated authority. We provide underwriting and risk management services to various insurers with whom we hold that delegated authority.

For the purpose of this Privacy Notice and the applicable data protection laws Global Litigation acts as controller and is responsible for the processing of your Personal Information: 

  • If you are an Insurance Contact

  • If you are a Business Contact or General Contact

  • If you are a Website Visitor

 In a number of instances, we do not collect the data from you directly (see Section 6: Where Do We Get Your Personal Information From?).

3. What types of Personal Information do we process?

The Personal Information we process depends on your relationship with Global Litigation and whether collection is permitted by applicable law. We collect and process the following categories of Personal Information from you:

Relationship with Global Litigation & Categories of Personal Information

Website Visitors

Website usage data and related identifiers such as technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, and operating system and platform. Personal Information collected by us also may automatically include information about your visit, including the full Uniform Resource Locators (URLs); clickstream to, through and from our site (including date and time); what you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks and mouse-overs); and methods used to browse away from the page.

Please refer to our Cookies Policy for more information about how we use cookies.

Insureds, Beneficiaries & Claimants

Individual details – name, address, date of birth and nationality.

Contact details, as well as further individual information about you in relation to a claim being made under a policy of insurance such including special categories data if the nature of the claim necessitates this.

Policy / Contractual information – such as details about quotes you receive and policies you hold and with whom you hold them.

Fraud and credit related data – such as credit history, credit score, sanctions and criminal offences, and information received from various anti-fraud databases relating to you.

Risk coverage details – information necessary to assess the risk to be insured and provide a quote. This may include data relating to your health, criminal convictions, or other special categories of Personal Information. For certain types of policies, this could also include telematics data.

Previous and current claims – information about previous and current claims (including other related insurances), which may include data relating to your health, criminal convictions, or other special categories of Personal Information and, in some cases, surveillance reports.

Special categories of Personal Information and criminal convictions data – data concerning your health and criminal offences and convictions data.

Witnesses

Contact details, as well as further individual information about you in relation to a claim being made under a policy of insurance such including special categories data – such as medical / health information or criminal history – if the nature of the claim necessitates this.

Business Contacts

Professional information and contact details such as information about your employer, your position / title and your professional contact details.

General Contacts

Visual information such as images collected from security cameras in our offices and basic contact details for visitor registration purposes such as your name, relevant professional information and contact details.

All Insurance Contacts

Inferences drawn from the above-referenced categories of information to assess risk.

Website Visitors, All Insurance Contacts, Business Contacts & General Contacts

Any other information you voluntarily share with us e.g. when you contact our customer service or otherwise engage with us.

We only process your special category and / or criminal Personal Information where strictly necessary. When we do, we will ask for your explicit consent where such is required in accordance with applicable data protection law, or we rely on a specific authorization in law that allows us to process this information.

4. What happens if you do not provide us with your Personal Information?

Depending on the capacity in which you interact with us as set out above, i.e. as a Website Visitor, Insurance Contact, Business Contact or General Contact, we need to process your Personal Information for different purposes (see Section 5: Why and on what legal grounds do we process your Personal Information?) including to respond to your inquiry, communicate with you, assess risk and make decisions in regard to your insurance policy application.

If we are not provided with your Personal Information, we are unable to undertake these activities and this may result in, e.g., us being unable to communicate with you or your insurance application being denied because we are unable to assess the risk involved.

5. Why and on what legal grounds do we process your Personal Information?

We will only use and process your Personal Information where we have a purpose and a legal ground to do so (where this is required under applicable data protection law). We use and process your Personal Information for the purposes and legal grounds set out below, depending on your relationship with us and whether the processing is permitted under applicable law:

Relationship with Global Litigation - Insureds, Beneficiaries & Claimants

Purpose

To consider an application for an insurance policy, assess and evaluate risk, determine the scope, risk coverage and premium of the policy and where applicable, provide you with insurance cover and any associated services.

To manage and administer contracts including or with regard to insurance policies (including dealing with your queries) with you and your legal and insurance representatives.

To assist our insurer Principals to manage and administer claims under an insurance policy, including assisting with the assessing and evaluating the merits of a claim.

To monitor risks and claims by performing spot checks.

To perform data analysis, draw up insurance-specific statistics and risk qualifications, and to otherwise improve our insurance and underwriting products and services and carry out market research and risk modelling.

To comply with our legal and regulatory obligations as an insurance company, including responding to requests from public authorities and fraud and money laundering prevention.

Legal Ground

The processing of your Personal Information is necessary to perform a contract to which you are a party (the insurance policy) or to take steps prior to entering into a contract with you.

