Privacy and cookies

Liberty Specialty Markets takes the protection of your personal data seriously and is committed to protecting your privacy.  This Privacy Notice sets out details of the information that we may collect from you and how we may use that information. Please take your time to read this notice carefully. When using a Liberty Specialty Markets website, this notice should be read alongside the website terms and conditions. The information is displayed in a drop-down list, divided into different questions related to the protection of your data. By clicking on each question, you can easily access the information that may be of most interest.

Please take the time to read this notice carefully. If you have any questions or concerns, please feel free to contact us by phone, email or mail at the addresses shown in sections 1 and 12 below. When using the Liberty Specialty Markets website, this privacy notice should be read in conjunction with the website terms and conditions.

Liberty Specialty Markets is an international insurance business. We offer insurance to individuals, companies and other insurers.

In order for us to deliver insurance services which involve providing you with a quote and then insurance, and dealing with any claims or complaints that might arise, we need to collect and process data.  We also collect your information for recruitment purposes, in our contractual relationships with you and for relationship development, where appropriate. This makes us a "data controller".

Liberty Specialty Markets is comprised of a number of data controllers depending on the interaction you have with us or the policy written.

• If you are contacting us for recruitment purposes then Liberty Specialty Markets Limited and/or Liberty Specialty Markets Europe Sarl will be the data controllers for your personal data.
• If you are a broker, customer, supplier, contractual counterparty or other third party then one of the following will be the data controllers of your personal data:
  • Liberty Managing Agency Limited (for and on behalf of the Underwriting Members of Lloyd’s Syndicate 4472) and/or
  • Liberty Mutual Insurance Europe SE and/or
  • Liberty Specialty Markets Europe S.a.r.L and/or
  • Liberty Specialty Markets Europe Two S.a.r.L and/or
  • Liberty Mutual Reinsurance (a division of Liberty Mutual Insurance Company) and/or
  • Liberty Specialty Markets MENA Limited and/or
  • Liberty Specialty Markets Bermuda Limited and/or
  • Liberty Specialty Markets Agency Limited.

Any documentation you receive may state any of our trading names, including Liberty Specialty Markets, Liberty Mutual Reinsurance, Global Transaction Solutions or Liberty Mutual Surety.

The specific company acting as a data controller of your personal data will be listed in the in the documentation we provide to you.

If you are a customer residing in California, please view the relevant supplementary privacy notice here. 

If you are unsure about who the data controller of your personal data is, you can also contact us at any time by e-mailing us at dataprotectionofficer@libertyglobalgroup.com or by writing to Data Protection Officer, Liberty Specialty Markets, 20 Fenchurch Street, London, EC3M 3AW.

Insurance involves the use and disclosure of your personal data by various insurance market participants such as intermediaries, insurers and reinsurers. The London Insurance Market Core Uses Information Notice sets out those core necessary personal data uses and disclosures. Our core uses and disclosures are consistent with the London Market Core Uses Information Notice. We recommend you review this notice (by clicking the link above).

The types of personal data that we collect and our uses of that personal data will depend on our relationship with you. For example, we will collect different personal data depending on whether you are a policyholder, a beneficiary under an insurance policy, a claimant, a witness, a broker, a potential employee or another third party.

Sometimes we will request or receive your “sensitive personal data” (which is information relating to your health, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership). For example we may need access to information about your health in order to provide you with a quote, provide your insurance policy, or process any claims you make. We may also need details of any unspent criminal convictions you have for fraud prevention purposes, to the extent permitted by Spanish law. In some of these cases, we will need and obtain your explicit consent to collect and process the special category of personal data. You can find out more about the purpose of the use of your personal data below.

This notice sets out the legal grounds enabling us to process your personal and special category data. There are different requirements in different jurisdictions for processing special category data. This notice sets out the position for Spain.  For example, in Spain, we are able to process special category data where it is necessary to provide insurance services to you. In other jurisdictions, we require your explicit consent. Where the tables below note that special category data will be processed for the purposes of providing insurance, this only applies to our data controllers subject to English, Irish, Dutch or Spanish law law (this will be clear from the documentation supplied to you).

Where the provision of information is legally or contractually required, we will tell you this at the time of collection.

Where you provide personal data to us about other individuals (for example, members of your family) we will also be data controller of and responsible for their personal data. You should refer them to this notice before supplying us data on behalf of others.

We may amend the personal data so that you cannot be identified from the data either by itself or when combined with any other data we hold.  That data will then not be subject to this notice or data protection law.

In order to make this notice as user friendly as possible, we have split it into different sections. The notice is available in different languages to reflect our global presence.   Please click on the section below that best describes your relationship with us.

If you apply for an insurance policy or where someone else (such as a family member or your employer) applies for an insurance policy which will benefit you, this section will be relevant to you and sets out our uses of your personal data.

What personal data will we collect?

• General information such as your name, address, contact phone numbers and email addresses, date of birth and gender.
• Information about your relationship to the policyholder where you are the beneficiary.
• Identification information such as passport details, driving licence and national insurance number.
• Your bank and payment details.
• If relevant, information about your job such as job title, employment history and professional accreditations.
• Any financial information about you which we have obtained as a result of conducting credit checks such as bankruptcy orders, individual voluntary arrangements or country court judgments.
• Information which we obtain as part of checking sanctions lists, such as those published by United Nations, European Union, UK Treasury, the U.S. Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce, Bureau of Industry and Security .
• Any information which is relevant to your insurance application such as previous insurance policies you have held and claims you have made. This will also include any information specific to the type of policy you are applying for, for example, if you are applying for a fine art policy we may collect and use information which relates to your art collection.
• Information which we have gathered from publically available sources such as the electoral roll, newspapers and social media sites.
• Any other information passed on from you, your insurance broker or someone else applying on your behalf. 

What sensitive personal data will we collect?

• Details about your criminal convictions and any related information. This will include information relating to any offences or alleged offences you have committed or any court sentences which you are subject to.
• Details about your physical and mental health which are relevant to your application (e.g. if you take out or are covered by a personal accident policy, we may need details of pre-existing medical conditions). This may take the form of medical reports or underlying medical data such as x-rays or blood tests.
• We may also collect information because it is relevant to your application, which reveals or is likely to reveal your race or ethnicity, religious or philosophical beliefs; political opinions; trade union membership; genetic or biometric data; or data concerning your sex life or sexual orientation. For example, we may process information relating to your trade union membership if you take out a policy with us via your trade union body, as we can determine that you are a member of a trade union or where you specify certain medical treatments, this could indicate your religious beliefs.

How will we collect your personal data?

We will collect information directly from you:

• when you apply for or renew a policy;
• when we are providing you with a quotation;
• when you contact us by email, telephone and through other written and verbal communications; and
• when you contact our third party administrators by telephone (please note that call recording may be used).
   

As well as obtaining information directly from you, we will collect information from:

• The applicant where you are a beneficiary or named under an insurance policy;  
• Third parties involved in the insurance application process (such as our business partners and representatives, brokers or other insurers).
• Publically available sources such as the electoral roll, court judgments, insolvency registers, internet search engines, news articles and social media sites.
• Other Liberty Mutual Insurance Group companies.
• Credit reference agencies in relevant jurisdictions e.g. for example Equifax Spain and Experian Bureau de Crédito, S.A. are credit reference agencies in Spain.

