1. INTRODUCTION

Kentro Capital respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data which you provide to us, or which we obtain, when providing services to you, when you use one of our websites, or when we deal with you in the course of our business.

This policy applies to personal data we hold relating to policyholders, brokers, professional contacts and other third parties. Depending on who you are, and how you interact with us, only some aspects of this policy may apply to you.

Who are Kentro Capital?

References to Kentro Capital refer to the applicable entities of Kentro Capital Limited. Registered in England and Wales number: 07055303. Registered office: 52-56 Leadenhall St, London EC3A 2EB. For more information, please visit www.kentrocapital.com or see our Regulatory page.

Changes to this policy

We may update this privacy policy from time to time – you can find our latest policy on our website at www.nexusunderwriting.com/privacy-policy or by asking us for a copy.

2. IMPORTANT INFORMATION

Kentro Capital is the controller and responsible for your personal data.

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.

Our full contact details are as follows:

Address: Kentro Capital, 52-56 Leadenhall Street, London, EC3A 2EB
Telephone Number: 0203 011 5700
Email address: compliance@nexusunderwriting.com

Third party links

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

3. THE DATA WE COLLECT ABOUT YOU

We collect, use, store and transfer the following data:

Identity and Contact Data: personal and identity data, including your names, date of birth, email address, postal address, telephone number(s), copies of passports and ID, national insurance number;
Financial Data: including details of your bank accounts, tax records, annual reports and accounts, management accounts, credit scores, claims history, premium finance, credit card details
Claims Data: Past and current claims experience, accompanying detailed information supporting past or present claims, medical reports, loss adjusters reports, legal opinions, credit reports
Insurance Data: details of the insurance policies you take out and details of the services we provide to you
Employment Data: your employment history and qualifications
Profile Data: Passwords and login details for online accounts
Technical Data: information we collect automatically when you visit our websites, including your IP address, how you use our site and the pages you visit, browser details, and device details
Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.

Special Category Data

We may also collect, store and use the following special categories of personal data:

Information about your health, including any medical condition, health and sickness records, and medical records and reports;
Details of criminal convictions and offences.
Details of your ethnicity, sexual orientation, gender and political or religious affiliations which may be divulged to us in the course of dealing with a claim or other matter. We do not seek or use this information in the normal course of our business.

Details of how we use this information are set out in section 6.

Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Technical Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Failure to provide data

Where we need to collect personal data by law, or under the terms of a contract we have with you, or in order to incept a policy for you or your client, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you, or to carry out the functions you are asking us to. In this case, we may have to cancel a policy or service you have.

4. HOW WE COLLECT YOUR DATA

We collect your data from different sources:

We collect all the types of data listed above directly from you when you interact with us;
We collect Identity and Contact Data, Financial Data, Special Categories of data, Claims Data and Insurance Data from professionals and others providing you with services, including your broker, accountant, financial advisor, solicitor, or bank.
We collect some personal data from third party search providers, such as details about criminal convictions, and some Financial Data from debt management and collection agencies.
We collect data from publicly available sources, and third-party databases, such as newspapers, and business data repositories.
We carry out searches against anti-fraud databases and other third-party databases, such as sanctions lists, and if your details are on such lists, we will receive personal information, including information about possible criminal convictions or offences.
We collect Technical Data automatically when you interact with our website, by using cookies and other similar technologies.
We may record telephone calls to use for training purposes, to improve our services & their delivery, to deal with complaints or other queries and for quality assurance.

5. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details above if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Lawful basis for processing including basis of legitimate interest
To register you as a user on one of our websites	Necessary for our legitimate interests (to assist policy holders in requesting and managing policies online)
To provide services to you and carry out your instructions in connection with our services.	Performance of a contract with you
To make decisions on whether to issue a policy of insurance to you, and to calculate the appropriate premium. In certain circumstances, we may decline to issue a policy of insurance to you because of data we have collected from third party sources (e.g. government sanctions lists, or data about your criminal convictions)	Performance of a contract with you; Necessary for our legitimate interests (to determine appropriate persons to issue policies of insurance to, and to determine appropriate insurance premiums; to comply with the terms of authority granted to us by insurance companies).
To share information with your broker and other professional advisors for the purposes of them providing services to you	Necessary for the legitimate interests of a third party (to allow your advisors to provide services to you).
To administer policies of insurance underwritten by us, including the transfer and receipt of premiums and commissions	Necessary for our legitimate interests (to carry out the services we are contractually required to provide for the benefit of policy holders and insurers) Necessary for the legitimate interests of a third party (to allow brokers and/or insurers to provide a service or policy which you have requested)
To review, manage and assess claims made by policy holders on policies of insurance	Necessary for our legitimate interests (to carry out services we are contractually required to provide, for the benefit of policy holders and insurers)
To make payments to policy holders in connection with claims on policies of insurance	Necessary for our legitimate interests (to carry out services we are contractually required to provide, for the benefit of policy holders and insurers)
To screen details of policy holders against lists of individuals subject to governmental or regulatory sanctions.	Necessary to comply with a legal obligation Necessary for our legitimate interests (to operate our business in accordance with regulatory requirements; to comply with the terms of authority granted to us by insurance companies
To manage queries relating to services we have provided to you or your clients historically, or policies we have underwritten	Performance of a contract with you Necessary for our legitimate interests (to be able to respond to queries about our services)
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests (to keep our records updated and to study how brokers and policy holders use our products/services).
To enable you to partake in a competition or complete a survey	Necessary for our legitimate interests (to keep our records updated and to study how brokers and policy holders use our products/services)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Necessary for our legitimate interests (to study how brokers and policy holders use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, broker and insured relationships.	Necessary for our legitimate interests (to define types of brokers and policy holders for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Consent (where you have provided positive consent) Necessary for our legitimate interests (to develop our services and grow our business)
To invite you to networking and professional events, and to inform you about developments in our business or the insurance sector more widely	Consent (where you have provided positive consent) Necessary for our legitimate interests (to develop our services and grow our business).

