Terms and Conditions

---

PRIVACY STATEMENT

SQrInsurance Services LLC (“SQrInsurance”) is committed to protecting your privacy. This commitment reflects the value we place on earning and keeping the trust of our employees, customers, clients, business partners and others who share their personal information with us.

This Privacy Statement (“Statement”) explains SQrInsurance’s information processing practices. This Statement applies to any personal information you provide to SQrInsurance and any personal information we collect from other sources, unless you are provided a more specific privacy statement at the time of data collection. This Statement does not apply to your use of any third-party sites linked to from this website or any websites which have their own privacy notices.

1. How do we collect your information and what information do we collect?

The personal information we collect varies depending upon the nature of our services. This Statement provides an overview of the categories of personal information we collect and the purposes for which we use it. More information about the personal information collected for each of our services, together with the purpose and legal basis for collecting the information, may be provided to you in separate privacy notices relevant to the applicable services.

SQrInsurance collects personal information in the following ways:

Information you provide to us.

SQrInsurance collects information directly from you when you:

Request a service from us;

Visit an SQrInsurance site or attend an SQrInsurance event;

Apply for a position at SQrInsurance;

Contact us with a complaint or query;

Engage with us over social media; or

Register with or use any of our websites or applications.

You are required to provide any personal information we reasonably require (in a form acceptable to us) to meet our obligations in connection with the services we provide to you, including any legal and regulatory obligations. Where you fail to provide or delay in providing information we reasonably require to fulfill these obligations, we may be unable to offer the services to you and/or we may terminate the services provided with immediate effect.

Where you provide personal information to SQrInsurance about third-party individuals (e.g., information about your spouse, civil partner, child(ren), dependents or emergency contacts), where appropriate, you should provide these individuals with a copy of this Statement beforehand or ensure they are otherwise made aware of how their information will be used by SQRINSURANCE. Where you provide information to us about your beneficiaries we may require you to provide explicit consent on their behalf.

Information we automatically collect

In some instances, we automatically collect certain types of information when you visit our websites and through e-mails that we may exchange. Automated technologies may include the use of web server logs to collect IP addresses, "cookies" and web beacons. Further information about our use of cookies can be found in our Cookie Notice and Cookie Preference Center at the footer of our page (where applicable).

Information we collect from clients or third parties

When we provide the services to our clients, we may collect personal information from our clients about you, such as your name, contact details, date of birth, gender, marital status, financial details, employment details, and benefit coverage. We may also collect (in each case as strictly relevant to the services we provide) sensitive information about you, such as health information in relation to life, health, professional liability and workers compensation insurance or employee benefit programs sponsored by your employer. Most of the personal information we receive relates to your participation in the compensation and benefits programs offered by your employer. Where permitted by national law, and appropriate to do so, we may collect criminal records information; for example, where required as part of our business acceptance, finance, administration, recruitment, anti-money laundering and sanctions screening processes.

The information we collect about you may include the following:

a. Basic personal details, such as your name, address contact details, date of birth, age, gender and marital status;

b. Unique identifiers such as National Insurance Number or pension scheme reference number;

c. Demographic details, such as information about your age, gender, race, marital status, lifestyle, and insurance requirements;

d. Employment information such as role, employment status (such as full/part time, contract), salary information, employment benefits, and employment history;

e. Health information such as information about your health status, medical records and medical assessment outcomes;

f. Benefits information such as benefit elections, pension entitlement information, date of retirement and any relevant matters impacting your benefits such as voluntary contributions, pension sharing orders, tax protections or other adjustments;

g. Financial details such as payment card and bank account details, details of your credit history and bankruptcy status, salary, tax code, third-party deductions, bonus payments, benefits and entitlement data, national insurance contributions details;

h. Claims details such as information about any claims concerning your or your employer’s insurance policy;

i. Your marketing preferences;

j. Online information: e.g., information about your visits to our websites;

k. Events information such as information about your interest in and attendance at our events, including provision of feedback forms;

l. Social media information such as interactions (e.g., likes and posts) with our social media presence; and

m. Criminal records information such as the existence of or alleged criminal offences, or confirmation of clean criminal records.

Where we collect sensitive personal information (such as information about your health or alleged criminal activities), we will ensure that it is necessary and is done in accordance with applicable law, which may include obtaining your explicit consent and/or necessary authorizations prior to collection.

2. How do we use your personal information?

The following is a summary of the purposes for which we use personal information. More information about the personal information collected for each of our services, together with the purpose and legal basis for collecting the information, may be provided to you in separate privacy notices which are relevant to the services which affect you.