From financial fraud detection agencies and databases and financial industry databases (such as fraud prevention and verification against international sanctions including the Total Loss, Theft and Fire File and the Miscellaneous Insurance Fraud Prevention File operated by UNESPA (Spanish Insurance Business Association)

What will we use your personal data for?

We may use your personal data for a number of different purposes, depending on your relationship with Liberty and the specific circumstances of the personal data processing. For each purpose for which we will use your personal data, we must have a "legal basis" to enable us to process it. We will rely on the following "legal bases" when we process your "personal data".

• We need to use your personal data to enter into or perform the insurance contract that we hold with you. For example, we need to use your personal data to provide you with a quote.
• We have a legal or regulatory obligation to use such personal data. For example, our regulators require us to hold certain records of our dealings with you, e.g. under the Spanish Insurance Contract Act and the money laundering and solvency laws.
• We need to use your personal data for a legitimate interest (e.g. to keep a record of the decisions we make when different types of applications are made, to keep business records, to carry out strategic business analysis, review our business planning and to develop and improve our products and services). When using your personal data for these purposes, we will always consider your rights and interests. 
• We need to use your personal data for reasons of public interest. For example, we may need to carry out investigations into fraudulent claims or money laundering.
• You have given your free, specific, informed and unequivocal consent to the processing of personal data.
   

When the information that we process is classed as “sensitive personal data", we must have an additional “legal ground". We will rely on the following legal grounds when we process your "sensitive personal data":

• We may need to use the special category of personal data for purposes arising from our insurance obligations where there is a substantial public interest in such use. Such purposes include assessing your application for insurance, handling claims and preventing and detecting fraud or analyzing the security of email content to detect cyber threats.
• We need to use such sensitive personal data to establish, exercise or defend legal rights.  This might happen when we are faced with legal proceedings or want to bring legal proceedings ourselves or when we are investigating a legal claim that a third party brings against you.
• You have provided your consent to our use of your sensitive personal data (e.g. in relation to your claim). In some circumstances, we may need your consent to process sensitive personal data (e.g. health information). Without it, we may be unable to offer you an insurance policy. We will always explain why your consent is necessary.
• We need to use such special category data for a justifiable public interest purpose on the basis of a legal requirement (e.g. security scanning of email contents to detect cyber threats)
• We need to use the special category of personal data when the processing is necessary for reasons of essential public interest in accordance with Article 9.2.g. of Regulation (EU) 2016/679, the Data Protection Act and Article 99 of the Act on the Regulation, Supervision and Solvency of Credit Institutions.

Who will we share your personal data with?

We will keep your personal data confidential and we will only share it where necessary for the purposes set out above with the following parties:

• Other Liberty Mutual Insurance Group companies (both inside and outside the European Economic Area) and their service providers.
• Third parties involved in the administration of your insurance application. These include surveyors, valuers and other experts.
• Other insurers (e.g. where another insurer has previous provided you with a policy or handled a claim).
• Insurance brokers and other intermediaries.
• Other insurers who provide our own insurance (reinsurers) and companies who arrange such reinsurance.
• Credit reference agencies in relevant jurisdictions, for example Equifax Spain and Experian Bureau de Crédito, S.A. are credit reference agencies in Spain.
• Third parties who provide sanctions checking services.
• Insurance industry bodies (including Cooperative Research between Insurance Companies and Pension Funds and Insurance Compensation Consortium).
• Financial crime detection agencies and insurance industry databases (as fraud prevention and verification against international sanctions including the Total Loss, Theft and Fire File and the Miscellaneous Insurance Fraud Prevention File operated by UNESPA (Spanish Insurance Business Association).
• Our regulators include the Directorate General of Insurance and Pension Funds, the UK Financial Conduct Authority, the UK Prudential Regulatory Authority, the Spanish Data Protection Agency and the Office of the Information Commissioner.
• If relevant, your policy details will also be added to the Motor Insurance Database (MID), run by the Motor Insurers’ Information Centre (MIIC).
• The police, HMRC and other crime prevention and detection agencies.
• Third party suppliers, agents and contractors appointed by Liberty Specialty Markets or the Liberty Mutual Group to help us carry out our everyday business activities including IT suppliers, actuaries, auditors, lawyers, document management providers, outsourced business process management providers, our subcontractors and tax advisers.
• Selected third parties in connection with any sale, transfer or disposal of our business.
• Any agent or representative acting for you.
• Any other person where necessary to perform any insurance contract with you, in order to protect ourselves from risk or to ensure regulatory compliance or good governance.

 

If you take out an insurance policy with us (e.g. a fine art policy) or if you are listed as an applicant or beneficiary under a policy that someone else has with us (such as a named director under a Directors & Officers policy), this section will be relevant to you and sets out our uses of your personal data.

What personal data will we collect?

• General information such as your name, address, contact phone numbers and email addresses, date of birth and gender.
• Information about your relationship to the policyholder where you are the beneficiary.
• Identification information such as passport details, driving licence and national insurance number.
• Your bank and payment details.
• If relevant, information about your job such as job title, employment history and professional accreditations.
• Any financial information about you which we have obtained as a result of conducting credit checks, such as bankruptcy orders, individual voluntary arrangements or county court judgments.
• Information which we obtain as part of checking sanctions lists, such as those published by United Nations, European Union, UK Treasury, the U.S. Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce, Bureau of Industry and Security.
• Any information which is relevant to your insurance application such as previous insurance policies you have held and claims you have made. This will also include any information specific to the type of policy you are applying for, for example, if you hold a property protection policy, we will collect and use information about your property or if you hold a fine art policy, we will collect and use information about your fine art or jewellery collection.
• Information (including photographic evidence) which is relevant to your policy or claim. For example, if you make a claim following damage to your property, we may use information relating to your property or if you make a claim following a road traffic accident, we may use personal data relating to your vehicle and named drivers.
• Information which we have gathered from publically available sources (including photographs) such as the electoral roll, newspapers and social media sites.
• Any other information passed on from you, your insurance broker or someone else applying on your behalf. 
• IP address obtained from online platforms.

What sensitive personal data will we collect?

• Details about your criminal convictions and any related information. This will include information relating to any offences or alleged offences you have committed or any court sentences which you are subject to.
• Details about your physical and mental health which are relevant to your policy or claim (e.g. if you are a pilot and take out or are covered by an aviation policy, we may need details of pre-existing medical conditions). This may take the form of medical reports or underlying medical data such as x-rays or blood tests.
• We may also collect information because it is relevant to your policy or claim, which reveals or is likely to reveal your race or ethnicity, religious or philosophical beliefs; political opinions; trade union membership; genetic or biometric data; or data concerning your sex life or sexual orientation. For example, we may process information relating to your trade union membership if you take out a policy with us via your trade union body, as we can determine that you are a member of a trade union or where you specify certain medical treatments, this could indicate your religious beliefs.

