Data Protection Notice – Toredo Platform

Who is responsible for your personal information?

Liberty Managing Agency Limited, for and on behalf of the Underwriting Members of Lloyd’s Syndicate 4472 and Liberty Mutual Insurance Europe Limited ( “we”, “our”, or “us”), are the data controllers for personal information held by it about you for the purposes of applicable data protection laws.

“You” shall include, as relevant, brokers, suppliers and contractual counterparties, including sole traders, a company’s owners, directors, partners and/or any individual who may interact with us and the www.toredounderwriting.com web site (“Site”).

What details do we collect and why?

When you register to use the Site, we collect information about you including (but not limited to) your name, your employer’s name, your work address (including your country location), and your email address. We may collect personal data from you directly through the Site or from third parties. We will use the information you provide or we collect to allow access to the Site, manage and handle your queries, for the performance of a contract entered into with Liberty Managing Agency Limited / Liberty Mutual Insurance Europe Limited (or in correspondence before entering into a contract), to underwrite insurance policies, for claims handling or to facilitate our business relationship with you. We may use your personal information for our business processes and activities including analysis, review, planning and business transactions, dealing with insurance and/or legal claims; and for compliance with our legal and regulatory obligations. To provide you with products and services, we hold information in our data systems (both inside and outside of the EEA) or data may be held by our agents or subcontractors or by other Liberty Mutual Insurance Group companies (including those in the USA). Your personal data may be stored within our relationship management and business contact system to develop our relationship with you.

By giving us your personal information you will be agreeing to us, our agents, other insurers and the other persons who we describe in this notice processing this information for all purposes as are relevant to your relationship with Liberty Managing Agency Limited/Liberty Mutual Insurance Europe Limited. Before you provide information about others, you should make sure they are aware of how we will use their information and have given their permission.

We may amend the personal information so that you cannot be identified from the data either by itself or when combined with any other data we hold. That data will then not be subject to this notice or data protection law. We may use it for insurance administration purposes including analysis of trends, carrying out actuarial work, planning service delivery, risk assessment and costs and charges. The data will be retained by us in accordance with our retention policy for the time necessary for fulfilling the purposes set out above.

What details do we share, who with and why?

Your personal information may be noted within policy documentation e.g. name, email address. We may share this policy documentation with:

Other personal information may be retained within our systems for relationship development. This may be shared across the Liberty Mutual Insurance Group companies for business management purposes.

Your personal information may be transferred to the persons/organisations listed above for the following purposes: providing access to and services in relation to the Site, analysing insurance needs, providing estimates and quotes for a Policy, carrying out any of our obligations under a relating Policy, claims handling, resolving any queries or issues that may arise under a relevant Policy and also for any other strategic and operational purposes such as, for example, purchasing reinsurance and managing our business.

We may also transfer your personal information to the police, other law-enforcement agencies, government agencies or regulatory authorities, and any other person or organisation to comply with insurance law or where necessary to perform any insurance contract arranged by you, for the purposes of fraud protection, credit risk reduction, law enforcement or the administration of justice, in order to protect ourselves from risk or to ensure regulatory compliance or good governance.

Where such persons/organisations are located outside of the EEA, this may involve the transfer of your personal information outside of the EEA. Countries outside of the EEA may not have a similar standard of data protection laws to the UK; however, we will require your personal information to be protected to at least UK standards. You have the right to object to the transfer of your personal information to third parties set out above that are located outside of the EEA by contacting us on the details provided at the end of this Notice. If you do not provide requested personal information or object to it being transferred in the manner detailed above and your objection is upheld, we or other relevant third parties may not be able to provide the appropriate type or level of services you require.

Objecting to processing; accessing, correcting and obtaining copies of your personal information and contacting us

You may object to the processing of your personal information in accordance with this notice, but please note that this may result in our not being able to provide the appropriate type or level of services you require.

You have the right to request a copy of the information we hold about you. You may also request information about: the purpose of the processing; the categories of personal data concerned; who else might have received the data from us; what the source of the information was (if you didn’t provide it directly to us); and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by us if it is inaccurate. You may request that we erase that data or cease processing it, subject to certain exceptions. In the UK, you have a right to lodge a complaint with the Information Commissioner’s Office if you have concerns about how we processes your personal data. When technically feasible, we will at your request, provide your personal data to you or transmit it directly to another data controller. Please help us to ensure your personal information is accurate by telling us as soon as reasonably possible in the event of change of address, contact details or other circumstances.

In order to exercise any of the above rights, please contact our Data Protection Officer at dataprotectionofficer@libertyglobalgroup.com or Liberty Specialty Markets, 20 Fenchurch Street, London, EC3M 3AW.

Cookie Statement

By accessing and using the Site you indicate that you accept our use of cookies.

Cookies help us to give you tailored experiences on our website.

If you are worried about privacy, it is possible to change your settings to disable cookies.

3 things to know about how we use cookies

  1. The reason we use cookies is so that your machine and our servers recognise each other
  2. No personal data captured by our cookies is used for any other purpose, other than advised below.
  3. Where you have shown engagement with particular content on this site, cookies allow us to show you content we expect you’ll have an interest in, allowing you to find useful content faster.

What are cookies

Cookies are small text files that are placed on your computer, tablet, smartphone, smartTVs or other devices by websites, web portals and applications that you visit. They are widely used in order to recognise your device, record some aspect of a website and to provide information to the owners of the website on your preferences or past actions.

The rules on cookies are covered by the EU e-Privacy Directive. The Information Commissioner’s Office (ICO) in the UK is responsible for enforcing these rules and further information can be found at: https://ico.org.uk/for-organisations/guide-to-pecr/cookies-and-similar-technologies/ and https://ico.org.uk/for-the-public/online/cookies/.

How and why we use cookies

Nearly all well-known websites rely on cookies to give you a good digital customer experience. We use cookies to give you the best experience when you visit our website. They allow us to tailor the content of our website, so we can show you services or products we think you may be interested in, making it quicker and easier for you to find what you need. Cookies can also make it easier for you to manage your accounts, policies, or login details, and when applying for products and services.

The cookies we use on the Site are below:

Links to sites provided by others

If you follow a link from our website to another website, please be aware that the owner of the other website will have their own privacy and cookie policies for their site. We recommend you read their policies, as we are not responsible or liable for what happens at their website.

Changing your browser settings for cookies

You can adjust the settings in your web browser to determine whether sites can set cookies on your device. If you've visited this site before, there may be previously set cookies on your computer. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

Alternately, you can find out how to delete them from the sites listed below:

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.


PLEASE READ THE PRIVACY NOTICE SET OUT ABOVE CAREFULLY. BY DOING BUSINESS WITH US YOU AGREE TO ANY OF YOUR PERSONAL INFORMATION THAT YOU HAVE PROVIDED BEING COLLECTED, USED AND DISCLOSED BY US AND THIRD PARTIES IN ACCORDANCE WITH THIS PRIVACY NOTICE AND YOU CONFIRM THAT ANY THIRD PARTIES WHOSE PERSONAL INFORMATION YOU HAVE PROVIDED HAVE AGREED TO YOU USING THEIR PERSONAL INFORMATION IN THIS WAY AND THAT THEY HAVE ALSO READ AND AGREE WITH THE TERMS OF THE PRIVACY NOTICE APPLICABLE TO THEM.