The processing of your Personal Information is necessary for us to comply with legal and regulatory obligations.

The processing of your Personal Information is necessary to support our legitimate interests in managing our business (or those of a third party), in particular to administer insurance policies and applications, claims and assess risk.

Relationship with Global Litigation - Website Visitors

Purpose

Communicating with you and responding to your queries and complaints, providing you with information about our business upon your request, offering you customer service, and operating, securing and improving our website.

Legal Ground

We have a legitimate interest to operate our website and communicate with you upon your request.

Relationship with Global Litigation - Website Visitors, Insurance Contacts, Business Contacts & General Contacts

Purpose

Carrying out audits and investigations, and to investigate and resolve complaints, grievances or misconduct.

Legal Ground

We have a legitimate interest to manage our business and to ensure that all investigations and proceedings are managed efficiently and effectively.

We have a legal obligation to do so.

Relationship with Global Litigation - Website Visitors & Insurance Contacts

Purpose

Preparing for and acting in relation to enquiries, investigations or proceedings, by governmental, administrative, judicial or regulatory authorities, including civil litigation.

Legal Ground

We have a legitimate interest to manage our business and to ensure that all investigations and proceedings are managed efficiently and effectively.

Relationship with Global Litigation - Business Contacts & General Contacts

Purpose

Complying with our legal and regulatory obligations including the prevention and detection of fraud, money laundering and other crimes.

Legal Ground

We have a legal obligation to do so.

Relationship with Global Litigation - General Contacts

Purpose

Debugging to identify and repair errors that impair existing intended functionality.

Legal Ground

We have a legitimate interest to debug to identify and repair errors that impair existing intended functionality.

If you are in the European Economic Area (“EEA”) or the UK, You have a right to object to the processing of your Personal Information where that processing is carried out for our legitimate interests. Please note however that we may not be able to fulfil this request in all instances.

Before relying on legitimate interests as a legal basis, Global Litigation perform a legal assessment to confirm that your rights do not override its legitimate interests. You can request further details on this assessment by contacting us using the contact details listed in Section 14: Contact details.

6. Where do we get your Personal Information from?

The source from which we get your Personal Information will always depend on your specific circumstances.

In most cases, we obtain your Personal Information from third parties such as your insurance agent, broker or solicitor.  

On occasion, we may also receive / collect your Personal Information directly from you, such as when you are a Website Visitor or where you are otherwise in direct contact with us. We may also receive your Personal Information from the following sources:

  • Persons and companies you are affiliated with or related to;

  • We automatically collect certain information when you visit or use our Website;

  • Credit reference agencies;

  • Reinsurance companies and other third party insurance companies with whom you have, had, are applying for, or have filed a claim under an insurance policy;

  • Anti-fraud databases, CLUE reports, sanctions lists, court judgements and other public databases;

  • Government agencies;

  • Open electoral registers and other publicly available registers such as company registers;

  • Supervisory, regulatory and other public authorities;

  • In the event of a claim, third parties including the other party to the claim (claimant / defendant), witnesses, experts (including medical experts), loss adjustors, external counsel, and claims handlers;

  • Service providers such as organizations operating our website; and

  • Other public and non-public sources including information that is publicly available online.

7. Automated decision-making including profiling

Automated decision-making is a process whereby decisions, with effect on an individual, are made using automated computing means (i.e., without involvement of a human). Profiling is an automated process whereby Personal Information is processed to evaluate certain personal aspects of an individual to analyse or predict behaviour or aspects.

As explained above in Section 5: Why and on what legal grounds do we process your Personal Information? Global Litigation performs data analytics to establish risk patterns and categories. This insurance specific exercise is considered profiling and / or automated decision-making and is necessary to enter into a contract with you – to confirm that the premium amount reflects and adequately matches the associated risk – and / or authorized under applicable law.

Profiling may also be used by our Insurance Market Participants to assess information relating to you, to identify and have a good understanding of fraud patterns. Where special categories of Personal Information are relevant, such as medical history or past criminal convictions for certain types of insurance, such special categories of Personal Information may also be used for profiling. However in this case, and where relevant, your prior consent will be requested unless reliance on another legal basis  to process this data for profiling purposes applies.

Please reach out to us using the contact details in Section 14: Contact Details below if you want to receive more information.

8. Retention of your Personal Information

We will retain your Personal Information only for as long as is necessary for the purpose for which it was originally obtained, to comply with our legal and regulatory obligations, and to defend our rights, and always in line with the data retention periods set forth in the laws and regulations applicable to us.