How will we collect your personal data?

We will collect information directly from you:

• when you apply for or renew a policy;
• when we are providing you with a quotation;
• when you make a claim on your policy;
• when you contact us by email, telephone and through other written and verbal communications;
• when you contact our third party administrators by telephone (please note that call recording may be used).
• when you make a complaint.
   

As well as obtaining information directly from you, we will collect information from:

• The named policyholder where you are a beneficiary.
• Third parties involved in the relevant insurance policy or claim (such as our business partners and representatives, brokers or other insurers, claimants, defendants or witnesses to an incident).
• Third parties who provide a service in relation to the relevant insurance policy or claim (such as loss adjusters, claims handlers, and medical experts).
• Publically available sources such as the electoral roll, court judgments, insolvency registers, internet search engines, news articles and social media sites.
• Other Liberty Mutual Insurance Group companies.
• Third parties who provide sanctions checking services.
• Insurance industry entities (including Cooperative Research between Insurance and Pension Funds and Insurance Compensation Consortium)
• From financial fraud detection agencies and databases and financial industry databases (such as fraud prevention and verification against international sanctions including the Total Loss, Theft and Fire File and the Miscellaneous Insurance Fraud Prevention File operated by UNESPA (Insurance Business Association).
• Our regulators include the Directorate General of Insurance and Pension Funds, the UK Financial Conduct Authority, the UK Prudential Regulatory Authority, the Spanish Data Protection Agency and the Office of the Information Commissioner.
• If relevant, your policy details will also be added to the Total Loss, Theft and Fire File and the Miscellaneous Insurance Fraud Prevention File operated by UNESPA (Spanish Insurance Companies Association).
• The police, the Tax Agency, the Executive Service of the Spanish Commission for the Prevention of Money Laundering and Monetary Offences (SEPBLAC), the Directorate General of Traffic (DGT) and other crime prevention and detection agencies.
• Third party suppliers we appoint to help us carry out our everyday business activities including IT suppliers, actuaries, auditors, lawyers, document management providers, outsourced business process management providers, our subcontractors and tax advisers.
• Selected third parties in connection with any sale, transfer or disposal of our business.

What will we use your personal data for? 

We may use your personal data for a number of different purposes.  In each case, we must have a "legal ground" to do so. We will rely on the following “legal grounds”, when we process your "personal data":

• We need to use your personal data to enter into or perform the insurance contract that we hold with you. For example, we need to use your personal data to provide you with a quote or to provide your insurance policy and other associated products (e.g. legal expenses cover). We will rely on this for activities such as assessing your application, managing your insurance policy, handling claims and providing other products to you.
• We have a legal or regulatory obligation to use such personal data. For example, our regulators require us to hold certain records of our dealings with you, e.g. under the Spanish Insurance Contract Act and the money laundering and solvency laws.
• We need to use your personal data for a legitimate interest (e.g. to properly investigate incidents which are the subject of a claim, to keep business records, to carry out strategic business analysis, review our business planning and to develop and improve our products and services). When using your personal data for these purposes, we will always consider your rights and interests. 

• We need to use your personal data for reasons of public interest. For example, we may need to carry out investigations into fraudulent claims or money laundering. 
• You have given your free, specific, informed and unambiguous consent to the processing of personal data.
   

When the information that we process is classed as “sensitive personal data", we must have an additional “legal ground". We will rely on the following legal grounds when we process your "sensitive personal data":

• We may need to use your sensitive personal data for purposes relating to an insurance policy or claim and there is a substantial public interest in such use. Such purposes include assessing your insurance application, managing claims and preventing and detecting fraud.
• We need to use such sensitive personal data to establish, exercise or defend legal rights.  This might happen when we are faced with legal proceedings or want to bring legal proceedings ourselves or when we are investigating a legal claim that a third party brings against you.
• You have provided your consent to our use of your sensitive personal data (e.g. in relation to your claim). In some circumstances, we may need your consent to process sensitive personal data (e.g. health information). Without it, we may be unable to provide your policy or handle claims. We will always explain why your consent is necessary. We will always explain why your consent is needed and the consequences of not giving us your explicit consent as well as the right you have to withdraw your consent as explained further in the "Your Rights" section of this notice.
• We need to use that special category of personal data that you have made manifestly public.
• We need to use the special category of personal data when it is necessary for reasons of essential public interest in accordance with Article 9.2.g. of Regulation (EU) 2016/679, the Data Protection Act and Article 99 of the Act on the Regulation, Supervision and Solvency of Credit Institutions.

 

 

Who will we share your personal data with?

We will keep your personal data confidential and we will only share it where necessary for the purposes set out above with the following parties.

• Other Liberty Mutual Group companies and their service providers (both inside and outside the European Economic Area).
• Third parties involved in the administration of the relevant insurance policy or claim. These include loss adjusters, claims handlers, private investigators, accountants, auditors, banks, lawyers and other experts including medical experts.
• Other insurers (e.g. where another insurer has previous provided you with a policy or handled a claim).
• Insurance brokers and other intermediaries.
• Other insurers who provide our own insurance (reinsurers) and companies who arrange such reinsurance.
• Credit reference agencies in relevant jurisdictions e.g.  Equifax Spain and Experian Bureau de Crédito, S.A. are credit reference agencies in Spain.
• Third parties who provide sanctions checking services.
• Insurance industry bodies (including the Employers’ Liability Tracing Office).
• Financial crime detection agencies and insurance industry databases (such as for fraud prevention and checking against international sanctions) including the Claims Underwriting Exchange (known as "CUE") operated by IDS and the Motor Insurance Anti-Fraud and Theft Register operated by the Association of British Insurers.
• Our regulators including the Financial Conduct Authority, the Prudential Regulation Authority and the Information Commissioner's Office.
• The police, HMRC and other crime prevention and detection agencies.
• If relevant, your policy details will also be added to the Motor Insurance Database (MID), run by the Motor Insurers’ Information Centre (MIIC).
• Third party suppliers, agents and contractors appointed by Liberty Specialty Markets or the Liberty Mutual Group to help us carry out our everyday business activities including IT suppliers, actuaries, auditors, lawyers, document management providers, outsourced business process management providers, our subcontractors and tax advisers.
• Selected third parties in connection with any sale, transfer or disposal of our business.
• Any agent or representative acting for you.
• Any other person where necessary to perform any insurance contract with you, in order to protect ourselves from risk or to ensure regulatory compliance or good governance.

If you make a claim against a third party who has an insurance policy with us, this section will be relevant to you and sets out our uses of your personal data.

What personal data will we collect? 

• General information such as your name, address, contact phone numbers and email addresses, date of birth and gender.
• Identification information such as passport details, driving licence and national insurance number.
• Your bank and payment details.
• If relevant to your claim, we may collect information about your job such as job title, employment history and professional accreditations.
• Information which we obtain as part of checking sanctions lists, such as those published by United Nations, European Union, UK Treasury, the U.S. Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce, Bureau of Industry and Security .
• Information relating to previous insurance policies you have held and claims you have made.
• Information (including photographic evidence) which is relevant to your claim. For example, if you make a claim following damage to your property, we may use information relating to your property or if you make a claim following a road traffic accident, we may use personal data relating to your vehicle and named drivers.
• Information which we have gathered from publically available sources such as the electoral roll, newspapers and social media sites.
• Any other information passed on from you, your representative or someone else making the claim on your behalf. 

