Privacy Statement

Use of this Website

Except as otherwise stated, Odyssey Group Holdings, Inc. (“Odyssey Group”) does not collect data containing confidential or personally identifying information (also referred to as Personal Data, Sensitive Personal Data and Personally Identifiable Information and, collectively, “PII”) from visitors to this website, unless provided by the visitor or the visitor’s internet browser. Odyssey Group has adopted policies to protect the confidentiality of your PII, and to limit access to those with a need to know such information. Odyssey Group will not use the information provided through your use of this website, except to respond to direct enquiries or to measure traffic and traffic trends at this website. Odyssey Group does not provide or sell any of this information to third parties.

Visitors to this website should be aware that Odyssey Group may collect information using cookies or similar technology, in compliance with applicable law and regulation. Cookies are small files that are written to visitors’ computers or mobile devices when they visit a website. Visitors’ browsers send the cookies back to this website every time they re-visit it, in order that this website may recognize the browser or for record-keeping purposes. Where such cookies are used, visitors may opt-out of receiving cookies by changing their browser settings.

Odyssey Group reserves the right to change its policy regarding cookies and the collection of information from visitors to this website at any time without advance notice. Should any new policy be put into effect, Odyssey Group will post it on this website and the new policy will apply only to information collected thereafter. Any such policy will permit visitors to “opt out” of the collection of PII.

Use and Disclosure of Your PII

Odyssey Group limits the collection, disclosure and use of PII to only what is needed to properly produce, underwrite, service and administer its insurance and reinsurance products and/or to fulfill legal or regulatory requirements and includes, but is not limited to:

• producing business
• quoting, underwriting and renewing insurance products
• policy administration
• claims administration, adjusting and management
• fraud detection, investigation, prosecution and prevention
• loss control
• other purposes outside the (re)insurance lifecycle that are necessary for the provision of (re)insurance throughout the insurance (re)lifecycle period
• business activities that Odyssey Group may legally undertake

Please note that Odyssey Group may also disclose PII for these purposes to its service providers, contractors, agents and other group companies that perform activities on its behalf.

Odyssey Group does not sell information to any third parties and does not use it for marketing any of its insurance products.

Types of PII Odyssey Group May Collect About You

In order for Odyssey Group to provide (re)insurance quotes, (re)insurance products and/or handle any claims or complaints, it needs to collect and process PII. The types of PII Odyssey Group collects and processes in the course of conducting such business may include:

• Individual Details – Name, address (including proof of address), other contact details (for example, email address and telephone numbers), gender, marital status, date and place of birth, nationality, employer, job title, employment history and family details, including their relationship to you.
• Identification Details – Identification numbers issued by government bodies or agencies, including your Social Security number, national insurance number, passport number, tax identification number and driver’s license number.
• Financial Information – Bank account or credit/payment card details, income or other financial information.
• Risk Details – Information about you which Odyssey Group needs to collect in order to assess the risk(s) to be (re)insured and provide a quote. This may include data relating to your health, criminal convictions or other special categories of PII. For certain types of products, this could also include telematics data.
• Insurance Policy Information – Information about the quotes you receive and policies you take out.
• Credit and Anti-Fraud Data – Credit history, credit score, sanctions, criminal offenses and information received from various anti-fraud databases relating to you.
• Previous and Current Insurance Claims – Information about previous and current claims (including other unrelated insurances), which may include data relating to your health, criminal convictions or other special categories of PII and, in some cases, surveillance reports.
• Special Categories of PII – Health records, criminal convictions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric or data concerning sex life or sexual orientation.

Where Odyssey Group Might Collect Your PII From

Odyssey Group might collect your PII from various sources, including:

• you
• your family members, employer or representative
• other insurance market participants
• the internet
• credit reference agencies
• anti-fraud databases, sanctions lists, court judgments and other databases
• government agencies
• the open electoral register
• in the event of a claim, third parties, including other parties to the claim (claimant / defendant), witnesses, experts (including medical experts), loss adjustors, attorneys and claims handlers

Which of the above sources apply will depend on your particular circumstances.

If you send personal correspondence, such as emails or letters, to Odyssey Group or if other users or third parties send correspondence about your activities or postings on our site to Odyssey Group, irrespective of the source of the PII, Odyssey Group may collect such information in a file specific to you. Odyssey Group uses information in the file that it maintains for you and other information that Odyssey Group obtains from your use of its services to resolve disputes, troubleshoot problems and enforce this website’s Terms and Conditions of Use.

