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Looking after the personal data you share with us is hugely important. CraftInsure Ireland Limited (we, us, our) want you to be confident that your data is safe and secure with us, and understand how we use it to offer you a better experience.

We are your "data controller" within the meaning of applicable Data Protection Laws. This means that we are responsible for deciding how we hold and use personal information about you. This privacy notice details how we collect and use personal information about you in accordance with Data Protection Laws.

Data Protection Laws means the Irish Data Protection Act 2018, the General Data Protection Regulation (EU) 2016/679 (the GDPR), the EU Privacy & Electronic Communications Directive 2002/58/EC, in all cases including any relevant amendments, transpositions, successors or replacements to those laws.

What information do we collect about you?

We will only request necessary information from you and we will try to ensure that your details are accurate and kept up to date.

Where we have collected information directly from you it will usually be obvious what this is, as you will have given it to us. This might not be the case where we have used cookies to collect information from your computer or portable electronic devices. Please see our cookies policy for more information.

We collect and use this information as part of your insurance quotation or contract with us, where it is necessary to fulfil a legal obligation, or as part of the establishment or defence of a legal claim.

What do we do with the information we collect, and why?

We use your personal information in order to meet our obligations in our contract of insurance with you. We use your personal information in the following ways:

Purposes for which your personal information is used

Our legal basis for using it

To provide insurance services

When you request us to provide you with a quote for one of our insurance policies or you purchase an insurance policy from us, we use information about you:

  • To underwrite your boat insurance risk, to quote for, and provide you with boat insurance and any special terms that may apply to that policy
  • To administer your policy and enable the payment of premiums
  • To contact you about the policy (e.g. for renewal purposes)
  • To provide the agreed service if you make a claim.

We cannot provide these services unless we use the information about you in this way.

This processing of your personal information is necessary to fulfil our obligations to you under the insurance contract (Article 6(1)(b) GDPR).

Do what we are required to do by law

As part of our duty as an insurer providing insurance services, sometimes we are required by law to use information about you:

  • To help make sure our customers are being treated fairly (e.g. to assist our regulators where we have a legal duty to do so);
  • To deal with complaints;
  • To help prevent and detect crime (including, for example, the prevention or detection of fraud); and
  • to comply with a legal or regulatory obligation.

This processing of your personal information is necessary in order for us to comply with our legal or regulatory obligations (Article 6 (1)(c) GDPR).

Prevent fraud occurring

Fraud has an impact on all customers as it increases costs for everyone. We use your personal information to check for signs that a customer might be dishonest (e.g. if someone has behaved dishonestly in the past it may increase the risk they will do so in future). We may use your personal information in this way because it is in all our customers' interests to ensure that they are not prejudiced due to increased premiums, as a result of a few customers acting dishonestly.

If you provide false or inaccurate information and fraud is identified the matter will be investigated and appropriate action taken. This may result in your case being referred to An Garda Siochana or other police forces and fraud prevention agencies. You may face fines or criminal prosecution. In addition, we may pass information relating to claims or potential claims to be placed on InsuranceLink. This information may be shared with other insurance companies, self-insurers or statutory authorities.

This processing of your personal information is necessary in order for us to comply with our legal or regulatory obligations (Article 6 (1)(c) GDPR).

Recover debt

If you owe us money we will use your personal information to help us recover it.

We can use your personal information in this way because it is a necessary part of the contract of insurance. We need to ensure that premiums are paid so that the majority of our customers do not suffer (e.g. through increased premiums) due to the actions of a small minority of customers.

The processing of your data is necessary to fulfil our obligations to you under our contract with you and to support our legitimate interests (Article 6(1)(f) GDPR) in managing our business and to fulfil our obligations to you under the insurance contract, provided our interests are not overridden by your rights and interests.

Please note that you have a right to object to the use of your personal data where that processing is carried on for our legitimate business interests. Where we rely on our "legitimate interest" as a reason for processing personal data, we have considered whether those interests are overridden by employees' rights and freedoms and have concluded that they are not. You have a right to request information on the balancing test we use.

To inform you about and promote products (marketing)

We may use your personal information to offer you suggestions about products and services you might want to buy.

We will always ensure that we keep the amount of your personal information that we collect and the extent of any processing to the absolute minimum to meet our legitimate interest.

We do not pass your information to any external third party for marketing purposes.

(a) The processing of your data is necessary to support our legitimate interests(Article 6(1)(f) GDPR) in managing our business, providing insurance quotations to potential customers, for marketing analysis and related profiling to help us offer you relevant products and services (including any of our products and services as well as any other offers we think may be of interest to you), provided our interests are not overridden by your rights and interests; or (b) consent which you may withdraw at any time.

