Privacy Policy

Last Updated: 11/9/2018

Fortitude Reinsurance Company Ltd. (“Fortitude Re”) and its subsidiaries and affiliates (each a “Fortitude Re Company”, “Fortitude Re Companies”, “we” or “us”) is committed to protecting the privacy of the individuals we encounter in conducting our business. “Personal Information” is information that identifies and relates to you or other individuals (such as your dependents). Our aim is responsible handling of Personal Information, balancing the benefits of activities like research and data analytics with our other commitments, including transparency and non-discrimination. This Privacy Policy describes how we handle Personal Information that we collect through:

  • this website (“the Site”), the software applications we may make available for use on or through computers and mobile devices (the “Apps”), our social media pages (our “Social Media Pages”) (collectively, including the Site, the Apps and our Social Media Pages, referred to as the “Fortitude Re On-line Services”); and

  • 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).

By using the Fortitude Re On-line Services, you signify your acceptance of this Privacy Policy.

Please note: This Privacy Policy is supplemented by Privacy Notices tailored to our specific relationships with you, including Privacy Notices that are sent to individuals as required under applicable laws and regulations.

Other websites and services of Fortitude Re Companies both within and outside of the United States of America and Bermuda may contain different privacy statements to this Privacy Policy, and you are advised to review the privacy statement on each Fortitude Re Company website.

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

6. Security

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

14. Changes to This Privacy Policy


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 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.
  • Carry out research and analysis, including analysis of individuals whose Personal Information we collect as explained in this Privacy Policy.
  • 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

Due to the global nature of our business, for the purposes set out above we may transfer Personal Information to parties located in other countries. We may transfer information internationally to our group companies, service providers, business partners and governmental or public authorities. By providing Personal Information and other information to Fortitude Re, including through the Fortitude Re On-line Services, and/or by sending a communication to a”” e-mail address, you understand and consent to the collection, use, processing disclosure and transfer of such information in the United States and other countries or territories, which may not offer the same level of data protection as the country where you reside, in accordance with the terms of this Privacy Policy. Further, please note that any communication you send to a “” e-mail address will be routed through the United States.

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.
  • Recipients of your social sharing activity Your friends associated with your social media account(s), other website users and your social media account provider(s), in connection with your social sharing activity, such as if you connect another social media account to your Fortitude Re On-line Services account or log into your Fortitude Re On-line Services account from another social media account. By connecting your Fortitude Re On-line Services account and your other social media account you authorize us to share information with your social media account provider and you understand that the use of the information we share will be governed by that other social media website’s privacy policy. If you do not want your Personal Information shared with other users or with your other social media account provider(s), please do not connect other social media accounts with your Fortitude Re On-line Services account and do not participate in social sharing using our Fortitude Re On-line Services.
  • 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

If you provide Personal Information to Fortitude Re regarding other individuals, you agree: (a) to inform the individual about the content of this Privacy Policy, and any other applicable Fortitude Re Privacy Notice provided to you; and (b) to obtain any legally-required consent of Personal Information about the individual in accordance with this Privacy Policy and other Privacy Notice.

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 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.
  • Using cookies; online tracking: Cookies are pieces of information stored directly on the device you are using. We may use cookies allow us to recognize your device and to collect information such as internet browser type, time spent on the Fortitude Re On-line Services, and pages visited. We may use the information for security purposes, to facilitate navigation, to display information more effectively, or to personalize your experience while using the Fortitude Re On-line Services. In addition, we may use the information to gather statistical information about the usage of the Fortitude Re On-line Services in order to understand how they are used, continually improve their design and functionality, and assist us with resolving questions about them. Cookies may allow us to present to you the advertisements or offers that are most likely to appeal to you. We may also use cookies to track your responses to our advertisements and we may use cookies or other files to track your use of other websites. We do not respond to browser do-not-track signals at this time.

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

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Fortitude Re On-line Services link. The inclusion of a link on the Fortitude Re On-line Services does not imply endorsement of the linked site or service by us or by our group companies.

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.

14. Changes to This Privacy Policy Back To Top

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our website.

Please take a look at the “LAST UPDATED ” date at the top of this Privacy Policy to see when it was last revised.