Last Updated: 11/9/2018
other means (for example, from your telephone calls, e-mails and other communications with us, as well as from third parties in connection with our reinsurance, policy administration, or claims handling activities).
1. Who To Contact About Your Personal Information
2. Personal Information That We Collect
3. How We Use Personal Information
4. International Transfer of Personal Information
5. Sharing of Personal Information
7. Personal Information of Other Individuals
8. Marketing Preferences
9. Social Security Numbers
10. Questions and Concerns
11. Other Information We May Collect Through our Fortitude Re On-line Services
12. Third Party Privacy Practices
13. Use of Services by Minors
1. Who To Contact About Your Personal Information – Back To Top
If you have any questions about our use of your Personal Information you can e-mail email@example.com or write to:
Fortitude Reinsurance Company, Ltd
c/o American International Group
Attn: E-Commerce Legal
80 Pine Street, 13th Floor, New York, NY 10005
2. Personal Information That We Collect – Back To Top
Depending on your relationship with us (for example, as a consumer policyholder; insured person benefiting under another policyholder’s policy, or claimant; witness; commercial broker or appointed representative; or other person relating to our business), Personal Information collected about you and your dependents may include:
- General identification and contact information
Your name; address; e-mail and telephone details; gender; marital status; family status; date of birth; passwords on our systems; educational background; physical attributes; activity records, such as driving records; photos; employment history, skills and experience; professional licenses and affiliations; relationship to the policyholder, insured or claimant; and date and cause of death, injury or disability.
- Identification numbers issued by government bodies or agencies Social Security or national insurance number; passport number; tax identification number; military identification number; or driver’s or other license number.
- Financial information and account details Payment card number; bank account or other financial account number and account details; credit history and credit score; assets; income; and other financial information.
- Medical condition and health status Current or former physical or mental or medical condition; health status; injury or disability information; medical procedures performed; personal habits (for example, smoking or consumption of alcohol); prescription information; and medical history.
- Other sensitive information In certain cases, we may receive sensitive information about you for example, if you applied for insurance through a third party that is a professional, trade, political, religious or community organization. In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud. We may also obtain sensitive information if you voluntarily provide it to us (for example, if you express preferences regarding medical treatment based on your religious beliefs).
- Telephone recordings Recordings of telephone calls to our representatives and call centers.
- Photographs and video recordings
Photographs or video recordings created or provided to us in connection with our business activities, including for claims assessment, processing, settlement, and disputes, or for other relevant purposes as permitted by law.
- Information to investigate or prevent crime, including fraud and money laundering For example, insurers commonly share information about their previous dealings with policyholders and claimants for this purpose.
- Information enabling us to provide services Location and identification of property insured (for example, property address, vehicle license plate or identification number); age categories of individuals insured; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organization; and other insurance you hold.
- Marketing preferences and other feedback You may let us know your marketing preferences or respond to a voluntary survey.
- Social media account and information from Apps We may receive certain Personal Information about you when you use our Apps or Social Media Pages, including your social media account ID and profile picture. If you elect to connect any of your other social media accounts to your account(s) on the Fortitude Re On-line Services, Personal Information from your other social media account(s) will be shared with us, which may include Personal Information that is part of you profile relating to those accounts or your friends’ profiles.
- Information from Other Sources
We and our service providers may supplement the Personal Information we collect with information from other sources, such as publicly available information from social media services, commercially available sources and information from our affiliates or business partners.
3. How We Use Personal Information – Back To Top
We use this Personal Information to:
- Communicate with you and others as part of our business.
- Send you important information regarding changes to our policies, other terms and conditions, our Fortitude Re On-line Services and other administrative information.
- Make decisions about whether to provide services which we offer, including policy administration, claim assessment, processing and settlement; and, where applicable, manage claim disputes.
- Assess your eligibility for payment plans, and process your premium and other payments.
- Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers).
- Prevent, detect and investigate crime, including fraud and money laundering, and analyze and manage other commercial risks.
- Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed.
- Personalize your experience when using our Fortitude Re On-line Services or visiting third-party websites by presenting information and advertisements tailored to you.
- Identify you to anyone to whom you send messages through any of the Fortitude Re On-line Services.
- Facilitate social sharing functionality.
- Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; data analytics; business continuity; and records, document and print management.
- Resolve complaints, and handle requests for data access or correction.
- Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering, sanctions and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence).
- Establish and defend legal rights; protect our operations or those of any of our group companies or business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.
4. International Transfer of Personal Information – Back To Top
5. Sharing of Personal Information – Back To Top
Fortitude Re may make Personal Information available to:
- Our group companies Other Fortitude Re group companies may have access to and use of Personal Information in connection with the conduct of our business where appropriate.
- Other third parties with whom we do business In the course of marketing, policy administration and claims handling, Fortitude Re may make Personal Information available to third parties such asinsurers, insurance and reinsurance brokers and other intermediaries and agents; appointed representatives; affinity marketing partners; and financial institutions, securities firms and other business partners.
