Important note: this Web Privacy and Cookie Policy (the “Policy”) does not include PartnerRe’s data protection and privacy in relation to its reinsurance business (please refer to PartnerRe’s Business Privacy Notice) nor in relation to job application and employment at PartnerRe (please refer to our Employee Privacy Notice in the “Careers” section).
Protecting your privacy is very important to us. We want you to understand what data we collect and how we use it when you navigate on our Site (as defined below). We treat nonpublic personal data collected when you navigate our Site in accordance with our Web Privacy and Cookie Policy.
Residents of California and other U.S. states with specific comprehensive privacy laws can find further information about how we collect and process their personal data and their rights under the respective privacy law in the “ section.
This Policy applies to personal data collected on our website or through platforms with a link to this Policy (“Site”). It does not apply to any other information collected by PartnerRe Ltd. and its subsidiaries and affiliates (collectively referred to herein as “PartnerRe”) through any other means. By “personal data”, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you (or, for California residents only, your household). “Personal Data” does not include publicly available information. This Policy covers how we collect, use, and share that personal data as of the date that this Policy is posted. This Policy also does not apply to any Sites maintained or operated by other companies or linked to our Site.
We generally collect only personal data you voluntarily provide to us. We do not require you to give us personal data to access public areas of our Site, except to register for a webcast or with respect to our use of cookies, as described in Section ‘Cookies’ of this Policy.
If you cannot or choose not to provide us with the personal data we reasonably require, we may be unable to provide you with the information or services you have requested.
The below chart lists the categories of personal data that we collect, along with the purpose for the collection of such data. The numbers in brackets correspond to the legal basis for which we process your personal data (depending on the circumstances) as described in the section below “WHAT ARE THE LEGAL BASES ON WHICH WE USE YOUR PERSONAL DATA?”. Some of the bases for processing will overlap and there may be several grounds which justify our use of your personal data.
| Category of personal data Collected | Purposes1. [Legal Basis – refer to Section “What are the Legal bases on which we use your personal data?’] |
| · Contact information such as your name, address, email, phone number and employer· The IP address of the computer used· Information regarding your interaction with our Site· The date, the hour and the duration of the visit· The URL used to access our Site | · To analyze the way you navigate through our Site and to enhance your experience. [1, 3]· For Site administration. [3]· To comply with applicable law, obey judicial orders, cooperate with law enforcement authorities, or prevent any suspected illegal activities. [2] |
We are committed to processing your personal data fairly and lawfully and only to the extent necessary to achieve the purposes listed above.
We must have a legal basis to process your personal data. In most cases, our ability to obtain and process your personal data is based on one of the following legal bases:
| Legal bases | Details |
| 1. Consent | We obtain your consent to process your personal data for cookies. You are free to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. Withdrawal of this consent may however prevent us from continuing to provide the services to you. |
| 2. Compliance with a legal obligation | Processing is necessary for compliance with legal obligation. |
| 3. Legitimate interests | Processing is necessary to meet our legitimate business interests (e.g. to measure the number of visitors to our Site). |
Our Site is not intended for minors. We do not knowingly collect any personal data from, sell or share the personal data of, or track the use of our Site by, minors.
We only process and share your personal data to the extent reasonably necessary to fulfill your requests and our legitimate business objectives.
PartnerRe provides aggregate statistics about our customers, traffic patterns, and related Site information to others, but these statistics do not include personally identifying data. We restrict access to your nonpublic personal data and only allow disclosures to persons and companies as permitted by law to assist in providing products or services to you. When we disclose personal data to external entities to perform support services for us, they may access your personal data only for the limited purposes of performing those support services. We also may combine your online information with information collected from offline sources or information we already have. We may also use and disclose certain personal data to our affiliates and others for purpose allowed by law.
PartnerRe Business Activities. We process and disclose your personal data to others for the purposes described in the table under Section “What Types Of Personal Data Do We Collect About You? For what purposes?”.
Authorized Service Providers. We use our affiliates, other companies and individuals to perform certain functions on our behalf, such as the administration and maintenance of our IT systems and the Site, sending or processing postal or electronic mail, or analyzing or hosting data on cloud-based servers. We disclose your personal data to these companies and other individuals in connection with services they provide to us.