What sensitive personal data will we collect?     

• Details about your criminal convictions and any related information allowed by the Spanish law. This will include information relating to any offences or alleged offences you have committed or any court sentences which you are subject to.
• Details about your physical and mental health which are relevant to your claim (e.g. because you have been injured whilst at a property insured by us). This may take the form of medical reports or underlying medical data such as x-rays or blood tests.
• We may also collect information because it is relevant to your claim, which reveals or is likely to reveal your race or ethnicity, religious or philosophical beliefs; political opinions; trade union membership; genetic or biometric data; or data concerning your sex life or sexual orientation. 

How will we collect your personal data?

We will collect information directly from you:

• when you make a claim;
• when you contact us by email, telephone and through other written and verbal communications;
• when you contact our third party administrators by telephone (please note that call recording may be used).
• when you make a complaint.
   

As well as obtaining information directly from you, we will collect information from:

• The party who holds a policy with us.
• Third parties involved in the insurance policy or claim (such as our business partners and representatives, brokers or other insurers, claimants, defendants or witnesses to an incident).
• Third parties who provide a service in relation to the claim (such as loss adjusters, claims handlers, and experts).
• Publically available sources such as the electoral roll, court judgements, insolvency registers, internet search engines, news articles and social media sites.
• Other Liberty Mutual Insurance Group companies.
• From financial fraud detection agencies and databases and financial industry databases (such as fraud prevention and verification against international sanctions including the Total Loss, Theft and Fire File and the Miscellaneous Insurance Fraud Prevention File operated by UNESPA (Insurance Business Association)
• Government agencies such as the police, the Tax Agency, the Executive Service of the Spanish Commission for the Prevention of Money Laundering and Monetary Offences (SEPBLAC), the Directorate General of Traffic (DGT) and other crime prevention and detection agencies.
• In limited circumstances, private investigators.
   

What will we use your personal data for?

We may use your personal data for a number of different purposes, depending on your relationship with Liberty and the specific circumstances of the processing of personal data. In each case, we must have a "legal ground" to do so. We will rely on the following “legal grounds”, when we process your "personal data":

• We have a legal or regulatory obligation to use such personal data. For example, our regulators require us to hold certain records of our dealings with you, e.g. under the Insurance Contract Act and the money laundering and solvency laws.
• We need to use your personal data for a legitimate interest (e.g. to properly investigate incidents which are the subject of a claim, to keep business records, to carry out strategic business analysis, review our business planning and to develop and improve our products and services). When using your personal data for these purposes, we will always consider your rights and interests. 
•  We need to use your personal data for reasons of public interest. For example, we may need to carry out investigations into fraudulent claims or money laundering.
• You have given your free, specific, informed and unequivocal consent to the processing of personal data.
   

When the information that we process is classed as “sensitive personal data", we must have an additional “legal ground". We will rely on the following legal grounds when we process your "sensitive personal data":

• In the UK, we need to use your sensitive personal data for purposes relating to an insurance policy or claim and there is a substantial public interest in such use. Such purposes include managing claims and preventing and detecting fraud or security analysis of email content to detect cyber threats.
• We need to use such sensitive personal data to establish, exercise or defend legal rights.  This might happen when we are faced with legal proceedings or want to bring legal proceedings ourselves or we are considering the claim that has been made against our policyholder.
• You have given your explicit consent to use the special category of personal data e.g. in connection with a complaint. On some occasions, we may need your explicit consent to process a special category of personal data. We will always explain to you why your consent is needed and the consequences of not giving us your explicit consent as well as the right you have to withdraw your consent as explained further in the "Your Rights" section of this notice.
• We need to use that special category of personal data that you have made manifestly public.
• You have provided your consent to our use of your personal data. In some circumstances, we may need your consent to process sensitive personal data (e.g. health information). Without it, we may be unable to handle your claims. We will always explain why your consent is necessary.
• We need to use the special category of personal data when the processing is necessary for reasons of essential public interest in accordance with Article 9.2.g. of Regulation (EU) 2016/679, the Data Protection Act and Article 99 of the Act on the Regulation, Supervision and Solvency of Credit Institutions.

Who will we share your personal data with?

We will keep your personal data confidential and we will only share it where necessary for the purposes set out above with the following parties.

• Other Liberty Mutual Insurance Group companies (both inside and outside the European Economic Area) and their service providers.
• Third parties involved in the administration of your claim such as loss adjusters, claims handlers, private investigators, accountants, auditors, banks, lawyers and other experts including medical experts.
• Other insurers (e.g. where another insurer is also involved in a claim that you are making).
• Insurance brokers and other intermediaries.
• Other insurers who provide our own insurance (reinsurers) and companies who arrange such reinsurance.
• Insurance industry bodies (including the Employers’ Liability Tracing Office).
• Third parties who provide sanctions checking services.
• Insurance industry bodies (including the Employers’ Liability Tracing Office).
• Financial crime detection agencies and insurance industry databases (such as for fraud prevention and checking against international sanctions) including the Claims Underwriting Exchange (known as "CUE") operated by IDS and the Motor Insurance Anti-Fraud and Theft Register operated by the Association of British Insurers.
• Our regulators including the Financial Conduct Authority, the Prudential Regulation Authority and the Information Commissioner's Office.
• The police, HMRC and other crime prevention and detection agencies.
• If relevant, your policy details will also be added to the Motor Insurance Database (MID), run by the Motor Insurers’ Information Centre (MIIC).
• Third party suppliers, agents and contractors appointed by Liberty Specialty Markets and the Liberty Mutual Group to help us carry out our everyday business activities including IT suppliers, actuaries, auditors, lawyers, document management providers, outsourced business process management providers, our subcontractors and tax advisers.
• Selected third parties in connection with any sale, transfer or disposal of our business.
• Any agent or representative acting for you.
• Any other person where necessary to perform any insurance contract with you, in order to protect ourselves from risk or to ensure regulatory compliance or good governance.

If you are a witness to an incident which is the subject of a claim, this section will be relevant to you and sets out our uses of your personal data.

What personal data will we collect?            

• General information such as your name, address, contact phone numbers and email addresses, date of birth and gender.
• Information relevant to the incident that you have witnessed.

What sensitive personal data will we collect?             

It is not standard practice to collect special category data of witnesses to an accident. However, if you are involved in the accident and your details are supplied to us (for example, within a medical report) we might process your sensitive personal data.

How will we collect your information? 

As well as obtaining information directly from you, we will collect information from:

• Third parties involved in the incident you witnessed (such as brokers or other insurers, claimants, defendants or other witnesses).
• Other third parties who provide a service in relation to the claim which relates to the incident you witnessed (such as loss adjusters, claims handlers, and experts).
• Publically available sources such as the electoral roll, court judgments, insolvency registers, insurance industry databases, internet search engines, news articles and social media sites.
• Other companies within the Liberty Mutual Insurance Group.

