PRIVACY NOTICE

Introduction

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. We are committed to protecting and respecting your privacy. We take your privacy seriously and will only use your personal information as set out in this Privacy Notice.

This Privacy Notice sets out how we collect and uses any information that you give us when you use this website and our services (the “Site”). The expressions “we”, “us” and “our” refer to First European Title Insurance Company Ltd.

The legal basis for processing your personal data will be to meet our contractual obligations in providing and / or offering you an insurance policy and administering that policy. Under the GDPR this is known as processing your data for the performance of a contract or in contemplation of a contract (i.e. the insurance policy).

Who are we?

First European Title Insurance Company Ltd is authorised by the Malta Financial Services Authority. First European Title Insurance Company Ltd is registered in Malta under company number C88171. Registered office: Signature - Portomaso Business Centre, Portomaso, St. Julian’s, STJ 4011, Malta

In what capacity will First European Title Insurance Company Ltd hold information about you?

In providing insurance services, we will act as a data controller, in full compliance with the GDPR requirements.

In most cases, your personal data will be provided to us by a third party, usually a legal advisor or insurance broker, but in some instances it may come directly from you.

This data will usually be provided to us by telephone, email or input on our Site.

What happens if you cannot provide us with personal information?

If you are unable to provide us with all the necessary information, we may be unable to offer you an insurance policy or administer any existing policy.

What are your rights relating to the use of your data?

Under data protection law, you have certain rights around the processing of your data, which depend on the legal basis for collecting your data and the uses made of your data. For all uses made of your data, you have the right to be informed about how we use your data, and this notice discharges that obligation.

However, further rights apply in different circumstances, set out below:

• Right of access – You have a right to request a copy of the information we hold about you.
• 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 to be held about you to be erased from our records. Please note our retention period set out below.
• Right of portability – You have the right to have the information we hold about you transferred to another organisation.
• Right to restriction of processing – Where certain conditions apply you have a right to restrict the processing, although this may mean we are unable to offer you an insurance policy or administer any existing policy.
• Right to object – You have the right to object to certain types of process such as direct marketing and automated processing – Please note we will not use your data for this purpose unless you have previously consented to such use.

What information will First European Title Insurance Company Ltd hold about you?

Personal information about you to enable us to offer or provide you with an insurance policy and to administer that policy (including fraud prevention and financial crime checks as well as claims handling), such as:

• Title and full name
• Current and new addresses
• Email address
• Telephone or other contact numbers
• Postal code
• IP address
• Bank details

First European Title Insurance Company Ltd will under no circumstances ask for any sensitive personal data from you.

How will First European Title Insurance Company Ltd use information held about you?

First European Title Insurance Company Ltd will only use your personal information when the law allows us to. We will use your personal data where we need to:

1. in order to meet our contractual obligations under our agreement with you;
2. where it is necessary for our legitimate interests (or those of a third party and your interests and fundamental rights do not override those interests; or
3. where we need to comply with a legal or regulatory obligation.

In summary this means we use your personal data for:

• Processing a request for an insurance policy;
• Internal record keeping;
• Claims handling;
• For fraud prevention; undertaking financial crime checks.

If you give us information regarding another person, you are confirming they have given you permission to provide their information to us to be able to process their personal data and also that you have told them about First European Title Insurance Company Ltd.

In some cases, we may be required to disclose information held to legal, regulatory or governmental bodies, but First European Title Insurance Company Ltd is committed to only doing so under proper authority.

Change of purpose

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 the above rules, where this is required or permitted by law.

How long will First European Title Insurance Company Ltd retain your information?

In most cases, the policies we offer provide insurance coverage in perpetuity. We are therefore required to retain the information indefinitely, in order to continue administering those policies.

Will your data be transferred to third parties?

First European Title Insurance Company Ltd may share the personal information that it has about you with affiliated parties, these could include the following:

• Other members of the Group (an in each case their employees, affiliates, successors or group companies)
• External insurance providers and their representatives
• Successors in title any relevant parties
• Providers of IT solutions
• Third party consultants, contractors or other service providers who may access the personal information when providing services to the relevant parties (including but not limited to IT support services);
• Government bodies, law enforcement agencies, regulatory bodies, legal societies, trade associations and in response to other legal or regulatory requests from similar third parties;
• Legal advisers, auditors, contractors or other advisers auditing, assisting with or advising on any of the business purposes of the relevant parties.

If you give us personal information regarding another person, you are confirming they have given you permission to provide their personal information to us to be able to process their personal information, and also that you have advised them that their personal information will be passed to First European Title Insurance Company Ltd and their affiliates.

Will your data be transferred to third countries?

On occasions, we may transfer your personal information to third countries for case administration or reinsurance purposes. We will not release the information to non-affiliated parties. Where we make such a transfer, we will take the required steps to ensure your information is protected. Such steps will include placing the party we are transferring personal information to under contractual obligations to protect it to adequate standards.

Security

We have put in place measures to protect the security of your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

The internet is not a secure medium, however, we are committed to ensuring that your personal information is as secure as possible.

In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal information we collect online. We will use our best efforts to ensure that no unauthorised parties have access to any of your personal information.

How do we use Cookies?

A cookie is a small file of letters and numbers that are downloaded onto your computer when you visit a website. You can use your web browser to control cookies. These cookies are used to secure sessions and improve access to the Site.

Further details on the use of cookies can be found in the cookie policy.

Further information

In the event you wish to make a complaint about how your personal data is being processed by First European Title Insurance Company Ltd you have the right to complain to the Compliance Officer, by email to: compliance@firsteuropean.eu or in writing to: The Compliance Officer, First European Title Insurance Company Ltd, Signature - Portomaso Business Centre, Portomaso, St. Julian’s, STJ 4011, Malta.

You also have the right to complain to the Office of the Information & Data Protection Commissioner:

Office of the Information & Data Protection Commissioner
Level 2, Airways House
High Street,
Sliema,
SLM 1549,
Malta

Data Protection UK Representative

In accordance with Article 27 of the UK GDPR we have designated a UK representative to act on our behalf if and when we undertake data processing activities to which article 3(2) of the UK GDPR applies.

Our representative is:

FIRST TITLE SERVICES LIMITED
42 Trinity Square
London
EC3N 4DJ

Legal statements about this Privacy Notice

We may change this Privacy Notice at any time by updating this page so you should, therefore, check the Site from time to time to ensure you are aware of any changes.

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

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

This Privacy Notice is not designed to form a legally binding contract.

Use of the Site by you constitutes acceptance by you of the Privacy Notice. If you do not wish to accept the Privacy Notice, you should not continue to use the Site.

All calls made to and by us may be monitored or recorded.

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