Performing services for our clients

We process personal information which our clients provide to us to perform our commercial risk, reinsurance, retirement, health, and data and analytics services. The precise purposes for which your personal information is processed will be determined by the scope and specification of our client engagement, and by applicable laws, regulatory guidance and professional standards.

Administering our client engagements

We process personal information about our clients and the individual representatives of our corporate clients to:

Carry out SQrInsurance’s regulatory and compliance obligations, including:

"Know Your Customer" checks and screening;

Anti-money laundering;

Trade sanctions screening;

Obtain and update credit information with appropriate third parties, such as credit reporting agencies, where transactions are made on credit;

Communicate with our clients;

Address client inquiries and complaints; and

Administer claims.

Communications and marketing to our clients and prospective clients

We process personal information about our clients, prospective clients, and the individual representatives of our corporate clients to: send newsletters, know-how, promotional material and other marketing communications; and invite our clients to events, including arranging and administering those events.

Conducting data analytics, benchmarking and modeling

SQrInsurance relies on developing sophisticated products and services by drawing on our experience from prior engagements to analyze trends. SQrInsurance also uses data to perform analysis, modeling, benchmarking and research.

Crime prevention

We process personal information to facilitate the prevention, detection and investigation of crime and the apprehension or prosecution of offenders and to comply with laws/regulations. For example, we do this as part of our business acceptance, finance, administration and recruitment processes, including anti-money laundering and sanctions screening checks.

Mergers and acquisitions

We process personal information in the event of a sale, acquisition or reorganization. This includes processing personal information for planning and due diligence purposes both prior to closing and after a transaction has closed for reasons related to the sale, acquisition, or reorganization and in order to transfer books of business to successors of the business.

Process and service improvement

We process personal data to maintain and improve processes used in providing the services and uses of technology, including testing and upgrading of systems. We also process data to develop new services.

If we wish to use your personal information for a purpose which is not compatible with the purpose for which it was collected, we will request your consent unless your personal information is being processed to satisfy our legal and regulatory obligations. In all cases, we balance our legal use of your personal information with your interests, rights, and freedoms in accordance with applicable laws and regulations to make sure that your personal information is not subject to unnecessary risk.

3. Legal basis

We rely on the following legal grounds to collect and use your personal information:

a. Performance of the service contract. Where we offer services or enter into a contract with you to provide services, we will collect and use your personal information where necessary to enable us to take steps to offer you the services, process your acceptance of the offer and fulfill our obligations in the contract with you.

b. Legal and regulatory obligations. The collection and use of some aspects of your personal information is necessary to enable us to meet our legal and regulatory obligations. For example, SQrInsurance is licensed and regulated by certain industry regulators and is required to provide some services in accordance with relevant regulatory rules.

c. Preventing and detecting fraud. We will use your personal information, including information relating to criminal convictions or alleged offences to prevent and detect fraud, other financial crime, and crime generally in the insurance and financial services industry.

d. Legitimate interests. The collection and use of some aspects of your personal information is necessary to enable us to pursue our legitimate commercial interests. For example, we have legitimate interests in:

Providing professional services across our product lines;

Operating our business, and managing and developing our relationships with clients, suppliers and with you;

Understanding and responding to inquiries;

Receiving information from third parties to provide services;

Sharing data in connection with mergers and acquisitions and transfers of business;

Improving our services; and

Understanding how you and our clients use our services and websites.

Where we rely on this legal basis to collect and use your personal information we shall take appropriate steps to ensure the processing does not infringe the rights and freedoms conferred to you under the applicable data privacy laws.

e. Consent. In certain instances, we rely on your consent as a legal basis. For example, we rely on your consent to collect and use personal information concerning any criminal convictions or alleged offences, specifically for assessing risks relating to your prospective or existing insurance policy. We may also share this information with other insurance market participants and third parties where necessary to offer, administer and manage the services provided to you, such as insurers and insurance underwriters, reinsurers, brokers and vetting agencies.

Where we rely on your consent to collect and use your information, you are not obliged to provide your consent and you may choose to subsequently withdraw your consent at any stage once provided. However, where you refuse to provide information that we reasonably require to provide the services, we may be unable to offer you the services and/or we may terminate the services provided with immediate effect.

Where you choose to receive the services from us you agree to the collection and use of your personal information in the way we describe in this section of the Statement. If applicable you also agree that such information may be collected and used for the above purpose by the insurance underwriter named in your insurance policy documentation. You should refer to the insurer’s privacy statement on their website for further information about their privacy practices.

f. Substantial public interest (in accordance with applicable law). If applicable law allows, we may collect and use your information for a substantial public interest. For example, to prevent or detect unlawful acts or in public health.