What will we use your personal data for?

We may use your personal data for a number of different purposes, depending on your relationship with Liberty and the specific circumstances of the processing of personal data. In each case, we must have a "legal ground" to do so. We will rely on the following “legal grounds”, when we process your "personal data":

• We have a legal or regulatory obligation to use such personal data. For example, our regulators require us to hold certain records of our dealings with you, e.g. under the Insurance Contract Act and the money laundering and solvency laws.
• We need to use your personal data for a legitimate interest (e.g. to properly investigate incidents which are the subject of a claim, to keep business records, to carry out strategic business analysis, review our business planning and to develop and improve our products and services). When using your personal data for these purposes, we will always consider your rights and interests. 
•  We need to use your personal data for reasons of public interest. For example, we may need to carry out investigations into fraudulent claims or money laundering.
• You have given your free, specific, informed and unequivocal consent to the processing of personal data.
   

When the information that we process is classed as “sensitive personal data", we must have an additional “legal ground". We will rely on the following legal grounds when we process your "sensitive personal data":

• In the UK, we need to use your sensitive personal data for purposes relating to an insurance policy or claim and there is a substantial public interest in such use. Such purposes include managing claims and preventing and detecting fraud or security analysis of email content to detect cyber threats.
• We need to use such sensitive personal data to establish, exercise or defend legal rights.  This might happen when we are faced with legal proceedings or want to bring legal proceedings ourselves or we are considering the claim that has been made against our policyholder.
• You have given your explicit consent to use the special category of personal data e.g. in connection with a complaint. On some occasions, we may need your explicit consent to process a special category of personal data. We will always explain to you why your consent is needed and the consequences of not giving us your explicit consent as well as the right you have to withdraw your consent as explained further in the "Your Rights" section of this notice.
• We need to use that special category of personal data that you have made manifestly public.
• We need to use the special category of personal data when the processing is necessary for reasons of essential public interest in accordance with Article 9.2.g. of Regulation (EU) 2016/679, the Data Protection Act and Article 99 of the Act on the Regulation, Supervision and Solvency of Credit Institutions.

Who will we share your personal data with?

We will keep your personal data confidential and we will only share it where necessary for the purposes set out above with the following parties:

• Other Liberty Group companies.
• Third parties involved in the administration of an insurance policy or claim. These include loss adjusters, claims handlers, private investigators, accountants, auditors, banks, lawyers and other experts including medical experts.
• Other insurers (e.g. where another insurer is also involved in the claim which relates to the incident you witnessed).
• Insurance brokers and other intermediaries.
• Other insurers who provide our own insurance (reinsurers) and companies who arrange such reinsurance.
•  Of credit reference agencies in the relevant jurisdictions, for example Equifax Spain and Experian Bureau de Crédito, S.A. are credit reference agencies in Spain.
• Third parties that provide us with sanction verification services. 
• Insurance industry entities (including Cooperative Research between Insurance Companies and Pension Funds and Insurance Compensation Consortium).
• From financial fraud detection agencies and databases and financial industry databases (such as fraud prevention and verification against international sanctions including the Total Loss, Theft and Fire File and the Miscellaneous Insurance Fraud Prevention File operated by UNESPA (Asociación Empresarial del Seguro)
•  Our regulators include the Directorate General of Insurance and Pension Funds, the UK Financial Conduct Authority, the UK Prudential Regulatory Authority, the Spanish Data Protection Agency and the Office of the Information Commissioner.
• If relevant, your policy details will be added to the Total Loss, Theft and Fire File and the Miscellaneous Insurance Fraud Prevention File operated by UNESPA (Asociación Empresarial del Seguro).
• The police, the Tax Agency, the Executive Service of the Spanish Commission for the Prevention of Money Laundering and Monetary Offences (SEPBLAC), the Directorate General of Traffic (DGT) and other crime prevention and detection agencies.
• Vendors, agents and contractors appointed by Liberty Specialty Markets or the Liberty Mutual Group to assist us in conducting our day-to-day business activities, including computer vendors, actuaries, auditors, attorneys, document management vendors, perpetual business process management vendors, our subcontractors and tax advisors
• Selected third parties in connection with any sale, transfer or disposition of our business advisors.
• Any agent or representative acting for you.
• Any other person in order to protect us from risk or to ensure regulatory compliance or good governance.

If you are a broker doing business with us, an appointed representative or other business partner such as an introducer or supplier, this section will be relevant to you and sets out our uses of your personal data.

What personal data will we collect?     

• General information such as your name, address, contact phone numbers and email addresses, date of birth and gender.
• Identification information such as passport details, driving licence and national insurance number.
• Information about your job such as job title and previous roles.
• Information which we obtain as part of checking sanctions lists, such as those published by United Nations, European Union, UK Treasury, the U.S. Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce, Bureau of Industry and Security .
• Other information (including publically available information) obtained as part of our due diligence checks.
• If you attend an event with us, we may collect relevant details such as your event preferences and dietary requirements.

What sensitive personal data will we collect? 

• Information relating to your criminal convictions (including offences and alleged offences and any court sentence or unspent criminal convictions), allowed by the Spanish law.
• If you attend an event with us, we may collect dietary requirements which could indicate a health condition or religious belief

How will we collect your information? 

As well as obtaining information directly from you, we will collect information from:

• Invoices, contracts, policies, correspondence and business cards
• Other Liberty Mutual Insurance Group companies.
• Publically available sources such as internet search engines.
• From service providers who carry out sanctions checks.
   

What will we use your personal data for? 

We may use your personal data for a number of different purposes.  In each case, we must have a "legal ground" to do so. We will rely on the following “legal grounds”, when we process your "personal data":

• We need to use your personal data to enter into or perform the contract that we hold with you. For example, we may need certain information in order to operate our business partnership arrangement.
• We have a legal or regulatory obligation to use such personal data. For example, we may be required to carry out certain background checks.
• We need to use your personal data for a legitimate interest (e.g. to keep business records, to carry out strategic business analysis, review our business planning and to develop and improve our products and services). When using your personal data for these purposes, we will always consider your rights and interests. 
• We need to use your personal data for reasons of public interest. For example, we may need to carry out investigations into fraudulent claims or money laundering.
• - You have given your free, specific, informed and unambiguous consent to the processing of personal data.
   

When the information that we process is classed as “sensitive personal data", we must have an additional “legal ground". We will rely on the following legal grounds when we process your "sensitive personal data":

• We need to use your sensitive personal data for purposes relating to an insurance policy or claim and there is a substantial public interest in such use. Such purposes include assessing an insurance application, managing claims and preventing and detecting fraud.
• We need to use your sensitive personal data to establish, exercise or defend legal rights. This might happen when we are faced with legal proceedings or want to bring legal proceedings ourselves.
• You have given your explicit consent to use the special category of personal data e.g. in connection with a complaint. On some occasions, we may need your explicit consent to process a special category of personal data. We will always explain to you why your consent is needed and the consequences of not giving us your explicit consent as well as the right you have to withdraw your consent as explained further in the "Your Rights" section of this notice.
• We need to use that special category of personal data that you have made manifestly public.
• We need to use the special category of personal data when the processing is necessary for reasons of substantial public interest in accordance with Article 9.2.g. of Regulation (EU) 2016/679, the Data Protection Act and Article 99 of the Act on the Regulation, Supervision and Solvency of Credit Institutions.