Safeguarding Your Privacy

Odyssey Group is committed to protecting your privacy. Odyssey Group maintains physical, electronic and procedural safeguards to protect your PII from unauthorized access. Odyssey Group regularly reviews its policies and practices, monitors its computer networks, tests the strength of its security and monitors its compliance with applicable laws and regulations in order to help it ensure the safety of your PII.

Access to PII is limited to those employees and authorized representatives, attorneys and service providers who specifically need such information to conduct their business responsibilities on behalf of Odyssey Group. If you conclude your relationship with Odyssey Group, Odyssey Group will continue to safeguard your privacy in accordance with the standards described in this Privacy Policy.

All employees of Odyssey Group are required to comply with this Privacy Policy. Employees who violate this Privacy Policy are subject to disciplinary measures.

Odyssey Group cannot ensure that all of your private communications and other PII will never be disclosed in ways not otherwise described in this Privacy Policy. For example, Odyssey Group may be forced to disclose information to the government, to regulators having jurisdiction, on the order of a court of competent jurisdiction, in response to a statutory obligation or, under certain circumstances, to third parties. In addition, third parties may unlawfully intercept or access transmissions or private communications. Odyssey Group can (and you authorize Odyssey Group to) disclose any information about you to law enforcement or other government officials as Odyssey Group, in its sole discretion, considers necessary or appropriate in connection with an investigation of fraud, intellectual property infringements or other activity that is illegal or may expose Odyssey Group to legal liability.

Odyssey Group may use affiliated companies and/or service providers located outside of the European Union to process and store PII. Those transfers would always be made in compliance with applicable laws and regulations. If you are located in the European Economic Area (“EEA”) and would like further details about how your PII would be protected if transferred outside the EEA, please contact Odyssey Group’s General Counsel’s Office as indicated below.

Linked Sites

For your convenience, this site contains links to other sites not under the control of Odyssey Group. Odyssey Group is not responsible for the privacy practices or the content of such websites. For more information about Odyssey Group’s policies with regard to such third party websites, please see the “Notices” section of this website.

Accessing Your PII

Where permitted by applicable law or regulation, you have the right to access your PII that is in Odyssey Group’s possession or under its control, in order to verify the accuracy and completeness of such PII. To request access, please send your written request to Odyssey Group’s General Counsel as indicated below. Odyssey Group will respond to your request within thirty (30) days or advise you if additional time is required to respond to your request.

There may be situations in which Odyssey Group is legally prohibited from allowing – or not legally required to allow – you access to your personal information. If this is the case, Odyssey Group will advise you of why, subject to any legal restrictions.

Please note that, in certain circumstances, such as manifestly unfounded or excessive requests, a reasonable processing fee may apply, or Odyssey Group may refuse to act on your request.

Rectification and/or Erasure of Your PII

If you believe that any of your PII is incorrect, you may request that it be amended or rectified, where permitted by applicable law or regulation. Odyssey Group will rectify PII that is demonstrated to be inaccurate or incomplete and will make reasonable efforts to advise other parties to whom Odyssey Group has supplied your PII of required corrections.

Subject to applicable law or regulation, you may be entitled to erasure of the PII Odyssey Group holds about you. If you wish us to erase your PII from our systems, you may request that it be deleted.

To request that your PII be rectified and/or erased, please send your written request to Odyssey Group’s General Counsel as indicated below. Odyssey Group will respond to your request within thirty (30) days or advise you if additional time is required to respond to your request.

There is no charge for rectifying and/or erasing PII from Odyssey Group’s systems.

Questions or Concerns

If you have any questions or concerns about this Privacy Policy, Odyssey Group’s data protection practices or your dealings with this website, you can contact the General Counsel’s Office at:

Odyssey Group Holdings, Inc.

Attn: General Counsel

300 First Stamford Place

Stamford, CT 06902

communications@odysseygroup.com

You may also have the right to lodge a complaint with the relevant supervisory authority/ies.

Email

Odyssey Group appreciates your questions and comments about our website and services and welcomes your email messages to mailboxes listed on this website. Odyssey Group will share your messages with those within its organization that are most capable of addressing the issues contained in your message. Odyssey Group will keep a copy of your message until it has had an opportunity to address your concerns. Odyssey Group may archive your message for a certain period of time or discard it, as appropriate.

Connecticut Privacy Protection Notice

Odyssey Group will take reasonable measures to protect the confidentiality of Social Security numbers and limit access to those with a need for such information. Odyssey Group prohibits the unlawful disclosure of Social Security numbers.

Changes to this Privacy Policy

This Privacy Policy may be amended from time to time. Please check this website for any amendments and for the current version of this Privacy Policy.

Last Updated: February 1, 2022