4. Do we collect information from children?

Our websites are not directed to children and we do not knowingly collect personal information from children on our websites. Children are prohibited from using our websites.

Certain SQrInsurance solution lines may process data related to children, such as their date of birth, address, and other identifiable information. This information is not collected directly from children, but from other parties such as from our client, the carrier, or directly from you as the parent or guardian of the child (e.g., so that the child may be named a beneficiary to an insurance policy or pension plan).

5. How long do we retain your personal information?

How long we retain your personal information depends on the purpose for which it was obtained and its nature. We will keep your personal information for the period necessary to fulfil the purposes described in this Statement unless a longer retention period is permitted or required by law and in accordance with the SQrInsurance Record Retention Policy. Your personal information will be securely destroyed when it is no longer required.

6. How do we disclose your personal information?

We generally share your personal information with the following categories of recipients where necessary to offer, administer and manage the services provided to you:

a. Within SQrInsurance for the processing purposes outlined in this Statement;

b. Insurance market participants where necessary to offer, administer and manage the services provided to you, such as insurers and insurance underwriters, reinsurers, brokers, intermediaries and loss adjusters. The insurance underwriter is the insurer that is underwriting your insurance policy and is named in your policy documentation. You should refer to the insurer’s privacy statement on their website for further information about their privacy practices;

c. Vetting and risk management agencies such as credit reference, criminal record, fraud prevention, data validation and other professional advisory agencies, where necessary to prevent and detect fraud in the insurance industry and take steps to assess the risk in relation to prospective or existing insurance policies and/or the services;

d. Legal advisers, loss adjusters, and claims investigators, where necessary to investigate, exercise or defend legal claims, insurance claims or other claims of a similar nature;

e. Medical professionals, e.g., where you provide health information in connection with a claim against your insurance policy;

f. Law enforcement bodies, when required to do so by law, legal process, statute, rule, regulation, or professional standard, or to respond to a subpoena, search warrant, or other legal request, and where necessary to facilitate the prevention or detection of crime or the apprehension or prosecution of offenders;

g. Public authorities, regulators and government bodies, where necessary for us to comply with our legal and regulatory obligations, or in connection with an investigation of suspected or actual illegal activity;

h. Third-party suppliers, where we outsource our processing operations to suppliers that process personal information on our behalf. Examples include IT service providers who manage our IT and back office systems and telecommunications networks, and contact center providers. These processing operations shall remain under our control and will be carried out in accordance with our security standards and strict instructions;

i. Successors of the business, where SQrInsurance or the services are sold to, acquired by or merged with another organization, in whole or in part, and personal information needs to be shared with relevant third parties as part of due diligence processes and transfers to the new entity. Where personal information is shared in these circumstances it will shared in accordance with this Statement; and

j. Internal and external auditors where necessary for the conduct of company audits or to investigate a complaint or security threat.

7. Do we have security measures in place to protect your information?

The security of your personal information is important to us and SQrInsurance has implemented reasonable physical, technical and administrative security standards in an effort to protect personal information from loss, unauthorized access, misuse, alteration or destruction and to ensure that such information is processed in accordance with applicable data privacy laws.

8. Other rights regarding your data

Subject to certain exemptions and the jurisdiction in which you live, and in some cases dependent upon the processing activity we are undertaking, you may have certain rights in relation to your personal information. We have listed some of the common rights that may be applicable below. When you exercise these rights, we may need to ask you for additional information to confirm your identity, before disclosing information to you or responding to your request. We will not charge a fee unless your request is manifestly unfounded or excessive and/or we are permitted by law to levy such charges.

You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way. If we cannot fully address your request, we will contact you to let you know and explain the reason why your request was denied.

Right to Access

You have the right under certain circumstances to access and inspect personal information which SQrInsurance holds about you. If you have created a profile, you can access that information by visiting your account.

Right to Correction

You may have the right to request us to correct your personal information where it is inaccurate or out of date.

Right to be Forgotten (Right to Erasure)

You have the right under certain circumstances to have your personal information erased. Your information can only be erased if your data is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the data.

Right to Restrict Processing

You have the right under certain circumstances to request the restriction of your personal information from further use, e.g., where the accuracy of the information is disputed, and you request that the information not be used until its accuracy is confirmed.

Right to Data Portability

You have the right under certain circumstances to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party.