Who will we share your personal data with?

We will keep your personal data confidential and we will only share it where necessary for the purposes set out above with the following parties:

• Our policyholders and other third parties such as claimants where relevant.
• Other Liberty Mutual Insurance Group companies.
• Third parties involved in the administration of an insurance policy or claim. These include loss adjusters, claims handlers, private investigators, accountants, auditors, banks, lawyers and other experts including medical experts.
• Our insurance partners such as other brokers and insurers.
• Other insurers who provide our own insurance (reinsurers) and companies who arrange such reinsurance.
• Third parties who provide sanctions checking services.
• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers.
• Our regulators including the Financial Conduct Authority and the Prudential Regulation Authority.
• The police, HMRC and other crime prevention and detection agencies.
• If relevant, your policy details will also be added to the Motor Insurance Database (MID), run by the Motor Insurers’ Information Centre (MIIC).
• Third party suppliers, agents and contractors appointed by Liberty Specialty Markets or the Liberty Mutual Insurance Group to help us carry out our everyday business activities including IT suppliers, actuaries, auditors, lawyers, document management providers, client relationship system providers, outsourced business process management providers, our subcontractors and tax advisers.
• Selected third parties in connection with any sale, transfer or disposal of our business.
• Any agent or representative acting for you.
• Any other person where necessary to perform any insurance contract , in order to protect ourselves from risk or to ensure regulatory compliance or good governance.

 

If you are a user of the Liberty Specialty Markets website (or a platform that links through to this Notice), this section will be relevant to you and sets out our uses of your personal data.

What personal data will we collect?   

• General information submitted via the website or platform, for example where you provide your details in the contact section such as your name, contact details and company name.
• Information obtained through our use of cookies. You can find more information about this in our cookies policy in the Cookies section below.
• Information obtained through a sign up form for an event or promotion.

What sensitive personal data will we collect? 

We do not anticipate collecting special category data through the website. However, where relevant, we may collect dietary requirements for an event or you might submit special category data through a query or complaint.

How will we collect your personal data? 

 

In addition to obtaining information directly from you, we will collect information from:

• We will collect your information directly from our website or a platform that links you through to our website.
• Our websites may also collect your device's unique identifier, such as an IP address.

What will we use your personal data for?

We may use your personal data for a number of different purposes.  In each case, we must have a "legal ground" to do so. We will rely on the following “legal grounds”, when we process your "personal data":

• We need to use your personal data to enter into or perform the insurance contract that we hold with you. For example, we need to use your personal data to respond to your enquiry about a quote.
• We have a legal or regulatory obligation to use such personal data. For example, our regulators require us to hold certain records of our dealings with you.
• We need to use your personal data for a legitimate interest (e.g. to monitor the number of visitors to our website, to keep business records and to develop and improve our products and services). When using your personal data for these purposes, we will always consider your rights and interests. 
• We need to use your personal data for reasons of public interest. For example, we may need to carry out investigations into fraudulent claims or money laundering.
• You have given your free, specific, informed and unambiguous consent to the processing of personal data.
   

When the information that we process is classed as “sensitive personal data", we must have an additional “legal ground". We will rely on the following legal grounds when we process your "sensitive personal data":

• We need to use your sensitive personal data for purposes relating to an insurance policy or claim and there is a substantial public interest in such use. Such purposes include assessing an insurance application, managing claims and preventing and detecting fraud.
• We need to use your sensitive personal data to establish, exercise or defend legal rights. This might happen when we are faced with legal proceedings or want to bring legal proceedings ourselves.
• You have given your explicit consent to use the special category of personal data e.g. in connection with a complaint. On some occasions, we may need your explicit consent to process a special category of personal data. We will always explain to you why your consent is needed and the consequences of not giving us your explicit consent as well as the right you have to withdraw your consent as explained further in the "Your Rights" section of this notice.
• We need to use that special category of personal data that you have made manifestly public.
• We need to use the special category of personal data when the processing is necessary for reasons of substantial public interest in accordance with Article 9.2.g. of Regulation (EU) 2016/679, the Data Protection Act and Article 99 of the Act on the Regulation, Supervision and Solvency of Credit Institutions.

Who will we share your personal data with?

We will keep your personal data confidential and we will only share it where necessary for the purposes set out above with our Liberty Mutual Insurance Group companies, our agents or contractors.

If you are applying for a job with us, this section will be relevant to you and sets out our uses of your personal data.

What personal data will we collect? 

• General information such as your name, address, contact phone numbers and email addresses, date of birth and gender.
• Information about your job such as job title and previous roles.
• Qualifications and academic results.
• Information about your right to work
• Other information (including publically available information) obtained as part of our due diligence checks.
• In the event you attend events with us, we may collect relevant details e.g. your event preferences, dietary requirements etc.

What sensitive personal data will we collect?   

• Information relating to your criminal convictions (including offences and alleged offences and any court sentence or unspent criminal convictions), if allowed by the Spanish law.
• If you attend an event with us, we may collect dietary requirements that could indicate a health condition or religious belief. If your resume contains a union membership, this information will be collected.

How will we collect your information? 

As well as obtaining information directly from you, we will collect information from service providers e.g. recruitment companies you have instructed.

Note, if you email us your CV or speculative application we will store it in our recruitment portal for 3 years unless you object.

What will we use your personal data for? 

We may use your personal data for a number of different purposes, depending on your relationship with Liberty and the specific circumstances of the personal data processing. For each purpose for which we will use your personal data, we must have a "legal basis" to enable us to process it. We will rely on the following "legal bases" when we process your "personal data".

• We need to use your personal data to enter into or perform the insurance contract that we hold with you. For example, we need to use your personal data to provide you with a quote.
• We have a legal or regulatory obligation to use such personal data. For example, our regulators require us to hold certain records of our dealings with you, e.g. under the Spanish Insurance Contract Act and the money laundering and solvency laws.
• We need to use your personal data for a legitimate interest (e.g. to keep your CV registered for future opportunities). When using your personal data for these purposes, we will always consider your rights and interests. 
• You have given your free, specific, informed and unequivocal consent to the processing of personal data.
   

When the information that we process is classed as “sensitive personal data", we must have an additional “legal ground". We will rely on the following legal grounds when we process your "sensitive personal data":

• We need to use your personal data for public interest reasons based on a legal requirement (e.g. security analysis of email contents to detect cyber threats).
• You have provided your consent to our use of your sensitive personal data (e.g. in relation to your claim). In some circumstances, we may need your consent to process sensitive personal data (e.g. health information). Without it, we may be unable to offer you an insurance policy. We will always explain why your consent is needed and the consequences of not giving us your explicit consent as well as the right you have to withdraw your consent as explained further in the "Your Rights" section of this notice.
• We need to use such special category data for a justifiable public interest purpose on the basis of a legal requirement (e.g. security scanning of email contents to detect cyber threats)
• We need to use the special category of personal data when the processing is necessary for reasons of essential public interest in accordance with Article 9.2.g. of Regulation (EU) 2016/679, the Data Protection Act and Article 99 of the Act on the Regulation, Supervision and Solvency of Credit Institutions.

