Privacy Policy / Statement

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information. This privacy notice supplements the other notices and is not intended to override them.

Introduction

This Privacy Notice covers the information practices of Ornella Underwriting Limited (“Ornella”) t/a Ornella Underwriting, Ornella, Bump Insurance, Patrona and Patrona Underwriting.

• We are committed to protecting and respecting your privacy.
• We are committed to protecting the privacy and security of your personal data.
• We wish to be transparent on how we process your data and show you that we are accountable with the General Data Protection Regulations (GDPR) in relation to not only processing your data but ensuring you understand your rights as a client.
• We are committed not only to the letter of the law, but also to the spirit of the law and place high importance on the correct, lawful, and fair handling of all Personal Data, respecting the legal rights, privacy, and trust of all individuals with whom we deal.

Who we are?

Ornella Underwriting Limited is a wholly owned subsidiary of Ornella Limited and is a Data Controller in its own right:

The Insurance Lifecycle

This notice is designed to help you understand how we process your personal data through the insurance lifecycle.

Quotation

This is the process of providing a quote to a potential policyholder for an insurance policy.

Inception

This is the date when the insurance policy commences.

Administration of the Insurance Policy

This is the process of administering and managing an insurance policy through its lifecycle.

Claims Processing

In the unfortunate event that you have a claim, this is the process of handling a claim that is made under an insurance policy.

Renewal

This is the process whereby a quotation for a new insurance policy is provided to replace the existing policy on its expiry.

Insurance is the pooling and sharing of risk in order to provide protection against a possible eventuality. Ornella is a managing general agent (MGA). An MGA is a type of insurance intermediary which underwrites and provides administration services on behalf of insurers or other capital providers with delegated authority. As an MGA we work closely with a number of insurers and insurance market participants with the aim of providing a range of insurance products.

What is the purpose of our Privacy Notice?

This notice describes how we, as an MGA, collect and use personal data about you in the provision of our services and in the course of our business, in accordance with data protection legislation (including the Data Protection Acts of 1998, 2003 and 2018 [“the DPA”], the General Data Protection Regulation effective from 25 May 2018 [“the Regulation”] and any subsequent data protection legislation).

Ornella is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all Personal Data, respecting the legal rights, privacy, and trust of all individuals with whom we deal.

Purpose for processing your data

GDPR defines Personal Data as any information relating to an identified or identifiable natural person (a Data Subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

The personal information provided will be used to set up, administer and manage your policy over the course of its lifetime. The information will also be used to manage any claims/complaints made by you. The information may also be used in the following ways:

• For the detection/prevention of any activities that indicate fraud, money laundering or other offences.
• To verify identity when providing policy information over the phone.
• For statistical analysis, actuarial analysis, research projects, risk validation or market research purposes.
• Staff training.
• For information backup purposes.
• Reporting purposes to insurers, reinsurance agencies, Insurance Link, Motor Insurance Bureau of Ireland.
• Compliance with all regulatory requirements.
• Any further processing as set out in this document or other documents made available to you.

Your Personal Data

For us to provide quotations, place and administer your insurance policy and deal with any claims or complaints, we need to collect and process personal data about you. The below table contains examples of the types of information we may collect for the purposes set out in this document.

Why are we processing your data?

In order for us to provide you our products and services Ornella need to collect personal data for the provision of our insurance products and services. Our reasons for processing your data under the GDPR are:

Legal basis – We need to process your data (including data you provide about other Insureds such as Named Drivers) as this is necessary in relation to a contract of insurance to which you have entered into or because you have asked for something to be done so you can enter into a contract. This will include all products and services provided to you that relates to the inception, administration, maintenance, and completion of policies that have been requested by a customer.

Regulatory requirement - To meet our duties to the Regulator, the Central Bank of Ireland, we may allow authorised people to see our records (which may include information about you) for reporting, compliance and auditing purposes. We may also share information with certain statutory bodies such as the Department of Finance, the Department of Social Protection and the Financial Services and Pensions Ombudsman Bureau of Ireland if required by law.

