Global Privacy Notice

This Global Privacy Notice (“Notice”) intends to comply with the relevant requirements under the applicable data protection laws. The Notice sets out how the following Texel entities (each and together “Texel”) use and protect information that Texel obtains about you, either on this website or in its relationship with you.

Texel Finance Limited, with its registered address at 11 Bury Street, London, United Kingdom, EC3A 5AT

Texel Europe BV, with its registered address at Avenue Louise 54, 1050 Brussels, and its UK branch with its establishment address as 11 – 12 Bury Street, London, United Kingdom, EC3A 5AT

Texel Asia Pte Ltd, with its registered address 3 Pickering Street #02-53 China Square Central – Nankin Road Singapore 048660

We collect personal information to offer and administer our insurance intermediary services, in addition to any information we collect to engage you as a third-party service provider for general office management purposes.

Texel is committed to ensuring that your privacy is protected. Your information obtained by Texel as “data controller” will be held in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”) and, where applicable, the UK legislation (including the Data Protection Act 2018), the Belgian Data Protection Act of 30 July 2018 and the Singapore Personal Data Protection Act 2012.  Should we ask you to provide certain information from which you can be identified this Privacy Notice sets out why we need your information, how we protect your information and your rights in relation to your information.

Texel may change this Privacy Notice from time to time.  This Privacy Notice is effective from 09 July 2024.

What information we collect

We may collect the following information:

• Information that you have provided to us by uploading it or filling in forms for us;
• Recorded telephone and both audio and video conferencing calls if you contact us or we contact you;
• Name and job title, details of your employer, contact information including email address and contact number (business or personal as required);
• Passport/ID details if we need to verify your identity for KYC/ Anti-Money Laundering purposes;
• Name, date of birth, passport/ID details, place of birth, nationality, details of your previous employment, employer references, DBS certificates of you, and the name, relationship, date of birth and contact number of your next of kin or beneficiaries, as applicable, for employment purposes;
• Demographic information such as postcode, preferences and interests (for website traffic monitoring purposes);
• Details of your visits to our website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.

We are unlikely to store any special categories of data, such as medical conditions, biometric data etc, however this information may become available to us indirectly while advising on a claim, arranging a contract of insurance, or dealing with you as a supplier/service provider.

What we do with the information we gather

We may use your information for the following:

• To provide information and insurance intermediary services as requested by you, in particular to negotiate, arrange, administer and incept insurance contracts with underwriters, or negotiate, administer and generally assist you with a claim under an insurance contract we have placed for you.
• To identify you as required under applicable law and regulations (such as KYC onboarding, AML, sanctions or credit checks).
• To monitor calls for training, monitoring or compliance purposes and to assist in the administration of your claim or your insurance policy.
• To engage in a commercial relationship with yourself, or your employer, or organisation.
• To send out billing and general administration communications.
• To send out client communications, invitations to events/presentations, and marketing materials that are relevant to you and the services we provide, including regulatory updates, Texel’s work in the Credit and Political Risk Insurance market and work by the Texel Foundation and supported programmes.
• To obtain and update credit information with appropriate third parties, such as credit reporting agencies.
• Internal record keeping.
• To manage, comply with or receive/provide a supplier/service agreement with yourself.
• From time to time, we may use your information to contact you for market research purposes. We may contact you by email, phone, or mail. We may use the information to customise the website according to your interests; and
• To manage our relationship as your employer or administrator for any applicable employee benefits.

Disclosure of personal data to third parties

For the purposes set out above, personal data may need to be shared with third parties such as underwriters and service providers required to administer your policy or your claims (loss adjustors, service companies, lawyers, auditors, etc.) to the extent necessary to carry out our relationship with you.

We may also need to liaise with our affiliates and other Group entities to negotiate, arrange, administer and incept insurance contracts with underwriters, or negotiate, administer and generally assist you with a claim under an insurance contract we have placed for you.

To obtain and update credit information we will moreover exchange personal data with appropriate third parties, such as credit reporting agencies.

In addition thereto, we sometimes share personal data with our third-party suppliers including IT service and platform providers and data storage providers, with our auditors, lawyers and other professional advisors, and with regulatory agencies, insurance bodies, law enforcement or relevant third parties (if you are not regulated) in order to detect and prevent financial crime, recover payments due or complete due diligence, or to comply with regulatory or legal obligations.

We will implement appropriate safeguards when transferring your personal data to third parties. If necessary, we will for example conclude a data transfer or a processing agreement specifying the limitations to the use of your personal data and the obligations with respect to the security of your personal data.

Finally, if Texel is (a) subject to negotiations for the sale of its business, or group or (b) is sold to a third party or (c) undergoes a re-organisation, personal data which it holds may be disclosed to that organisation/person (or its advisors) as part of any due diligence process or transferred to that re-organised entity or third party and used for the same purposes or for the purpose of analysing any proposed sale or re-organisation. In such context, only strictly necessary personal data shall be disclosed, and appropriate data security and confidentiality safeguards shall always be implemented.

Overseas transfer

We may send your personal information overseas outside the EEA or Singapore in order to deliver our insurance intermediary services.  Should this situation arise, Texel shall ensure that the appropriate safeguards are in place to protect your personal information.