Who will we share your personal data with?

We will keep your personal data confidential and we will only share it where necessary for the purposes set out above with the following parties:

• Other Liberty Mutual Insurance Group companies (both inside and outside the European Economic Area) and their service providers.
• Third parties involved in the hosting, analysis and supply of recruitment services
• Credit reference agencies in the relevant jurisdictions, for example Equifax Spain and Experian Bureau de Crédito, S.A. are credit reference agencies in Spain.
• Our regulators include the Directorate General of Insurance and Pension Funds, the UK Financial Conduct Authority, the UK Prudential Regulatory Authority, the Spanish Data Protection Agency and the Office of the Information Commissioner.
• The police, the Tax Agency, the Executive Service of the Spanish Commission for the Prevention of Money Laundering and Monetary Offences (SEPBLAC), the Directorate General of Traffic (DGT) and other crime prevention and detection agencies.
• Vendors, agents and contractors appointed by Liberty Specialty Markets or the Liberty Mutual Group to assist us in conducting our day-to-day business, including computer vendors, actuaries, auditors, attorneys, document management vendors, perpetual business process management vendors, our subcontractors and tax advisors
• Selected third parties in connection with any sale, transfer or disposal of our business.
• Any agent or representative acting for you.

A select group of third party suppliers used to host and manage our recruitment portals (based in the USA)

Marketing:

We will only send marketing communications to our business contacts. This may be done by post, email or telephone. In most cases, we will only send you marketing communications for which you have clearly expressed your consent and therefore interest in receiving.

On other occasions, we will process your personal data to provide you with business information based on our legitimate business interests and the relationship we have with you as a customer.

However, if you wish to opt-out of receiving further marketing communications - by opting out of our processing your personal data for this purpose or by withdrawing your initial consent - you may do so by contacting us using the details set out in section 10 (Contacting Us).

Profiling:

Profiling is integral to the offering of insurance. We assess the risk that you would like to insure (e.g. the risk of your home being damaged by a flood) against the likelihood of that event occurring (e.g. based on the geographical location of your property and history of floods in the area). We use this profiling to help us decide whether or not to offer you insurance, the terms and the price of your policy.

Whilst we use profiling to help us make our decisions, it is always a member of our team who makes a decision taking into account the profiling outcome and other relevant factors.

We will keep your personal data for as long as reasonably necessary to fulfil the purposes set out in section 3 above and to comply with our legal and regulatory obligations.  

We have a detailed data retention policy that determines how long we will retain different types of personal data. The exact period of time for which we retain your personal data will depend on your relationship with us and the type of personal information we hold, for example, we will keep your data for a longer period if legal proceedings are underway.

If you would like further information regarding the periods for which your personal data will be stored, please contact us using the details set out in section 10 (Contact us). 

From time to time, Liberty (or third parties acting on our behalf) may need to share your personal data we collect from you with countries outside the European Economic Area ("EEA"). These will be transferred to fulfil the purposes set out in section 3 of this Privacy Notice (How we process your personal data and special categories of personal data).

In accordance with data protection laws, we will only make international transfers of personal data to countries considered appropriate by the European Commission, an organization with Binding Corporate Rules, where a Data Protection Regulator has granted prior authorization or the use of a permitted method of transfer (e.g. standard contract terms) as set out below. When we make a transfer of your personal data outside the EEA, we will take steps to ensure that your personal data is protected. These measures may include the following methods:

• putting in place appropriate contracts. We will use a set of contract wording known as the "standard contractual clauses" which has been approved by the data protection authorities.

Depending on our relationship and your particular circumstances, we might transfer personal data anywhere in the world. For example, if you have a personal accident policy with us and are injured, we may need to instruct medical experts or other service providers in the country you are injured in. A summary of our regular data transfers outside the EEA is set out below:

If you would like further information regarding our data transfers and the steps we take to safeguard your personal data, please contact us using the details set out in section 10 (Contact us). 

Liberty Specialty Markets takes security of your information very seriously. We maintain appropriate technical, organisational, and physical safeguards designed to protect the personal data we process in accordance with client instructions and in line with our legal and regulatory obligations. The security measures in place on our website and computer systems are in place to protect the loss, misuse or alteration of the information you provide to us. We keep your personal data only for as long as reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.

The Liberty Mutual Group has a number of Information Security Standards that apply depending on the data type and data location. These standards cover access controls, encryption, network and host security, physical security, data recovery and business continuity. Our standards change from time to time as we react to market challenges and changing regulatory requirements.

Because e-mails submitted via this website are not protected by the same security measures we use in other areas where we actively collect information, you should be particularly careful in deciding what information you wish to send to us via e-mail.
In the event that you become aware of any actual or potential misuse of any such information or for more information on IT Security please contact us using the details set out in section 10.

If you would like more information about the steps we take to safeguard your personal data, please contact us using the contact details set out in section 10 Contact Us.  

In accordance with data protection regulations, you have numerous rights in relation to the processing of your personal data. Without prejudice to the information provided in details below, you have the right to: access your personal data, rectify any inaccuracies or deficiencies, have them deleted, limit the processing of your data, have them made available to you, object to their processing, withdraw the consent you have given to the processing of your data, have your data not subject to an automated decision including profiling, be informed of the safeguards applicable to the international transfer of your data and file a complaint with the competent supervisory authority for the protection of personal data.

You may exercise these rights at any time by contacting us using the contact details listed in section 10 Contact Us.  

Please note the following issues relating to the exercise of your rights:

• Identity: Because of the guarantee of confidentiality with which Liberty treats your personal data, we may on occasion require proof or confirmation of your identity when you make a request to exercise any of your rights.
• Response time: We undertake to process your application as soon as possible and, in general, within a maximum of one month from the date we receive it. However, depending on the complexity of your request or if you have made several requests, this period may be extended by a further two months - in which case we will inform you of this delay and the reasons for it.
• Inability to comply with your request: Please note that while we take your rights very seriously, in some cases, we may not be able or reasonable to comply with your request (for example, when there is a conflict with our own legal or regulatory obligations or when your request is manifestly unfounded or excessive). However, we will always respond to any request you make and if we cannot comply with your request, we will tell you why within one month of receiving it. Furthermore, in this case, we will inform you of the possibility of lodging a complaint with the appropriate data protection supervisory authority and of taking legal action.
• Observations related to the exercise of your rights and the provision of our services: The information we provide you with, as well as any communication and any action taken in the exercise of your rights, will be free of charge. However, where your request is manifestly unfounded or excessive, in particular due to its repetitive nature, we will charge you a reasonable fee (of which we will inform you before completing your request) based on the administrative costs that we are obliged to incur in order to carry out the requested action.
   