Right to Object to Processing

You have the right to object the processing of your personal information at any time, but only where that processing is based our legitimate interests as its legal basis. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to Decline Automated Decision Making

You have the right to object to decisions involving the use of your personal information, which have been taken solely by automated means. See section eleven (11) below for further information.

Right to Object to Direct Marketing

Where your personal information is processed for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning him or her for such marketing. We will provide specific information on how to opt-out from our marketing initiatives through the medium we communicate with you.

9. Automated Decisions

Where you apply or register to receive the service we may carry out a real-time automated assessment to determine whether you are eligible to receive the service. An automated assessment is an assessment carried out automatically using technological means (e.g., computer systems) without human involvement. This assessment will analyze your personal information and comprise several checks, e.g., credit history and bankruptcy check, validation of your driving license and motoring convictions, validation of your previous claims history and other fraud prevention checks. Where your application to receive the service does not appear to meet the eligible criteria, it may be automatically refused, and you will receive notification of this during the application process. However, where a decision is taken solely by automated means involving the use of your personal information, you have the right to challenge the decision and ask us to reconsider the matter, with human intervention. If you wish to exercise this right, you should contact us.

10. Contact Us

If you have any questions, would like further information about our privacy and information handling practices, would like to discuss opt-outs or withdrawing consent, or would like to make a complaint about this Statement, please contact SQrInsurance, 180 Park Avenue, Suite 106, Florham Park, NJ 07932-1054 or info@sqrinsurance.com.

You also have a right to lodge a complaint with your local data protection supervisory authority,

11. Changes to this Statement

We may update this Statement from time to time. When we do, we will post the current version on this site, and we will revise the version date located at the bottom of this page.

We encourage you to periodically review this Statement so that you will be aware of our privacy practices.

This Statement was last updated on January 3, 2022.

______________________________________________________

State of California Privacy Notice - As Prescribed by the California Consumer Privacy Act

Effective Date: January 7, 2022

These California Resident Privacy Terms are effective January 3, 2022 and supplement the information contained in SQrInsurance’s Privacy Statement. This notice applies solely to consumers who are California residents.

We strive to protect the privacy and confidentiality of the personal information with which we are entrusted. This California Resident Privacy Notice explains the personal information we collect or process about California residents in connection with the services we provide or offer to you, including through any site, application, or product that links to this Privacy Notice (the “Service”), how we use, share, and protect that personal information, and what your rights are with respect to your personal information that we gather and process.

In this California Resident Privacy Notice, "personal information" has the same meaning as under the California Consumer Privacy Act (“CCPA”): information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, Personal information does not include information that has been de-identified or aggregated.

Please also note that in certain cases, we may collect your personal information for the Service pursuant to a contract we have with a commercial client (our “Client”). In such circumstances, we may be acting as a “service provider” and are obligated to process the personal information we collect or are provided in connection with the Service in accordance with instructions from or the contract with our Client, which is the business ultimately responsible for determining how your personal information will be handled. Accordingly, if you are using the Service in connection with your role as an employee of our Client, or by virtue of some other relationship with, our Client, we encourage you to review that Client’s privacy notice to understand the full scope of how your personal information will be handled. Further, in any case where we are acting as a service provider to a Client, if you or your authorized agent (together referred to hereinafter, where applicable, as “you”) wish to exercise any rights that may be available to you under certain data privacy laws (for example, the right to access or deletion under the CCPA if you are a resident of California as described below), you should direct your request to our Client, who is the party responsible for receiving, assessing, and responding to your requests, as we do not have any obligation, and, notwithstanding anything in this Privacy Notice to the contrary, may elect not, to respond to your requests. If you are not certain whether we are acting as a service provider to a Client in your particular circumstance, please contact us through one of the methods described at the end of this Privacy Notice.

What Personal Information do We Collect and Share, and for What Purpose?

In the past 12 months, we have not collected and shared the following types of personal information from or about users of the Service, but we may do so on a going forward basis.

We may also use or share de-identified information that is not reasonably likely to identify you for commercially legitimate business purposes.

We do not sell personal information to any third parties, and have not done so in the preceding 12 months.

Your Rights as a California Resident

Under California law, some California residents have specific rights regarding their personal information as described below. These rights are subject to certain exceptions. Further, if we have collected or processed your personal information in connection with a product or service we are providing to our Client that is a company, partnership, sole proprietorship, nonprofit or government agency, and you are an employee, owner, director, officer, or contractor of that entity. When required, we will respond to most requests within 45 days, unless it is reasonably necessary for us to extend our response time.