Other Disclosures. We otherwise disclose personal data as permitted or required by law, when we believe in good faith it is necessary for safety or security purposes, required for legal reporting, or to protect our legal rights or enforce our Terms of Use or any applicable rules, or to protect the rights of others. We also disclose personal data to our auditors, legal advisors, or to respond to a subpoena. We also aggregate information that we gather about you, product information, traffic patterns, and services, and provide these statistics to others in aggregate form.
A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as font size and other display preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another.
With your consent, we use cookies (e.g. Google Analytics) to analyze the way you navigate through our Site and to enhance your experience. We have implemented a Cookie Preference Center on our site, which gives you the ability to consent (or not) to the setting of the different types of cookies our Site uses and gives you control to accept or reject various types of non-essential cookies. You can return to the Cookie Preference Center at any time by clicking on the Cookies Settings button to change your preferences.
You can also accept, reject or delete cookies on your computer by modifying the settings in your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities of our Site may not work.
Below you will find links to information for disabling cookies for several common browsers.
Social media functions and social plug-ins are embedded in our Site in the form of small icons. We currently embed Twitter, LinkedIn and other social networks as icons on our Site.
We exclusively embed deactivated icons, which do not contact the servers of these external networks when our Site is accessed. The buttons become active and create a connection only if you deliberately click an icon, thus indicating your consent to communicating with such providers. By clicking on these icons you leave our Site and we do not record which external network you activate.
When you interact with these social plug-ins – for example, by entering a comment – a corresponding notification is sent to the social network and saved in accordance with the respective network’s policy. Please consult the respective social network’s data protection statement with regard to the scope and purpose of the data collected, its use and processing, as well as your respective rights and options in protecting your privacy.
We do not currently support the capability to respond to web browser “do not track” signals.
PartnerRe Ltd is headquartered in Bermuda and while PartnerRe has active reinsurance businesses in many countries around the globe, if you decide to use the Site, your personal data may be processed, stored and/or transferred outside your home country in jurisdictions (e.g. Bermuda or the United States of America) in which the data protection and privacy laws may not offer the same level of protection as those in the country where you reside or are a citizen. If you prefer not to have your personal data transferred to such countries, do not use the Site.
When we transfer your personal data to other countries outside the EEA, we establish legal grounds for such a transfer, mainly in the form of standard contractual clauses or other legal grounds permitted by applicable legal requirements.
To regulate intra group personal data transfers, PartnerRe has executed a master data transfer agreement. For more information on the appropriate safeguards in place, please contact us at the details contained in the “Contact us” section below.
The time for which we retain your personal data depends on the type of information and the purposes for which we use it. We retain your personal data pursuant to a retention schedule that is designed to keep personal data only for so long as is necessary and for a reasonable period thereafter to allow us to investigate, commence or defend legal claims brought by or against us or our clients, comply with our regulatory obligations and conduct analysis.
We securely destroy personal data when they are no longer needed for the aforementioned purposes and its retention period has expired. In some circumstances we retain aggregated or anonymised data which can no longer be associated with you and is not treated as personal data under this privacy notice.
To support us in managing how long we hold personal data and our record management, we maintain a data retention policy which includes clear guidelines on retention and deletion.
We consider the following criteria when determining how long a particular record will be retained, including any personal data contained in that record:
The same personal data about you may be included in more than one record and used for more than one purpose, each of which may be subject to different retention periods based on the factors listed above.
We implement technical and organizational measures to ensure a level of security appropriate to the risk to the personal data we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal data. We evaluate these measures on a regular basis to ensure the security of the processing.
(Residents of California and other U.S. States with specific comprehensive privacy laws shall refer to Section “Your Rights under state-specific privacy laws”)
We generally collect personal data voluntarily given to us by you.
Under certain conditions, you may have the right to require us to:
In certain circumstances, we may need to restrict the above rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). Upon receipt of a request from you exercising any of the above-listed rights, we will need to verify your identity.
This section is meant to provide supplemental or specific information for residents of California and certain other US states regarding how we collect personal data and your rights regarding that information under respective state privacy laws.