• The right to access your personal data 

You are entitled to a copy of the personal data we hold about you and certain details of how we use it, specifically:

o What kind of data do we have

o What we use them for

o Who we will share your data with

o How long will we keep them

o What rights do you have with regard to your personal data

o How you can file a claim

o Where or who provided us with your data if you did not provide them

o If we have made any automated decisions - including profiling - based on your personal data

o The guarantees applicable to international data transfers of your personal data

We will usually provide your personal data to you in writing unless you request otherwise. Where your request has been made electronically (e.g. by email), a copy of your personal data will be provided to you by electronic means where possible.

• The right to rectification 

We take reasonable steps to ensure that the information we hold about you is accurate and where necessary up to date and complete. If you believe that there are any inaccuracies, discrepancies or gaps in the information we hold about you, you can contact us and ask us to update or amend it.

You must indicate in your application what data you are referring to and the correction to be made. It shall be accompanied, where necessary, by documentation proving the inaccuracy or incompleteness of the data processed.

• The right to restriction of processing 

In certain circumstances, you are entitled to ask us to stop using your personal data, for example where you think that the personal data we hold about you may be inaccurate or where you think that we no longer need to use your personal data. 

You have the right to ask us to limit the processing of your personal data (i.e. to keep it but not to use it) in the following circumstances:

o When you exercise your right to rectify your personal data, for as long as is necessary for us to verify its accuracy; or

o When the processing is unlawful, but you do not wish to exercise your right to Suppression; or

o When your personal data are no longer necessary for the purposes for which they were collected, but are required to initiate, exercise or defend legal proceedings; or

o When you have exercised your right to object to the processing of your personal data, for the time necessary to verify whether our legitimate interests would prevail over your right.

If you have successfully exercised your right to limit the processing of your personal data, we will inform you in due course before the limitation is lifted.

However, even if you have successfully exercised your right to Limitation, we may continue to use your personal data when

o We have your consent; or

o For the purpose of formulating, exercising or defending claims; or

o To protect the rights of another person or entity; or

For reasons of substantial public interest

• The right to withdraw your consent 

We will rely on obtaining your consent (sometimes explicitly) to process your personal data, you will have the right to withdraw your consent at any time so that we do not use your personal data in the future.

Please note that for some of the purposes indicated in section 3 (How we process your personal data and special categories of personal data), we will need your consent in order to continue to provide you with insurance-related services. If you withdraw your consent, we may have to cancel your policy or we may not be able to pay your claims. We will advise you of this circumstance and all possible consequences at the time you request to withdraw your consent.

• The right to object 

In certain circumstances, you have the right to ask us to stop using your personal information, for example, when you believe that personal information we hold about you may be incorrect or when you believe that we no longer need to use your personal information.

You may exercise your right to object at any time, on grounds relating to your particular situation, to any processing of your personal data which has a legal basis in our "legitimate interests", if you believe that your fundamental rights and freedoms prevail over our legitimate interests.

Once you have objected to the processing, we may continue to process your personal data if we are able to demonstrate that we have legitimate interests which prevail over your rights and freedoms or that, despite your objection, Liberty needs to process your personal data for the formulation, exercise or defence of claims.

• The right to erasure 

Sometimes known as the right to be forgotten. In certain circumstances, you have the right to request that we delete (erase) your personal data. In particular, you can ask us to delete your personal data only if:

o They are no longer necessary for the purposes for which they were collected;

o You have withdrawn your consent (where the processing of the data was based on consent); or

o Once you have obtained the right to object; or

o Your personal data has been unlawfully processed; or

o In order to comply with a legal obligation imposed on Liberty.

However, we will not be obliged to comply with your request for the deletion of your personal data if it is necessary to process your personal data for:

o Compliance with a legal obligation; or

o Formulating, exercising or defending claims; or

o Exercising the right to freedom of expression and information

In addition to the above, there are other circumstances in which we are not required to comply with your request for removal. If you would like more information about this, please contact us using the contact details in section 10 Contact Us.

• The right to oppose the processing of your data for marketing purposes 

 

As noted in Section 4, you have control over the extent to which we send you marketing materials and you have the right to request that we stop sending you advertising messages at any time. You can request this by clicking the "unsubscribe" button in any email we send you or you can contact us using the contact details in Section 10 Contact Us.

Please note that even if you exercise this right because you do not want to receive marketing messages, we may still send you service related communications where necessary.

Processing based on our legitimate interests: Where we process your personal data based on our legitimate interests, you can object to our processing. We will consider your objection and determine whether or not our legitimate interests prejudice your privacy rights.

• The right to data portability

You have the right to request that we transfer personal data provided to us by a third party. However, you will only be entitled to the Portability when:

o We are processing your personal data on the basis of the consent you have given us, or

o We are processing your personal data on the basis of entering into or fulfilling a contract with you, and

o Processing is carried out by automated means

• Rights relating to automated decision-making 

We do not routinely carry out any automated decision making. If this changes in the future, we will provide you with an updated notice setting out our decision making process.

• The right to file a complaint or claim with the Spanish Data Protection Agency or the relevant competent authority 

 

You have the right to file a complaint or claim with the Spanish Data Protection Agency, the Information Commissioner's Office or any other local Personal Data Authority if you believe that the use of your personal information by us violates applicable data protection laws and regulations. Further information can be found on the website of the Spanish Data Protection Agency: https://www.agpd.es

Filing a complaint or claim with the Spanish Data Protection Agency will not affect any other rights or legal action you may have. 

 

By accessing and using this website you indicate that you accept Liberty Specialty Market’s use of cookies.

The website uses cookies which are small files of letters and numbers that Liberty Specialty Markets puts on your computer if you allow it. After your visit to the website, the cookies will remember your language selection during your visit. They also allow us to recognise and count the number of visitors and to see how visitors move around the site. Some of the cookies are required to provide you with access to the website and to make your browsing experience more user-friendly.
This website may link through to third party websites (including websites of companies within the Liberty Mutual Insurance Group) which may also use cookies over which we have no control. We recommend that you check the relevant third parties’ privacy policies for information about any cookies that they may use.
You can configure your web browser to refuse cookies, to delete cookies, or to be informed if a cookie is set. The “Help” section on the menu bar of most internet browsers will tell you how to do so. You may delete and block all cookies but, if you do so, our website may not function correctly and you may not be able to access certain areas. For more information about cookies and how to delete them, visit http://www.allaboutcookies.org/.

If you want to know more about the cookies we use on this website please click here.

If you would like further information about any of the matters in this notice or if have any other questions about how we collect, store or use your personal data, you may contact our Data Protection Officer at dataprotectionofficer@libertyglobalgroup.com or by writing to Data Protection Officer, Liberty Specialty Markets, 20 Fenchurch Street, London, EC3M 3AW or click here.

Please note that we are not responsible for the privacy policies or content of any websites linked to this website, (including websites of companies within the Liberty Mutual Insurance Group).

From time to time we may need to make changes to this notice, for example, as the result of changes to law, technologies, or other developments. We will provide you with the most up-to-date notice and you can check our website here periodically to view it.

This notice was last updated on 9 December 2020.