PRIVACY POLICY (ONLINE SERVICES)

Crown Global Insurance Group LLC and our affiliated businesses Crown Global Insurance Company of America, Crown Global Insurance (Cayman) Limited, d Crown Global Life Insurance Limited, Crown Global Life Insurance (Bermuda) Limited and Crown World Services, Limited  (collectively, “Crown”) is committed to being a responsible custodian of the information you provide to us and the information we collect in the course of operating our business.

This Privacy Policy describes how Crown may collect, use, and share information, particularly in association with the operation of our main website (www.crownglobalinsurance.com) and all of our websites, mobile applications, and HTML-formatted emails that link to this Privacy Policy (collectively, “Online Services”).

This Privacy Policy sets out how Crown may collect, use and share information and describes:

  • The types of information, including personal information, we may collect;
  • How we may use and share the information we collect;
  • The measures we have in place to protect and safely store the information we collect;
  • Legal grounds for using personal information;
  • Your choices and rights in respect of the information we hold;
  • Retention of the information we collect;
  • How to contact us;
  • Complaints; and
  • Changes to this privacy policy

The types of information, including personal information, we may collect

We collect your personal information when you provide it to us. "Personal information" is any information that can be used to identify you or that we can link to you as an individual. We may automatically collect certain information when you use, access, or interact with our Online Services.   We may also collect information from other sources, such as social media platforms that may share information about how you interact with our social media content.

Information you provide to us voluntarily

Generally, you can use our Online Services without providing us with any personal information.

We collect information that you voluntarily provide to us, including when you communicate with us via email or other channels; when you sign up for or request that we send you our e-alerts, or other marketing materials; when you submit an application for an employment position with us; and when you respond to our communications or requests for information. The information you provide may include your name, contact information, title, and information about the organisation with which you are affiliated.

Information we may collect automatically through cookies and similar technologies

We use browser cookies and similar technologies (collectively, “Cookies”) to collect and store certain information when you use, access, or interact with our Online Services. We may, for example, collect information about the type of device you use to access the Online Services, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the content you view and features you access on the Online Services, the web pages you view immediately before and after you access the Online Services, whether and how you interact with content available on the Online Services, and the search terms you enter on the Online Services. For information about how we use Cookies and the choices you may have, please see our Cookies Policy.

Please note that we do not currently respond to web browser “do not track” signals or other mechanisms that may allow you to opt out of the collection of information across networks of websites and online services as there is no standard for how online services should respond to such signals. As standards develop, we may develop policies for responding to do-not-track signals that we will describe in this Privacy Policy.

Your choices: managing cookies and opting out

You can choose how web browser cookies are handled by your device via your browser settings, including refusing or deleting all cookies. Some devices allow you to control this via your device settings. If you choose not to receive cookies at any time, the website may not function properly and certain services will not be provided. Each browser and device is different, so check the settings menu of the browser or device you are using to learn how to change your advertising settings and cookie preferences.   

Information we may collect from third party sources

We may receive information about you from other sources, including third parties and publically available information that help us: update, expand, and analyse our records; identify new customers or prevent or detect fraud. We may also receive information about you from social media platforms, including but not limited to, when you interact with us on those platforms or access our social media content. Please note that the information we may receive from those third party sites is governed by the privacy settings, policies, and/or procedures of the applicable platform, and we strongly encourage you to review them before submitting any information to them. 

How we use the information we may collect

We may use the information we collect:

  • To respond to your enquiries;
  • To provide you with insurance and other services that you request;
  • To operate and improve the Online Services;
  • To send you e-alerts and other updates, marketing communications and other information or materials that may be of interest to you or which you have expressed an interest in receiving;
  • To maintain our list of contacts;
  • To understand how people use our Online Services, including by generating and analysing statistics;
  • For Crown’s business purposes, including improving the provision of our insurance services, data analysis; submitting invoices; detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement;
  • To assess the effectiveness of our events, promotional campaigns and publications;
  • To evaluate, recruit, and hire personnel; and
  • As we believe reasonably necessary or appropriate to: comply with our legal obligations; respond to legal process or requests for information issued by government authorities or other third parties; or protect your, our, or others’ rights.

How we may share the information we collect

Crown is a global provider of insurance solutions for high net worth individuals, hedge funds, private equity and institutional investors. Our offices and business entities share information with each other for business purposes such as, internal administration, promoting our services, and providing you or your organisation with insurance services. We do not sell, rent, or otherwise share any information with unaffiliated entities except as expressly described in this Privacy Policy or with your prior permission. We may share anonymised information that does not reasonably identify you or your organisation only as permitted by applicable law.