How we collect personal data about you
The personal data we may collect about you includes data within the categories below. These categories are defined by California law. Where we collect this data and the purposes for which we process it are consistent with how we treat other data under this Policy as described above. We do not necessarily collect all data listed in a particular category, nor do we collect all categories of data for all individuals.
We have also shared data in each of the following categories with our affiliates and service providers for our business purposes within the last 12 months. As a reinsurance company, we may receive requests for data from regulatory authorities, our auditors and/or our legal advisors. If requested from such parties, we would share your personal data as appropriate.
We do not sell your personal data or share your personal data for “cross-contextual behavioral advertising,” as such term is defined under California law. We also do not sell or share your personal data for “targeted advertising”, as such term is defined under relevant state laws.
Depending on the circumstances, we may collect and process the following personal data about you:
We do not collect or process what the state-specific privacy laws refer to as “sensitive personal data” when you navigate our Site.
Your rights under state-specific privacy laws
Depending on your state of residence, and subject to certain exceptions as set forth by law, you (or an authorized agent acting on your behalf) have the right to ask us to:
You may also have the right to receive the details/data you request in a portable and readily usable format.
Depending on your residency, these rights may not apply to pseudonymous data if the information necessary to identify the consumer is kept separately and is subject to controls that prevent access to the information. Pseudonymous data is personal data that can no longer be attributed to a specific individual without the use of additional information, if the additional information is kept separately and is subject measures to ensure that personal data is not attributed to the specific individual.
Data solely retained for data backup or archive purposes is principally excluded from these rights until it is restored to an active system or next accessed or used for a sale, disclosure, or commercial purpose.
Any disclosure(s) we make pursuant to your request under this Section will cover only data we collect and maintain on or after January 1, 2022.
In certain circumstances, we may need to restrict the above rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).
You have the right not to receive discriminatory treatment from us for exercising the rights conferred to you under the respective state privacy law.
If you would like to exercise any of the above state-specific rights, you (or an authorized agent acting on your behalf) can e-mail us at [email protected], or call us at 1-800-261-3164. Depending on where you reside, you may be entitled to make either one or two requests per calendar year, free of charge. You will be charged a fee for subsequent requests exceeding this limit. Under applicable privacy law, and for the protection of your personal data, we may be limited in what personal data we can disclose.
Upon receipt of a request from you exercising any of the above-listed rights, we will need to verify your identity. To do so, we will send you a pre-assessment form within 10 business days of receiving your request. Such pre-assessment form will, among other things, request certain contact information and ask that you certify that you are either the consumer whose personal data is the subject of the request or the authorized representative of such consumer.
If you are not satisfied with our use of your personal data or our response to any request by you to exercise any of your rights in Section “Your Rights” or “Your rights under state-specific privacy laws” of this Policy, or if you think that we have breached the applicable data protection laws, then you may have the right to appeal our decision or complain to your local supervisory authority (i.e. the supervisory in the jurisdiction where you live or work) or the supervisory authority of the jurisdiction where you believe an infringement of data protection laws has occurred. Each supervisory authority may have a different process for lodging complaints so we encourage you to contact the relevant supervisory authority first to check this.
PartnerRe Ltd., located at Wellesley House South, 90 Pitts Bay Road, Pembroke HM08, Bermuda is responsible for the personal data we receive in connection with your use of the Site.
If you have any questions, have a complaint, or wish to send us comments about this Policy, please contact PartnerRe’s Data Protection Officer via e-mail at [email protected] or call or write to us. We will investigate your complaint and use reasonable efforts to respond to you as soon as possible.
Bermuda:
Wellesley House South
90 Pitts Bay Road
Pembroke HM08
Bermuda
Phone: +1 441 292 0888
Ireland:
3rd Floor, The Exchange
Georges Dock
IFSC
Dublin 1
Ireland
Phone: +353 1 637 9600
United States:
200 First Stamford Place
Suite 400
Stamford, Connecticut 06902
Phone: +1 203-485-4200
This Policy is dated June 30, 2023.
If we make changes to this Policy, we will update the date it was last changed and publish the revised Policy on our website.