- Our service providers External third-party service providers, such as medical professionals, accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; medical assistance providers; call center service providers; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; banks and financial institutions that service our accounts; third-party policy and claims administrators; document and records management providers; claim investigators and adjusters; construction consultants; engineers; examiners; jury consultants; translators; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
- Governmental authorities and third parties involved in court action Fortitude Re may also share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.
- Other Third Parties We may share Personal Information with payees; emergency providers (fire, police and medical emergency services); retailers; medical networks, organizations and providers; credit bureaus; credit reporting agencies; and other people involved in an incident that is the subject of a claim; as well as purchasers and prospective purchasers or other parties in any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business, assets or stock.
Personal Information may also be shared by you, on message boards, chat, profile pages and blogs, and other services to which you are able to post information and materials (including, without limitation, our Social Media Pages and Apps). Please note that any information you post or disclose through these services will become public information, and may be available to visitors who access the Fortitude Re On-line Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Fortitude Re On-line Services.
6. Security – Back To Top
Fortitude Re will take appropriate technical, physical, legal and organizational measures, which are consistent with applicable privacy and data security laws. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have with us has been compromised), please immediately notify us. (See the “Who to Contact About Your Personal Information ” section above.)
When Fortitude Re provides Personal Information to a service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the Personal Information.
If we believe the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail.
7. Personal Information of Other Individuals – Back To Top
8. Marketing Preferences – Back To Top
We will provide you with regular opportunities to tell us your marketing preferences, including in our communications to you. You can also contact us by e-mail at firstname.lastname@example.org or by writing to:
Fortitude Reinsurance Company, Ltd
c/o American International Group
ATTN: E-Commerce Legal 80 Pine Street, 13th Floor, New York, NY 10005
to tell us your marketing preferences and to opt out.
If you no longer want to receive marketing-related e-mails from Fortitude Re on a going-forward basis, you may opt out of receiving these marketing-related emails by clicking on the link to “unsubscribe” provided in each e-mail or by contacting us at the above addresses. We will endeavor to comply with your opt-out request(s) within a reasonable time period. Please note that if you opt out as described above, we will not be able to remove your Personal Information from the databases of third parties with whom we have already shared your Personal Information (i.e., to those to whom we have already provided your Personal Information as of the date on which we respond to your opt-out request). Please also note that if you do opt out of receiving marketing communications from us, we may still send you other important administrative communications from which you cannot opt out.
9. Social Security Numbers – Back To Top
It is Fortitude Re’s policy to protect Social Security Numbers that we collect in the course of our business as confidential. This includes maintaining physical and electronic security procedures to guard against unauthorized access to Social Security Numbers. We also limit access to Social Security Numbers, by among other means, only granting access to Social Security Numbers to our employees who use that information to perform their job-related duties. In addition, we do not disclose Social Security Numbers to third parties, except where required or permitted by law.
10. Questions and Concerns – Back To Top
Please contact us as set out in the “Who to Contact About Your Personal Information ” section above with any such requests or if you have any questions or concerns about how we process Personal Information.
11. Other Information We May Collect Through our Fortitude Re On-line Services – Back To Top
“Other Information” is any information that does not reveal your specific identity, such as:
- Browser and device information;
- App usage data;
- Information collected through cookies, pixel tags and other technologies;
- Demographic information and other information provided by you; and
- Aggregated information
How We Collect Other Information
We and our third-party service providers may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most websites or automatically through your device, such as your IP address (i.e., your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, device manufacturer and model, language, internet browser type and version, time of the visit, page(s) visited and the name and version of the Fortitude Re On-line Services (such as the App) you are using. We use this information to ensure that the Fortitude Re On-line Services function properly.
- Through your use of any Apps: When you download and use Apps that we may make available, we and our service providers may track and collect App usage data, such as the date and time the App(s) on your device accesses our servers and what information and files have been downloaded to the App(s) based on your device number.
Third parties may collect information about your use of the Fortitude Re On-line Services and your use of other websites or online services.
You can refuse to accept the cookies we may use by adjusting your browser settings. However, if you do not accept cookies, you may experience some inconvenience in your use of the Site and some online products.
- Using information provided by you: Some information (for example, your location or preferred means of communication) is collected when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you.
- By aggregating information: We may aggregate and use certain information (for example, we may aggregate information to calculate the percentage of our users who may access the Site from a particular country).
Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, or if we combine Other Information with Personal Information, then, in addition to the uses listed in the “ Other Information We Collect ” section above, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.
12. Third Party Privacy Practices – Back To Top
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other software application developer or provider, social media platform, operating system or wireless service provider, or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages..
13. Use of Services by Minors – Back To Top
The Fortitude Re On-line Services are not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Information through the Fortitude Re On-line Services.