We may also share information we collect with:

  • Employees of Crown but their use shall be limited to the performance of their duties and in line with the reason for processing. Our employees are required to keep that information confidential and are not permitted to use it for any purposes other than to provide insurance services or to deal with requests which are submitted to us.
  • Third-party service providers engaged by us to perform services on our behalf, such as web-hosting companies, information technology providers and analytics providers;
  • Law enforcement, courts or tribunals, other government authorities, or third parties (within or outside the jurisdiction in which you reside) as may be permitted or required by the laws of any jurisdiction that may apply to us; as provided for under contract; or as we deem reasonably necessary to provide our services. In these circumstances, we take reasonable efforts to notify you before we disclose information that may reasonably identify you or your organisation, unless giving prior notice is prohibited by applicable law or is not possible or reasonable in the circumstances.
  • Service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

Legal grounds for using personal information

We rely on the following legal grounds to process personal information, namely:

  • Consent – We may use personal information as described in this Privacy Policy subject to your consent. To withdraw your consent to such use, you can contact us via our Contact Us page. Where required by applicable laws, we will rely on your consent for direct marketing and to collect information from your device or computer.
  • Performance of a contract – We may need to collect and use personal information to enter into a contract with you or to perform a contract that you have entered into with us. For example, when you engage Crown to provide an insurance policy we will use your personal information to respond to provide you with such services.
  • Legal obligation – We may need to collect and use personal information to comply with legal obligations to which Crown is subject. This includes undertaking client due diligence and background checks (known as “KYC” or “know your client” checks) as well as all other anti-money laundering or other legal obligations. 
  • Legitimate interests – We may use your personal information for our legitimate interests to provide insurance services and to improve our services. Consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable laws, we may use personal information for our marketing purposes and other technical information as described in this Privacy Policy.

Third-party services and content

Our Online Services may include integrated content or links to content provided by third parties. This Privacy Policy does not address the privacy, security, or other practices of the third parties that provide such content.

We engage third parties that support the operation of our Online Services, such as analytics providers. These third parties may use technologies to track your online activities over time and across different websites and online platforms.

 

Measures we take to protect and safely storing the information we collect

Crown is a global provider of insurance solutions for high net worth individuals, hedge funds, private equity and institutional investors. The Online Services are controlled and operated by Crown from the United States. We may store the collected information in the United States or in other countries where we or our service providers have facilities. We may process the information we collect in jurisdictions where we or our service providers have facilities, including but not limited to Bermuda, the Cayman Islands, Zurich and the United States.

However, to ensure that your personal information does receive an adequate level of protection we have put in place standard data protection clauses with all members of the Crown Group or service providers who we may share information with to ensure that your personal information is treated by those third parties in a way that is consistent. If you require further information about this protective measure, please contact us via our Contact Us page.

In addition we deploy administrative, technical, and physical safeguards designed to comply with applicable legal requirements and safeguard the information that we collect. This includes, when required or appropriate and feasible, obtaining written assurances from third parties that may access your data that they will protect the data with safeguards designed to provide a level of protection equivalent to that adopted by Crown.

However, no information system can be 100% secure. So, we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the Internet and wireless networks.

Retention of the information we collect

We retain the information we collect for no longer than is reasonably necessary to fulfil the purposes for which we collect the information and to comply with our legal obligations.

Your choices and rights

To withdraw your consent to the use of your information as described in this Privacy Policy you can contact us via our Contact Us page. Please note that in some circumstances this may mean that we can no longer provide our services to you.  If you no longer wish to receive marketing communications from us, you can also let us know via our Contact Us page. The electronic marketing communications we send you also contain opt-out mechanisms that allow you to opt-out from receiving those communications, update your contact information or change your preferences at any time. We will honour your choice and refrain from sending you such announcements. You may also opt back in to receive those communications at any time.

Subject to local law, you may have certain rights regarding information that we have collected and that is related to you. We encourage you to contact us to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate or out of date. You can also ask us to see what personal information we hold about you and to erase your personal information if it is no longer required. You may also tell us if you object to our use of your personal information.

Your ability to exercise these rights will depend on a number of factors and in some instances, we will not be able to comply with your request, for example because we have legitimate grounds for not doing so or where the right doesn’t apply to the particular information we hold on you.

If you would like to discuss or exercise the rights you may have, you can contact us via our Contact Us page.

How to contact us

We welcome your enquiries and comments. But please note that if you are not a client, we may not be able to treat the information you send us as confidential or privileged. If you wish to contact us regarding our services, please contact one of our offices near you. You can find a list of our offices on our main website at www.crownglobalinsurance.com

If you would like to contact us with questions about our privacy or data protection practices, please send us an email via our Contact Us page or by writing to:

The Data Privacy Officer
data_protection@Crownglobalinsurance.com

 

Complaints

We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to complain to the data protection authority/regulator, as applicable, in your jurisdiction. We have set out below the contact details for the relevant authority/regulator in each Crown jurisdiction:

The Cayman Islands

The Ombudsman

3rd Floor, Anderson Square,

64 Shedden Road,

George Town, Grand Cayman

+1 345 946 6283

Bermuda

Information Commissioner

Valerie T. Scott Building

60 Reid Street

Hamilton, Bermuda HM12

441-294-9181

Switzerland

Federal Data Protection and Information Commissioner

Feldeggweg 1

CH - 3003 Berne

+41 (0)58 462 43 95

 

Changes to this privacy policy

We may update this Privacy Policy from time to time and we encourage you to periodically review this page. If we make any material changes in the way we collect, use, and/or share the personal information that you have provided, we will notify you by posting notice of the changes in a clear and conspicuous manner on the Crown website www.crownglobalinsurance.com.