Fulfilling contract - We will use the information provided by you, for the purpose of quoting, incepting, administering your policy and for claims and complaints handling. We may appoint external Third Party’s to undertake operational functions on our behalf. We will ensure that any information passes to Third Party’s conducting operational functions on our behalf will do so with respect for the security of your data and will be protected in line with data protection law.

All information gathered will comply with both current Data Protection Laws as well any guidelines set down by the Central Bank of Ireland.

How will we use the personal data it collects about you?

Your Personal Data will be used to enable us to fulfil our contractual obligations in relation to your insurance cover and the provision of any ancillary risk management services. We will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.

Special Categories of personal data

If we collect any special categories of personal data (e.g., health, religious beliefs) we will ensure that we will obtain your explicit consent.

Explicit Consent: This is consent that is freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Who are we sharing your data with?

We may pass your personal data on to third-party service providers contracted to Ornella in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide on your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Ornella procedures.

If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your explicit consent unless we are legally required to do otherwise.

The third parties that we pass your personal data to are:

• Your representatives, such as a relative, a named individual on the policy, your broker or any legal representatives you may appoint.
• Support companies for the delivery of the products and services we offer to you including but not limited to: insurers; other insurance brokers, loss adjusters and loss assessors; legal counsel, risk managers, administrators, incident management firms; professional advisors; premium finance companies; IT providers, internet service providers and mailing/fulfilment houses;
• Other individuals, such as third-party claimants and their representatives, other insurance companies.
• Law enforcement, credit and identity check agencies for the prevention and detection of crime.
• Anti-fraud data bases (e.g., Insurance link);
• Product reinsurers.
• External Auditors, either third party or regulatory i.e., Central Bank of Ireland;
• Government departments, such as An Garda Siochana and Motor Insurers’ Bureau of Ireland.
• As required under the Consumer Insurance Contracts Act, 2019 if you hold insurance against a liability that may be incurred by you against a third party, where for whatever reason you cannot be found or you become insolvent, or the court finds it just and equitable to so order, then your rights under the contract will be transferred to and vest in the third party even though they are not a party to the contract of insurance. The third party has a right to recover from the insurer the amount of any loss suffered by them. Where the third party reasonably believes that you as policyholder have incurred a liability the third party will be entitled to seek and obtain information from the insurer or from any other person who is able to provide it concerning:
  
  
  o the existence of the insurance contract,
  o who the insurer is,
  o the terms of the contract,
  o whether the insurer has informed the insured person that the insurer intends to refuse liability under the contract.

Transferring personal data to a country outside the EEA

Ornella may from time-to-time transfer (‘transfer’ includes making available remotely) Personal Data to countries outside of the EEA where this is necessary for us to provide our services to you. This will take place only if one or more of the following applies:

• The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for Personal Data.
• The transfer is to a country (or international organisation) which provides appropriate safeguards.
• The transfer is made with the informed consent of the relevant Data Subject(s)
• The transfer is necessary for the performance of a contract between the Data Subject and the Company (or for pre-contractual steps taken at the request of the Data Subject).
• The transfer is necessary for important public interest reasons.
• The transfer is necessary for the conduct of legal claims.
• The transfer is necessary to protect the vital interests of the Data Subject or other individuals where the Data Subject is physically or legally unable to give their consent; or
• The transfer is made from a register that, under EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who can show a legitimate interest in accessing the register.

Data Subjects Rights:

Ornella facilitate you, our clients, rights in line with our data protection policy and our subject access request and data breach procedures.

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

Right of access:

You have the right to request a copy of the information that we hold about you. You can either make a request verbally or in writing to your usual Ornella Underwriting contact or you can contact our Data Protection Officer at:

Email: customerservices@ornellaunderwriting.ie.

Address:
Data Protection Officer
Ornella Underwriting Limited
3rd Floor
The Bushels
Cornmarket
Wexford
Y35 HYE0

Telephone: 053 918 0300 (Main Office Number)

Right of rectification:

You have a right to correct data that we hold about you that is inaccurate or incomplete.