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
In addition, we may process your personal data without your knowledge or consent, where this is required or permitted by law.

Marketing

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

You will receive marketing communications from us in respect of our business and our services if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

We do not share your contact details with any third party for the purpose of that third party sending marketing.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting use using the details above at any time.

Automated Decision Making

We sometimes make decisions about you using only technology, or “automated decision making”, where none of our employees or any other individuals have been involved. For example, we may do this to decide whether to offer a policy of insurance to you, the premium that is payable for any policy of insurance offered to you, the risk involved of offering a policy of insurance, or whether to offer you credit.

The criteria that we apply to such decisions will differ depending on the policy of insurance and the criteria specified by the insurance company offering that policy of insurance.

As a result of this type of decision making, you may be offered or declined a policy of insurance, the terms of your offer may be determined, or your request for a policy of insurance may be referred to one of our underwriters for further consideration.

Information about our use of cookies

Please refer to our cookie policy here.

6. HOW WE USE SPECIAL CATEGORIES OF PERSONAL DATA

Where we collect special categories of personal data, we may use it in the following ways:

Health Data

For some policies of insurance, we collect data about your health. We collect this directly from information you provide to us. We may also collect data about your health in an emergency situation from your doctors and healthcare providers and advisers, and also from loss adjusters who collect information on our behalf. We use this data for the purpose of determining whether we can offer to issue a policy of insurance to you, and if we do, the terms upon which we offer the policy to you, including the level of premium. We will also use it in connection with assessing any claims that you make.

Where we collect and use this data, we do so with your consent.

Criminal Convictions

For some policies of insurance, we may collect data about your criminal convictions directly from you, from proposal forms completed by brokers or third parties you have interacted with, and from third party search providers, such as third-party databases, and sanctions lists.

We use this data for the purpose of determining whether we can offer to issue a policy of insurance to you, and if we do, the terms upon which we offer the policy to you, including the level of premium.

We may also receive details of convictions or offences or alleged offences when we carry out searches against third-party databases. Where your name appears on a sanctions list, we may not be able to provide a policy of insurance to you.

Where we collect and use this data, we do so as permitted by law.

In both of the above cases, we have in place an appropriate policy and safeguards which we are required by law to maintain when processing data regarding your health or criminal convictions.

7. DISCLOSURES OF YOUR PERSONAL INFORMATION

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above:

Your broker where we interact with a broker in respect of your policy;
Your insurer who provides the insurance policy, and also reinsurance companies;
Claims management providers who provide claims handling and management services to us, and others who assist in managing claims such as loss adjusters and surveyors;
Other members of our group identified at the start of this notice.
Service providers who provide IT and system administration services.
Our professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Debt Management and Collection Agencies
Government and regulatory bodies including tax authorities, Lloyd’s and regulators, who require reporting of our processing activities in certain circumstances.
Premium Finance Companies who provide insurance premium finance. They may share this data with others, including credit reference agencies.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. INTERNATIONAL TRANSFERS

We may transfer your personal data to third parties providing services to us who are based outside of the European Economic Area (EEA). This includes parties providing IT administration services and hosting services, and parties providing assistance with managing our marketing databases.

Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Transferring data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
Using appropriate contractual protections which give personal data the same protection it has in Europe.

9. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will usually keep your data for between 6 years and 10 years from inception of the last insurance policy that you incepted with us. For full details of our retention periods, please contact our Data Privacy Manager.

10. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are set out below. If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Complaint to the ICO

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Your legal rights

Your legal rights are as follows:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.