Effective Date: 21.11.2022

Nimblr takes your privacy seriously and commits to protect and respect your privacy. We aim to comply with best practices when it comes to data protection acts and regulations governed in each jurisdiction we are located and operate from, namely: Bermuda’s Personal Information Protection Act of 2016 (“PIPA”), effective December 2018.​ This policy explains:

- Who we are;

- How we collect information and what type of information is collected from you;

- How we use information collected from you;

- How we share your data;

- How long we keep your data;

- International Data transfers;

- How we keep your data secure;

- Your rights; and

- How you can contact us. 

This notice applies to information held in the course of providing the following services:

Insurance

Underwriting

Capital Provision

Actuarial Modeling

Claims

INTRODUCTION

WHO IS NIMBLR? 

When we refer to Nimble (“we” or “our” or “us”), that means Nimble Insurance Ltd., a Bermuda exempt company, licensed as a Class IIGB insurer by the Bermuda Monetary Authority (“BMA”), and its subsidiaries and affiliates as applicable. We specialise in providing insurance solutions for new and emerging business categories (“Services”) so when we refer to “you”, that means the potential insureds and/or partners.

WHY DO WE COLLECT, USE AND DISCLOSE YOUR INFORMATION?

In the provision of our Services, or during the process of determining whether or not such Services will be provided, we collect, store, use and disclose personal information about you (including to and from our affiliates and/or subsidiaries, referring organizations and/or third party providers/suppliers) in order to allow us to effectively and accurately assist you in finding and maintaining appropriate (re)insurance coverage when applicable, and for the following purposes: 

Establish your identity

Understand and assess your needs and eligibility for products and services

Analyze, assess, underwrite and (re)insure risks on a prudent basis and determine eligibility for discounts if and when appropriate

Facilitate payment of your premiums through appropriate means

Investigate and settle claims

Protect you and us from error, fraud, and illegal activity

Communicate with you

Ensure quality assurance

Establish and maintain responsible commercial relations with you

Develop, enhance, market, or provide products and services

Analyze business results and to report to appropriate regulatory or industry entities

Marketing and promotions, including but not limited to targeted advertising

Compile statistics, conduct market research in accordance with prudent practices

Comply with the law or requests of law enforcement officers or regulators

Provide ongoing serviceSurvey your customer and claims experiences and satisfaction; and

For other purposes with your consent or as permitted or required by law.

Privacy Policy

WHAT INFORMATION DO WE COLLECT?

We obtain most of your personal information directly from you. However, we may need to collect information from other sources. We will only collect information pertinent to the appropriate purpose. The personal information we collect may include, but is not limited to: ‍Personally Identifiable Information (PII): Name, age, email address, telephone number, physical address, driver’s license number, passport number, social security number, account number or other information of key personnel as required by a government or regulatory agency or to exercise prudence as required by internal underwriting policies and procedures. This is obtained by Nimble or our Compliance-as-a-Service partners. ‍Other Information: Company financing, financial condition and merger and acquisition activity; claims history; recent or ongoing civil or criminal actions or administrative proceedings; employment practices; international exposures; diversity of business activities; or such other information as we may collect with your consent or as permitted or required by law. ‍Electronic information: IP address, browser version, tracking information.

HOW DO WE COLLECT YOUR INFORMATION? 

We may collect information from the following sources: 

- When you provide the information to us directly, whether through a website, to a third party service representative (such as a broker) when you inquire about a quote or otherwise‍

- You, or any person authorized by you, on applications for (re)insurance or service products, or other forms filled out in person or through telephone, email, or online‍- Government, industry and other entities authorized by law that have information on your claims history, legal standing or proceedings, or otherwise pertinent to an application for (re)insurance‍

- Consumer reporting agenciesYour continued interaction with us, such as payment history or claims settlement; or‍

- Reputable, third party market research agencies who conduct customer and claims satisfaction surveys on our behalf‍

- We may also collect some information automatically when you visit our website(s) or social networking websites or platforms. This may include information such as the type of Internet browser or computer operating system you are using, your IP address, the domain name of the website from which you linked to the website, or details of your social media account(s). We use this automatically-collected information to improve our website, to enhance user experience, to target the content and advertising we deliver to you, and to improve upon the services we provide. 

In addition, when you view the website, we may store some information on your computer in the form of a “cookie” or similar file. Cookies are small pieces of data which are stored on your computer to allow your Internet browser to remember something about a website. We use cookies and IP addresses to obtain information from online visitors to determine how many people visit our website, and to track your online activity as permitted by law. You can set your browser not to accept cookies or have your computer notify you when cookies are being sent by following the instructions for your particular web browser. However, if you refuse cookies, you may not be able to use certain features of our website.

WITH WHOM DO WE SHARE INFORMATION ABOUT YOU? 