9. Who do we share your Personal Information with?

We share your Personal Information with other Global Litigation affiliates and litigation funders. Global Litigation employees only have access and process your Personal Information on a “need to know” basis, i.e. only where such access and processing is necessary for such employees to perform the tasks and responsibilities allocated to them.

We also share your Personal Information with the following categories of third-parties:

  • Our service providers (e.g. IT service providers supporting our information security and technology, external counsel and other legal advisors, consultants, auditors, website and data hosting providers, marketing agencies, accountants, etc.);

  • Governmental authorities including our supervisory regulatory authorities and law enforcement agencies;

  • Contractors, brokers, your solicitors, litigation funders, barristers, specific case expert witnesses or financial institutions; and

  • Other third parties (i) upon your request; (ii) to protect and defend our rights and properties; (iii) to detect and / or prevent fraud or money laundering; (iv) in the event of a sale, merger or reorganization of our assets or other restructuring; and / or (v) where we are, or believe in good faith that we are, under a legal obligation to share your data.

The categories of personal information we collect about you and the third parties to whom we disclose that Personal Information for a business purpose are as follows:

Categories of Personal Information & Categories of third-parties to whom we disclose Personal Information

Website usage data and related identifiers

Intra-group Global Litigation entities, service providers and other interested third-parties (in connection to the purpose for which data was collected) as reflected above. 

Individual details

Intra-group Global Litigation entities, service providers and other interested third-parties (in connection to the purpose for which data was collected) as reflected above.

Contact details

Intra-group Global Litigation entities, service providers and other interested third-parties (in connection to the purpose for which data was collected) as reflected above.

Identification details

Intra-group Global Litigation entities, service providers and other interested third-parties (in connection to the purpose for which data was collected) as reflected above. 

Financial information

Intra-group Global Litigation entities, service providers and other interested third-parties (in connection to the purpose for which data was collected) as reflected above. 

Policy / Contractual information

Intra-group Global Litigation entities, service providers and other interested third-parties (in connection to the purpose for which data was collected) as reflected above. 

Fraud and credit related data

Intra-group Global Litigation entities, service providers and other interested third-parties (in connection to the purpose for which data was collected) as reflected above. 

Risk coverage details

Intra-group Global Litigation entities, service providers and other interested third-parties (in connection to the purpose for which data was collected) as reflected above. 

Previous and current claims

Intra-group Global Litigation entities, service providers and other interested third-parties (in connection to the purpose for which data was collected) as reflected above.

Special categories of Personal Information and criminal convictions data

Intra-group Global Litigation entities, service providers and other interested third-parties (in connection to the purpose for which data was collected) as reflected above.

Professional information

Intra-group Global Litigation entities, service providers and other interested third-parties (in connection to the purpose for which data was collected) as reflected above. 

Inferences drawn from the above-referenced categories of information to assess risk.

Intra-group Global Litigation entities, service providers and other interested third-parties (in connection to the purpose for which data was collected) as reflected above. 

Any other information

Intra-group Global Litigation entities, service providers and other interested third-parties (in connection to the purpose for which data was collected) as reflected above.

In the preceding twelve (12) months, we may have disclosed the above listed categories for a business purpose. We do not sell Personal Information, and in the preceding twelve (12) months, we have not sold Personal Information.

10. International data transfers

The recipients who we share your Personal Information with, as mentioned in Section 9: Who do we share your Personal Information with? may be located in countries that may have data protection laws that are different to the laws of your country, and in some cases, may not have an adequate level of data protection, which means that local laws may provide for a lower standard of protection for Personal Information than the one that applies within your jurisdiction.

We only transfer your Personal Information to these jurisdictions in compliance with applicable data protection law and transfer restrictions, and we implement appropriate safeguards where required.

If you are located in the EEA/UK and we transfer your Personal Information to other Global Litigation group companies located outside the EEA/UK, we rely on the EU Commission Standard Contractual Clauses (“SCCs” – link here) (amended for use in the UK as appropriate with the application of the international transfer addendum (“Addendum” – link here) to the EU SCCs) (Art. 46(2)(c) GDPR) or the UK standalone international data transfer agreement (“IDTA” – link here). Where your Personal Information is transferred to another recipient outside of the EEA/UK we will seek to enter into SCCs or international data transfer agreement with the recipient, seek assurances from the recipient that they have Binding Corporate Rules in place (Art. 46(2)(b) GDPR) or, in exceptional circumstances, rely on a derogation under applicable data protection law (Art. 49 GDPR) (e.g., where the transfer is necessary for the defence of legal claims). Further, where there is a direct transfer of Personal Information from you as an individual to us or one of these recipients outside the EEA/UK we rely on the household exemption where this is available under applicable data protection law. Furthermore, Global Litigation relies on the recommendations 01/2020 on measures that supplement transfer tools to ensure compliance with the EU level of protection of personal data from the European Data Protection Board.

