"FM Global" refers to FM Insurance Company Limited, including its parent company, subsidiaries and affiliates (also referred to as "we", "us", or "our"). FM Insurance Company Limited is the controller and responsible for your personal data.
We have appointed a data protection officer who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, or any requests to exercise your legal rights, please contact us at:
Data Protection Officer,
FM Insurance Company Limited
Berkshire, SL64 2PJ
INFORMATION WE MAY COLLECT FROM YOU
What type of information we collect:Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
How we collect your personal data:We use different methods to collect data from and about you including through:
1. Direct interactions
You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- give us some feedback,
- provide one of our representatives with your contact details (for example, by giving your business card); or
- register for or attend an event organized by us.
2. Automated technologies or interactionsAs you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. Information can be collected in the following ways:
For the purposes of this Policy, "website" includes our mobile applications.With regard to each of your visits to our websites, FM Global may automatically collect certain types of information. When you visit our websites, associated micro-sites, mobile applications and exchange e-mails, we may use automated technologies such as web server logs to collect IP addresses, "cookies" and Web beacons. The collection of this information will allow us to improve the effectiveness of FM Global’s websites and our marketing activities.
When accessing our websites on a mobile device, we may collect your unique device identifier and mobile device IP address, as well as information about your device's operating system, mobile carrier and your location information. If you previously chose to receive push notifications on your mobile device from us but no longer wish to receive them, you can manage your preferences either through your device or the application settings. If you no longer wish to have any information collected by the mobile application, you may uninstall the application by using the uninstall process available on your mobile device.
FM Global collects information during your visit to an FM Global website through the use of cookie technology. Using cookies allows us to improve our websites, compile aggregate statistics and distinguish you from other users of our websites. The use of this technology helps us to provide you with a positive experience when you browse our websites, it also helps refine our content and personalize your experience.
When you engage with us through social media websites or through features such as plug-ins or applications on FM Global websites that integrate with social media sites, you may choose to link your account with us to third party social media sites. When you link your account or engage with us on or through third party social media sites, plug-ins, or applications, you may allow us to have ongoing access to certain information from your social media account (e.g., name, e-mail address, photo, gender, birthday, the posts or the 'likes' you make).
If you post information when you interact with our websites through social media sites, plug-ins or other applications, depending on your privacy settings, this information may become public on the Internet. You can control what information you share through privacy settings available on some social media sites. In addition, we also give users the option to share our stories on social networks such as Facebook and Twitter. To deliver this service we link to a third-party website called AddThis. If you use our share buttons you will be directed to a website controlled by AddThis. We have no control over the additional cookies that AddThis sets when you use its services. You can opt out of such cookies through this external party’s cookie preference center.
3. Third PartiesWhile the information we collect may come directly from you, it may also be provided by our affiliates or other third parties (such as employers, insurance companies, insurance brokers or agents, credit organisations, financial institutions, etc.). Sometimes we may obtain your contact details through third parties who would have shared personal details with us with your consent. If you provide personal information about other individuals (such as employees, dependents, etc.), you must obtain their consent prior to your disclosure to FM Global.
USE OF PERSONAL INFORMATIONWe will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following ways:
With your consent:Where appropriate, we will ask for your consent to use your personal information, in particular with regards to direct marketing communications about our products and services to you via email or text message, or for sending you e-newsletters or online publications. You have the right to withdraw consent to marketing at any time by contacting us. If you request electronic communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in the communication.
Where it is necessary for our legitimate interests:
We have a legitimate interest in using your personal information in certain circumstances. “Legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). We use personal information to offer and administer our services and products. These may include, but are not limited to, claims management, risk management consulting, loss prevention including engineering visits, product certification and testing and other forms of insurance services (including underwriting of insurance products and reinsurance). We may also have legitimate interests to use personal Information to:
- provide information and services as requested;
- determine eligibility and process applications for products and services;
- understand and assess ongoing needs and offer products and services to meet those needs;
- carry out communication, service, billing and administration;
- administer claims;
- conduct data analysis;
- ·obtain and update credit information with appropriate third parties, such as credit reporting agencies, where transactions are made on credit;
- execute monitoring and training;
- develop new services;
- to administer our websites and ensure the contents are present effectively;
- to allow you to participate in interactive features;
- market products and services;
- conduct processing necessary to fulfill other contractual obligations;
- exercising our legal rights and protecting our interests in the event any of the information you provide is relevant or helpful in connection with insurance claims brought by our customers or legal actions brought by or against us; and
To comply with a legal or regulatory obligation:
We may be required to process your information to comply with applicable laws or regulatory obligations.
DISCLOSURE OF YOUR PERSONAL INFORMATIONWe do not rent, sell or otherwise disclose personal information about our clients and website visitors with unaffiliated third parties for their marketing use. We may share personal information with third parties including, but not limited to, affiliates and subsidiaries, credit and fraud reporting agencies, debt collection agencies, insurers, reinsurers, insurance brokers, reinsurers, other insurance intermediaries, third parties that provide data analytic services, our marketing service providers, lawyers and accountants and others involved in the claims handling process, sub-contractors, suppliers and service providers. These entities are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements.
Furthermore, we may disclose personal information:
- to respond to the courts and/or regulators, governmental agencies or public authorities in connection with enquiries, proceedings, subpoenas or other legal process or investigations by parties anywhere in the world;
- in order for FM Global to comply with its regulatory requirements or dialogue with its regulators as applicable;
- in the event of a merger/acquisition;
- to business partners that may deliver marketing communications, promotional materials, or advertisements that may be of interest to you;
- to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate 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.
TRANSFER OF YOUR PERSONAL INFORMATION ACROSS BORDERSDue to the global nature of our business, the personal information FM Global collects may be transferred, processed and stored across geographical borders. These transfers are governed by applicable data protection laws including the United Kingdom (UK), European Union (EU), and any other international, federal, state, provincial, and local law in any relevant jurisdiction. With regard to transfers and processing of Personal Information from the EU, the UK and Switzerland, these transfers are governed by EU standard contractual clauses, UK standard contractual clauses, and/or equivalent data transfer regulations to protect the security and confidentiality of personal information. We will take appropriate steps to ensure that your data is treated securely and in accordance with this Policy.
PROTECTION OF YOUR INFORMATION
FM Global has implemented appropriate physical, technical and administrative security standards to protect personal information from loss, misuse, alteration or destruction.
Some of the steps we take are:
- placing confidentiality requirements on our employees, representatives and third parties. They will only process your personal data on our instructions and we limit access to your personal information to persons who have a business need to know;
- keeping information security policies;
- destroying or permanently de-identifying personal information if it is no longer needed for the purpose for which it was collected; and
- maintaining appropriate website protection and security measures.
DATA RETENTIONWe will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, included 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. In some circumstances, you can ask us to delete your data: see Request Erasure below.
ACCURACY OF YOUR INFORMATIONPlease notify us of any changes to your personal information by contacting us at the e-mail or postal address listed in the "Contact Us" section above.
YOUR LEGAL RIGHTSUnder certain circumstances, you have rights under data protection laws in relation to your personal data:
You have the right to:
- 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, though we may need to verify the accuracy of the new data you provide to us.
- 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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data if there is something about your particular situation which makes you want to object to processing as you feel there is an impact 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.
- 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.
No fee usually required
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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
CHANGES TO THIS POLICY
Last updated: June 2023