Please note that you have a right to object to the use of your personal data where that processing is carried on for our legitimate business interests. Where we rely on our "legitimate interest" as a reason for processing personal data, we have considered whether those interests are overridden by employees' rights and freedoms and have concluded that they are not. You have a right to request information on the balancing test we use.

To administer and improve our service

To administer our services we will share information with others, in particular our underwriters, Navigators & General, part of Zurich Insurance plc whose own Privacy Policy is accessible here :

  • In order to enable us to process your claim or administer your insurance policy more cost effectively;
  • To help develop our products, services and systems to deliver you a better sales and claims experience in the future.

We may also ask you to provide feedback on the service we provide to you.

We will always ensure that we keep the amount of your personal information that we collect and the extent of any processing to the absolute minimum.

The processing of your data is necessary for our legitimate interests (Article 6(1)(f) GDPR) in managing our business and providing our services in the most efficient way, provided our interests are not overridden by your rights and interests.

Please note that you have a right to object to the use of your personal data where that processing is carried on for our legitimate business interests. Where we rely on our "legitimate interest" as a reason for processing personal data, we have considered whether those interests are overridden by employees' rights and freedoms and have concluded that they are not. You have a right to request information on the balancing test we use.

Who do we share your personal information with and why do we do it?

We may share your personal information with third parties.

In particular we share information with:

  • Our underwriters, Zurich Insurance plc. We cannot provide these services unless we share information about you with our underwriters. This is required to assist with the administration of your insurance, including claims
  • Marine Surveyors and other industry specialists who we may appoint in order to assist with the handling of a claim.
  • Other insurance companies to help settle any insurance claim or to verify that the information you have provided is correct (e.g. we may check the amount of No Claims Discount you have told us with your previous insurer).
  • Fraud prevention agencies
  • Law enforcement or government agencies. We and fraud prevention agencies may permit law enforcement or government agencies to access and use your personal information, if they request it.
  • Your spouse or partner who calls us on your behalf, provided they are named on the policy. In some exceptional cases, we may also deal with other people who call on your behalf, but only with your permission. If at any time you would prefer us to deal only with you, please let us know.
  • Insurance industry databases , such as the Claims and Underwriting Exchange where you make a claim so that insurers can check that your claims history is correct, and the Insurance Fraud Register.
  • Our financial service providers Secure Trading and STFS , for the purpose of credit/debit card authorisation.

We take all reasonable steps, as required by law, to ensure the safety, privacy and integrity of your personal information and, where required or appropriate, enter into contracts with the above organisations to protect the privacy and integrity of such data and any information supplied.

How long may we keep your information for?

We are only allowed to keep your personal information if we need it for one of the reasons we describe in the sections above.

As a general rule, we will keep it for 6 years from the end of your relationship with us, as it is likely that we will need the information for regulatory reasons or for a claim. For example, should you wish to bring some form of legal action relating to your relationship with us, this would generally need to be done within 6 years from the end of that relationship. However there may be exceptions where we need to keep your personal information for longer, such as where a claim has involved a minor.

We will also retain data in an anonymous form for statistical and analytical purposes, for example, to assess risk of storm damage occurring.

Change of Purpose

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. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with this policy, where this is required or permitted by law.

When and how can you ask us to stop using the information that you hold?

If we rely on your consent to collect and process your personal information. You can ask us to stop using your personal information at any time by withdrawing that consent. We will stop using your personal information for those purposes.

Where we are not able to hold or use the personal information we need to provide the service you are asking for, or to fulfil a legal requirement, we will be unable to continue providing that service.

We will be pleased to tell you about why we need the information when we ask for it.

When do we use computers to make decisions about you?

We will collect information about you and your boat, and put this into our computer systems. The computer systems will make certain automated decisions which will be based on comparing you with other people. This may have an impact on the level of premium and your policy terms. We will, for the purposes of providing you with a contract of insurance, processing claims, carrying out identity verification checks, process your personal data by means of automated decision making and profiling where we have a legitimate interest or you have consented to this. Where automated decision making, including profiling, produces legal effects concerning you or similarly significantly affects you, we will only process your personal information where necessary for the purposes of providing you with a contract of insurance, where you have explicitly consented to this or where it is expressly permitted by law.

This is important because:

  • In providing insurance services it helps us decide what price you should pay for your policy and understand any risks associated with that policy;
  • In identity verification it helps us to check that you are who you say you are and to prevent others from imitating you.

Your data rights

You have the right to request access to, rectification, or erasure of your personal data, or restriction of processing or to object to processing of your personal data, as well as the right to data portability. The following is a summary of what these rights involve:

Your data rights

What this means

Right to withdraw consent

In the event that we request, and receive, your consent to process your personal (or explicit

consent for special data) for a specific purpose, you have the right to withdraw your consent for that specific processing at any time (see "contact us" below).