We may share information with persons or organisations including but not limited to the following: 

- Any person authorized by you 

- Any person required or permitted by law to have access to your personal information 

- Any person as is necessary to meet our legal, regulatory, insurance, audit, processing and security requirements or to protect our reasonable business interests 

- Third party agents or service providers (including our affiliates acting in this capacity) that perform services on our behalf, such as administrative and technical services, verification services, claims management services, collection services, marketing and research services, online directed advertising services, data hosting, processing or similar services, or that otherwise collect, use, disclose or store personal information on our behalf for the purposes described in this Privacy Statement including other (re)insurers, agents or brokers, as necessary 

- Professionals, such as lawyers or adjusters working with or retained by us 

- Credit and financial organizations 

- Credit card issuers and processors; and - Industry data collection agencies for the purpose of analyzing business results. When we share personal information with third parties, we provide only that information that is required in the circumstances and we take reasonable contractual or other measures to protect your personal information. 

Depending on the processes and procedures involved, we, or third parties acting on our behalf may process and/or store some or all of your personal information in jurisdictions outside of Bermuda, including the United States.

Personal information processed and/or stored outside of Bermuda will be subject to the laws of the country in which it is stored. We take reasonable contractual or other measures to protect your personal information while processed or handled by our service providers.

HOW CAN YOU GIVE YOUR CONSENT?

There are many ways you can give consent. Consent can be express, for example, in writing on a form you may sign describing the intended uses and disclosure of personal information, verbally, or through electronic means. Alternatively, where permitted by law, your consent may be implied through an action you’ve taken or when you continue to use a product or service after we’ve notified you of a change with respect to your personal information and you have not withdrawn your consent, such as by using an “opt out” option provided, if any. You may indicate your consent by the following: 

- Providing your personal information to us for the purposes of acquiring a insurance related product or service, including information previously provided to us‍

- Your express consent or acknowledgement contained, for example, within a written, verbal, or electronic application process 

- Your express consent solicited by us for a specific purposeYour receipt of this Privacy Policy and/or the link to provide you with access to this Privacy Policy, until you notify us of a withdrawal of this consent; or 

- Your consent given through your authorized representative such as your legal guardian, agent, or holder of power of attorney. Generally, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Policy if applicable, or otherwise at the time of collection. 

By providing personal information about a third party such as a family member you represent that you have obtained their consent to the collection, use, and disclosure of such personal information in accordance with this Privacy Policy.

CAN YOU WITHDRAW YOUR CONSENT? 

Subject to certain legal and contractual obligations you may, on reasonable notice, withdraw your consent to the collection, use, or disclosure of your personal information. If you do not wish to consent or if you withdraw your consent we may not be able to provide you with a particular product or service. Where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfil the purposes described in this Privacy Policy or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures of the personal information. We will explain the impact of withholding or withdrawing your consent, to help you with your decision. If you wish to withdraw your consent, you should contact our Compliance Officer at the address or telephone number listed below. Unless we hear otherwise from you, you are giving to us your consent for the collection, use, and disclosure of personal information as provided in this Privacy Policy. We may contact you on behalf of us or our affiliates to offer other (re)insurance products and services through direct mail, telephone, or other means. If you would rather not receive such information, please use the contact information below to let us know.

HOW LONG DO WE RETAIN YOUR DATA?

We will retain your personal information only as long as necessary to satisfy legal or business obligations, including reasonable business record-keeping obligations. The length of time we keep your information depends on the product or service and the nature of the personal information and in accordance with our data retention policies and practices. Following that period, we’ll make sure it’s deleted or anonymised.

INTERNATIONAL DATA 

When we share data, it may be transferred to, and processed in, countries other than the country you live in. These countries may have laws different to what you’re used to. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

HOW DO WE KEEP YOUR INFORMATION SECURE?

Security is a priority for us when it comes to your personal data. We are committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

WHO CAN YOU CONTACT ABOUT YOUR INFORMATION?

For further information, please contact us at compliance@nimblr.insure

WHAT ARE YOUR RIGHTS? 

Right of access by the data subject: You have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and where that is the case, to gain access to your personal data. Right to rectification: You have the right to obtain from us without undue delay the rectification of inaccurate personal data. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement. Right to erasure (‘right to be forgotten’): You have the right to obtain from us the erasure of personal data concerning you without undue delay and we have the obligation to erase personal data without undue delay subject to legal or regulatory provisions. Right to restriction of processing: You have the right to obtain from us restriction of processing depending on certain legal provisions. Right to data portability: You have the right to receive the personal data concerning you, which you provided to us, in a structured, commonly used and machine-readable format and have the right to transmit this data to another controller without hindrance from the us to which the personal data have been provided. Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, including profiling. We shall no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of yourself or for the establishment, exercise or defence of legal claims. If you would like to exercise any of these rights, please our Compliance Officer at compliance@nimblr.insure

CHANGES TO OUR PRIVACY NOTICE

We reserve the right to make changes to our privacy notice without prior notice.