If you are in the EEA/UK, you may obtain more information with regards to the transfer mechanism used by contacting us using the contact details below.

If you are in the EEA/UK and would like to receive further details on the safeguards implemented for the transfer of your Personal Information, you may contact our Data Protection Team using the contact details reflected under Section 14: Contact Details below.

11. Your rights

As a data subject, you may have rights with respect to the processing of your Personal Information under our control as follows:

  • Access your Personal Information – You may ask us what Personal Information we process and request copies of such Personal Information;

  • Rectification of Personal Information – You may ask us to rectify or update Personal Information that is inaccurate or incomplete;

  • Erasure of Personal Information – You may ask us to delete your Personal Information in certain instances;

  • Restriction of processing – Under certain circumstance (such as when you question the accuracy of the Personal Information we hold on you or the lawfulness of its processing) you may request us to stop processing such data until your request is resolved;

  • Data portability – In certain cases, you may ask us to send an electronic copy of your Personal Information directly to you or to another organization;

  • Object – You may object to any processing of your Personal Information, including profiling, based on the ground of legitimate interest, as well as the share of your Personal Information for cross-context behavioural advertising;

  • Withdraw – Where processing of your Personal Information is based on your consent – you may at any time withdraw your consent however this will not affect any processing we did before withdrawal.

Please note that in addition to the abovementioned limitations to your rights, other limitations to the above rights may apply, for instance to safeguard the public interest (e.g., the prevention or detection of crime).

You also have the right to lodge a complaint about the processing of your Personal Information with the competent data protection authority which typically would be the supervisory authority of the country you are located in. Please find below the competent authorities depending on your location:

  • To consult a full list of all EU data protection authorities, please click here.  

  • To consult the UK data protection authority’s contact details please click here.  

Global Litigation will verify that the information you submit (which may include your first name, last name, email address, company, and country / state) matches our records before we fulfil the request. You may use an authorized agent to submit a consumer rights request on your behalf using the methods above, however, Global Litigation will require the authorized agent to provide signed permission to submit the request on your behalf and may still contact you to confirm your identity and that this request was submitted with your permission.

Global Litigation does not discriminate against you for exercising your rights or offer you financial incentives related to the use of your personal information.

In order to exercise the above listed rights, please contact our Data Protection Team using the contact details reflected under Section 14: Contact Details below. Please note that we may ask you to verify your identity.

12. Information security

The Personal Information collected by Global Litigation is secure and maintained in a manner consistent with current industry standards, laws, and regulations. Your Personal Information is protected in several ways: 

  • It resides on a secure server that only selected personnel and contractors can access using a unique logon and password. Access is provided based upon the principle of least privilege;

  • We encrypt your Personal Information in transit in order to prevent unauthorized parties from viewing that information when it is transmitted;

  • We use internet firewalls, intrusion detection and network monitoring depending on the nature of the information and the scope of processing. 

13. Commitment to children’s privacy

Our services are not directed to or intended for individuals under 18 years of age. We do not knowingly collect information from individuals under the age of 18 years without parental consent.  If we become aware that an individual under 18 years has provided us with personal information without parental consent, we will take steps to remove the data as permitted by law.

We do not knowingly sell or share information of individuals under the age of 16 years.

14. Contact details and DPO

For all details regarding compliance with data protection / Personal Information laws, please contact our Data Protection Officer (“DPO”) by email at simon.ware@global-litigation.com. 

15. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. If such changes are material in nature, we will provide you with additional notice (such as adding a statement to the Website page or sending you an email notification). The most current version of the Privacy Notice in effect at the time of your use of the Website will govern your use of it.  Changes to the Privacy Notice will not be applied retroactively to Personal Information that was collected before the effective date of any change, unless required by applicable law.

16. Key terms

Term & Meaning

Insurance Market Participants

Managing General Agents and Third Party Administrators or our “Members”.

Personal Information

Any information relating to an identified or identifiable person i.e. who can be directly or indirectly identified

Special categories of information

Certain categories of Personal Information, which have additional protection under certain data protection laws due to their sensitivity. The categories are health, criminal convictions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric, or data concerning sex life or sexual orientation.

We, us

Global Litigation Limited 

You, your

Website Visitors, Insurance Contacts, Business Contacts and General Contacts.

Data protection law

Local regulation and legislation that is offering the protection on Personal Information to ensure that natural persons can trust Global Litigation to use their Personal Information fairly and responsibly. Such texts include (but are not limited to) the EEA/UK General Data Protection Regulation (GDPR).