Right of access

You can request a copy of the personal information we hold about you (a data subject access request).

Right to rectification

You can request us to correct any inaccurate or incomplete personal data.

Right to erase

You have the right to request that your personal data be deleted in certain circumstances including:

• The personal data is no longer needed for the purpose for which it was collected;

• You withdraw your consent (where the processing was based on consent);

• You object to the processing and there are no overriding legitimate grounds justifying us in processing the personal information (see "right to object" below);

• The personal information has been unlawfully processed; or

• To comply with a legal obligation.

However, this right does not apply where, for example, the processing is necessary:

• To comply with a legal obligation; or

• For the establishment, exercise or defence of legal claims.

Right to restriction of processing

You can ask that we restrict your personal data (i.e. keep but not use) where:

• The accuracy of the personal information is contested;

• The processing is unlawful but you do not want it erased; or

• We no longer need the personal information but you require it for the establishment, exercise or defence of legal claims.

We can continue to use your personal data:

• Where we have your consent to do so;

• For the establishment, exercise or defence of legal claims;

• To protect the rights of another; or

• For reasons of important public interest.

Right to data portability

Where you have provided personal data to us, you can ask to receive such personal information back in a structured, commonly-used and machine-readable format, and to have that data transmitted to a third-party data controller without hindrance but in each case only where:

• The processing is carried out by automated means; and

• The processing is based on your consent or on the performance of a contract with you.

Right to object

You can object to the processing of your personal information in those cases where we are processing your personal information in reliance on our legitimate business interests. In such a case we will stop processing your personal data unless we can demonstrate compelling

legitimate interests which override your interests and you have a right to request information on the balancing test we have carried out.

You also have the right to object where we are processing your personal data for direct marketing purposes.

Right to complain

If you have any concerns regarding our processing of your personal information, or are not satisfied with our handling of any request by you in relation to your rights, you also have the right to make a complaint to the Office of the Data Protection Commissioner at any time. You may contact the Office of the Data Protection Commissioner in writing at: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland or online at: https://www.dataprotection.ie/en/contact/how-contact-us .

If you wish to exercise any of these rights, please see "contact us" below. We will respond to your request within one month. That period may be extended by two further months where necessary, taking into account the complexity and number of data subject requests. We will inform you of any such extension within one month of receipt of your request. We may request proof of identification to verify your request. We have the right to refuse your request where there is a legal basis to do so, or if it is manifestly unfounded or excessive, or to the extent necessary for important objectives of public interest.

[International Data Transfers]

Where CraftInsure transfers your personal data to other recipients outside of the EEA and Switzerland, we will put in place appropriate safeguards to protect the transfer of your personal data to those non-EEA countries, in accordance with Data Protection Laws, including, for example, EU-approved standard contractual clauses (SCCs) where applicable. To obtain more information about these safeguards and appropriate security measures, please contact us at help@craftinsure.ie

Keeping your details safe

We have used SSL 256 bit encryption to keep your personal information and credit or debit card account details as secure as possible. We use Secure Trading to provide the highest levels of encryption. Please click on www.securetrading.com for more information.

Your email address and password help us to protect your personal information.

You must keep this password safe and must not disclose it to anyone.

You need your email address and password to access your personal information on the craftinsure.ie web site.

craftinsure.ie will accept no responsibility or liability if a third-party obtains and uses your email address and/or password.

You must tell us immediately if you have lost your password, or if you believe a third-party may have obtained it.

You may change your password through the Existing Customer section of the website.

Should you wish to remove any information that we may have recorded about you, please email us at help@craftinsure.ie, with full details.

Cookie Policy

This section tells you how we use cookies, why, and how this allows us to improve our service. We call it our Cookies Policy. If you do not know what cookies are, or how they are used, then we recommend you visit www.aboutcookies.org for detailed guidance.

By using our websites (through any device) you agree that this Cookies Policy applies to that use in addition to any other terms and conditions which may apply.

We reserve the right to make changes to our Cookies Policy. Any such changes will appear here and become effective immediately. Your continued use of our websites is taken as meaning that you agree to any such changes.

The list below describe the cookies we use on this site and what we use them for.

Analytics Cookie: We use analytics to collect information about visitor behaviour on our website. The Analytics data we collect is not tied to personally identifiable information and is used purely to improve the usability of our website.

Session Cookies: We use session cookies to allow you to log-in to the Craftinsure site. These are strictly necessary to the working of the website. Session cookies last only for the duration of your visit and are deleted when you close your browser.

Contact us

If you have any questions regarding security, about how we handle your personal information, or if you want to exercise any of your rights, please contact us in writing at: help@craftinsure.ie

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

Last updated: [24.12.2020]