Within our Group, we have Group companies and branches based in the UK, the US and Singapore.  Whilst these operations are separate, there may be instances where we work with our UK, US and Singaporean counterparts and information may be shared between the entities and branches of the Group.  Where this is the case, we will ensure we have the appropriate safeguards in place to protect personal information.

Lawful bases for processing your information

We rely on the following lawful bases to permit us to collect and process your information so that we can arrange insurance cover, deal with claims or manage a service provider relationship with you:

• We process your information to fulfil our terms of business with you, should you request our insurance intermediary services.
• It is in our legitimate interests to do so, and the such interests are not overridden by your fundamental rights or freedoms. Such legitimate interests include our ability to provide insurance intermediary services to you, should you request this.
• From time to time, Texel may be required to process your information to comply with the law or our regulatory obligations; and/or
• Your consent. Where information is obtained directly from you, your consent may be requested for the processing of your data for specifically identified purposes (such as direct marketing or recording video calls).

Your rights relating to your information

You have the following rights, subject to certain limitations and exceptions:

• You may review and obtain a copy of the information we hold about you or ask us to amend it where it is inaccurate or limit the purpose for which we use your information.
• You may object to your information being used, for example for direct marketing, or, in the case of video calls, you may disconnect or switch off your camera from the beginning of the meeting (although, audio may still be recorded).
• Where processing your information on the basis of your consent, you may withdraw your consent to such processing at any time.
• You may, in some cases, ask us to erase any personal data we hold about you; and
• You may request to receive your personal data in a structured, commonly used and machine-readable format and to (have) transmit(ted) your personal data to another organisation.

More information can be found at the following links:

• UK – https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/;and
• Belgium – https://www.dataprotectionauthority.be/citizen/privacy/what-are-my-rights
• Singapore https://www.pdpc.gov.sg/Overview-of-PDPA/Data-Protection/Individual/Individuals-Overview

Finally, you also have the right to lodge a complaint relating to the processing of your personal data by us with the data protection authority in your country. For the EU, please find a list of supervisory authorities here: https://edpb.europa.eu/about-edpb/board/members_en or see the contact details herein:

Your rights may be exercised by contacting us as stated below.  These rights are not absolute, and we will let you know in our correspondence with you whether we think they apply to you. If you limit the purpose for which we use your information or withdraw your consent, this may impact our ability to arrange insurance, administer claims, or provide and/or receive services from you.

In principle you may exercise these rights free of charge. Only where requests are manifestly unfounded or excessive, we may charge a reasonable fee. We might (if deemed necessary) also request a proof of identity in advance in order to verify your request.

Security

We are committed to ensuring that your information is secure.  In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online and through our ongoing relationship with you.

Any information we hold about you is held on secure servers accessible only by authorised parties and complies with industry accepted security protocols.

Data retention

Your personal data will not be stored for longer than is necessary in relation to the purposes for which we process them (as listed above). Afterwards it is still possible that they can be found in our back-ups or archives, but they will no longer be actively processed in a file.

More specifically, the following data retention guidelines are applied:

• Any personal data included in accounting, financial or other official documents will be retained for as long as such documents legally need to be kept;
• Any personal data obtained in the context of complaint handling will be deleted (or anonymised) as soon as the complaint is closed;
• Only where we are legally obliged to, or where this is necessary for defending our interests in the context of judicial proceedings (where a statutory limitation period of 10 years applies in Belgium), we will store the personal data for longer periods.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive.

Once you use our website, the file is added and the cookie helps analyse web traffic or lets us know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs.

We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies, by indicating your preference through our cookie consent banner. Most web browsers automatically accept cookies, but you can modify your browser setting to decline non-critical cookies if you prefer. This may in some cases prevent you from taking full advantage of the website.

An audit is carried out by a third party, periodically of all cookies being used on our website.

Current Cookies which are used on our website are Google analytics cookies (for website analytics and statistical purposes):

• _utma (used to distinguish users, expires after 2 years)
• _utmt (used to throttle request rate, expires after 1 minute)
• _utmb (used to determine new sessions/visits, expires after 30 minutes)
• _utmc (used to set interoperability, expires at the end of the browser session); and
• _utmz (used to store traffic source, expires six after months).

These are third-party cookies provided by Google Analytics. For more information about Google Analytics cookie usage, visit the following web page: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?hl=en. Google’s Privacy Policy can be easily consulted here: https://policies.google.com/privacy?gl=NL&hl=en.

All major internet browsers offer the option to manage the cookies that were installed on your computer or mobile device. In case you no longer want us to place cookies on your computer or mobile device, you may limit or delete them easily by adjusting your browser or mobile settings. In addition, you can set you browser or mobile settings in such a way that you get a notification every time you receive a cookie on your computer or mobile device, so that you can decide whether you wish to accept this cookie or not.

More information for your browser type:

• Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
• Chrome: https://support.google.com/accounts/answer/61416?hl=en
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
• Safari: http://support.apple.com/kb/PH5042

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Notice. You should exercise caution and look at the privacy statement applicable to the website in question.

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