Right to be forgotten:

In certain circumstances you can ask for the data we hold about you to be erased from our records.

Right to restriction of processing:

Data Subject may request to restrict the processing of data that they feel is inaccurate, processed unlawfully, that is irrelevant to the contract, or have invoked their right to object.

Right of portability:

Data subject may request that all personal information be copied and transferred to another company in a readable and functional format.

Right to object:

You have the right to object to certain types of processing such as direct marketing.

Right to object to automated processing, including profiling:

Data subject may request to not have decisions made on the processing of their data solely based on an automated electronic process without any human intervention.

Right to judicial review:

In the event that we refuse your request under rights of access, we will provide you with a reason as to why.

All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.

Additional information we are providing you with to ensure we are transparent and fair with our processing

Our website and our Cookie Notice

This notice also aims to give you information on how Ornella collects and processes your personal data through your use of this website.

Our website may, from time to time, contain links to and from third-party websites, plug-ins, and applications. Clicking on those links may allow third parties to collect or share data about you. Please note that these third-party websites have their own privacy notices and we do not control those websites or accept any responsibility or liability for these privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit. This notice is specific to our website and together with the Cookies Notice sets out how we look after your personal data when you visit our website and tells you about your privacy rights and how the law protects you.

Ornella does not intentionally collect information from children, and Ornella does not target its website to children.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Notice.

Retention of your personal data

Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Ornella Underwriting Limited will process personal data in accordance with our retention schedule. Only relevant data will be retained by Ornella in order for it to fulfil its legal and regulatory responsibilities.

Quote information: 15 months
Policy information: 7 Years from end date of the policy.
Policy information where a claim is present: 7 Years from the end date of the policy or when the claim is finalised, whichever is the latter.
Policy information where a complaint is present: 7 Years from the end date of the policy or when the complaint is finalised, whichever is the latter.
Policy information where a claim and complaint is present: 7 years from the end date of the policy or when the claim or complaint is finalised, whichever is the latter.

Marketing

In the event that we would like to send you direct marketing, we will ask for your explicit consent. If we request your consent for this purpose, it will be presented in a manner which is clearly distinguishable as consent to marketing. If you had provided such consent, you have the right to withdraw it at any time, free of charge and such withdrawal will be as easy to as to give consent.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Ornella or how your complaint has been managed, you have the right to lodge a complaint directly with the Data Protection Commission or Ornella Underwriting Limited’s Data Protection Officer.

You can contact our Data Protection Officer at:

Email: customerservices@ornellaunderwriting.ie.

Address:
Data Protection Officer
Ornella Underwriting Limited
3rd Floor
The Bushels
Cornmarket
Wexford
Y35 HYE0

Failure to provide further information

If we are collecting your data for a contract and you cannot provide this data, the consequences of this could mean the contract cannot be completed or details are incorrect.

Profiling – automatic decision making

In order to underwrite your policy, Ornella may use automated software to review and calculate a premium for a given risk based on the information provided to us by you. Where an automated decision-making process is in place, you are entitled to query the process to ensure that all information provided is correct and the quote provided (if any) is fair.

Additional Processing

If we intend to further process your personal data for a purpose other than for which the data was collected and already described in this document, we will provide this information prior to processing this data.

Contact Us

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us by:

Email: customerservices@ornellaunderwriting.ie.

Telephone: 053 918 0300 (Main Office Number)

Contacting the Data Protection Commissioner (DPC)

You have a right to complain to the Data Protection Commissioner (DPC) in respect of any processing of your data by contacting them at:

Weblink: How to contact us | Data Protection Commissioner

Email Address: info@dataprotection.ie

Phone Number: 01 7650100 / 1800437 737

Address:
Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland

Privacy policy statement changes

Ornella may change this privacy policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy policy periodically so you are aware of any changes. By using our services, you agree to this privacy policy.