Right to Disclosure of Information

You have the right to request that we disclose certain information regarding our practices with respect to personal information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:

· The categories of personal information we have collected about you in the last 12 months;

· The categories of sources for the personal information we have collected about you in the last 12 months;

· Our business or commercial purpose for collecting that personal information;

· The categories of third parties with whom we share that personal information;

· The specific pieces of personal information we collected about you;

· If we sold your personal information for a business purpose, a list of the personal information types that each category of recipient purchased; and/or

· If we disclosed your personal information to a third party for a business purpose, a list of the personal information types that each category of recipient received.

Right to Delete Personal Information

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will determine if retaining the information is necessary for us or our service providers to:

· Complete a transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

· Debug products to identify and repair errors that impair existing intended functionality;

· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

· Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);

· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;

· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

· Comply with a legal obligation; and/or

· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If none of the above retention conditions apply, we will delete your personal information from our records and direct our service providers to do the same.

How to exercise the above rights

To exercise your rights to disclosure or deletion described above, please submit a verifiable consumer request to us at  info@sqrinsurance.com or you may call us at +1(646) 267-9005.

Only you or a person who can demonstrate that they are legally authorized to act on your behalf may make a verifiable consumer request related to your personal information.

You may make a verifiable consumer request for access or deletion no more than twice within a 12-month period. The verifiable request must:

· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Such verification process will involve you confirming details of the personal information we have collected about you, and will increase in scope in the event the nature of your request relates to the disclosure of sensitive personal information or the deletion of any personal information. In some instances, you may be required to submit proof of your identity (e.g. a driver’s license); and

· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You will not be required to create an account with us in order to submit a verifiable request, though we may communicate with you about your request via a pre-established account if applicable. However, in order to safeguard the personal information in our possession, if we cannot verify your identity or authority to act on another’s behalf, we will be unable to comply with your request. We will only use personal information you provide when submitting a verifiable request to confirm your identity or authority, or to fulfill your request.

Right to Opt out of Sales of Your Personal Information

As a California resident, you have the right to direct a business that sells your personal information to third parties not to sell your personal information. This right is referred to as “the right to opt-out.” Because we do not sell your personal information, we do not provide any mechanism for you to exercise the right to opt out.

Right to Non-Discrimination

You may exercise your rights under the CCPA without discrimination. For example, unless the CCPA provides an exception, we will not:

· Deny you goods or services;

· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

· Provide you a different level or quality of goods or services; or

· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services

We may offer you financial incentives to provide us with personal information that is reasonably related to the information’s value. This could result in different prices, rates, or quality levels for our products or services. Any financial incentive we offer will be described in written terms that explain the material aspects of the financial incentive program. You must opt-in to any financial incentive program and may revoke your consent at any time by contacting us as indicated below.

Direct Marketing and Do Not Track Signals

Under California’s “Shine the Light” law, California residents may request and obtain a notice once a year about the personal information we shared with other businesses for their own direct marketing purposes. Such a notice will include a list of the categories of personal information that were shared (if any) and the names and addresses of all third parties with which the personal information was shared (if any). The notice will cover the preceding calendar year. To obtain such a notice, please contact us as described below. In addition, under this law you are entitled to be advised how we handle “Do Not Track” browser signals. Because there currently is not an industry or legal standard for recognizing or honoring Do Not Track signals, we do not honor Do Not Track requests at this time.

Minors

We do not knowingly collect personal information from children under the age of 13. If we learn that we have collected any personal information from a child under the age of 13 without verifiable parental consent, we will delete that information from our files as quickly as possible. If you believe that we may have collected information from a child under 13, please contact us at the email address provided below.

We never sell the personal information of minors under 16 years of age, and would not do so in the future without affirmative authorization of the consumer if between 13 to 16 years of age, or the parent or guardian of a consumer less than 13 years of age.

Questions, Requests or Complaints

To submit general questions or requests regarding this Privacy Notice or our privacy practices, please contact us at info@sqrinsurance.com or call us at  +1(646) 267-9005.

*Please note that, as described above, in certain cases we may collect your personal information as a service provider pursuant to a contract we have with a commercial Client to provide the Service. In any case where we are acting as a service provider to a Client, you should direct your requests to exercise your rights available under data privacy laws to our Client, who is the party responsible for receiving, assessing, and responding to your requests. As a service provider, we do not have any obligation, and, notwithstanding anything in this Privacy Notice to the contrary, may elect not, to respond to your requests.