Privacy Notice

In the course of its business, Radix ILS Holdings Ltd. (“Radix ILS”), may come in to possession of and use certain Personal Information, which may also include Sensitive Personal Information. Bermuda’s Personal Information Protection Act 2016 (“PIPA”) came in to force on 1 January 2025 and we respect your right to privacy and the protection of your Personal Information against unauthorized use or disclosure.

This Privacy Notice details how we will collect, use and share Personal Information from you in the business process of Radix ILS.

This Privacy Notice does not form part of a contract with Radix ILS and does not confer any contractual rights on you, or place any contractual obligation on us.

Definitions

  • “Personal Information” means any information about an identified or identifiable natural person.
  • “Use” or “using”, in relation to Personal Information, means carrying out any operation on personal information, including collecting, obtaining, recording, holding, storing, organising, adapting, altering, retrieving, transferring, consulting, disclosing, disseminating or otherwise making available, combining, blocking, erasing or destroying it.
  • “Sensitive Personal Information” means any Personal Information relating to an individual’s place of origin, race, colour, national or ethnic origin, sex, sexual orientation, sexual life, marital status, physical or mental disability, physical or mental health, family status, religious beliefs, political opinions, trade union membership, biometric information or genetic information.

Personal Information Collected

Radix ILS will underwrite reinsurance business and we may collect Personal Information about you during our business process in various media, whether in in writing (including electronically) or by telephone, either from you or via a third-party service provider.

  • Clients – In particular, we may collect:
    • Contact information such as your name, address, phone number, email address and date of birth;
    • KYC Information (e.g. copies of passports, utility bills or other proof of address); and/or Financial Information (e.g. bank account details and source of wealth information).
  • Intermediaries and Business Partners – For brokers, intermediaries and business partners, we may collect and use Personal Information including:
    • General information such as your name, address, contact phone numbers and email addresses;
    • Identification information such as passport details, driving license and national insurance number;
    • Job information such as job title and previous roles;
    • Information which we obtain as part of checking sanctions lists, such as those published by United Nations, European Union, UK Treasury, the U.S. Office of Foreign Assets Control and the U.S. Department of Commerce, Bureau of Industry and Security;
    • Information (including publicly available information) obtained as part of our due diligence checks; and/or
    • If you attend an event with us, we may collect relevant details such as your event preferences and dietary requirements.
    We will collect other data from you directly as part of our on-boarding processes for business partners and intermediaries. In addition to this we will collect data from:
    • Invoices, contracts, policies, and correspondence;
    • Publicly available sources such as internet search engines; and
    • Service providers who conduct sanctions checks.
  • Employee Personal Information – For employees (including part and full-time) Radix ILS will be required to collect and use your Personal Information required to maintain your employee status. This will include:
    • Your name and address;
    • Your bank details;
    • Records of your performance reviews;
    • Details of any disciplinary action;
    • Your remuneration;
    • Any medical conditions that you have informed us about;
    • Records of when you enter and leave the building where our offices are located.
  • Prospective job applicants – If you are applying for a job with us, this section will be relevant to you and sets out our uses of your Personal Information. The Personal Information that we will collect from you will include:
    • Your name, address, contact phone numbers and email addresses, date of birth and gender;
    • Information about your job such as job title and previous roles;
    • Information about your right to work;
    • Other information (including publicly available information) obtained as part of any due diligence process.

Purposes of Personal Information

The Personal Information you provide to us may be used during the Radix ILS business process where it relates to the management and administration of: (a) investment allocations to Radix ILS, (b) reinsurance agreements in any form (including derivatives) and/or (c) services agreements. Such processing activities may include:

  • Verifying your identity and conducting due diligence on you for the purposes of credit assessment;
  • Conducting our KYC process (including Anti-Money Laundering and Anti-Terrorist Financing procedures);
  • Complying with any of Radix ILS’ global legal, regulatory or compliance requirements;
  • Obtaining legal advice for Radix ILS’s benefit, including in relation to potential or actual disputes;
  • Processing for internal operational, analytical business purposes;
  • Providing you with information concerning other Radix ILS’ products and services;
  • Business development meetings and events;
  • Identifying and investigating fraud and other crimes.

Lawful Uses of Personal Information

There are a number of lawful bases on which we may use your Personal Information including where use is:

  • Performance of a contract (or to enter into a contract) between Radix ILS and you;
  • Where you have expressly consented to such use, which consent you have the right to withdraw at any time;
  • Necessary in the context of your present, past or potential employment relationship with us;
  • Except for Sensitive Personal Information, where a reasonable person would consider that you would not reasonably request that our use not begin or cease, and such use does not prejudice your rights;
  • Necessary to comply with a provision of law that authorises of requires such use; and/or
  • Reasonable to protect or defend us in any legal proceedings.

Personal Information Disclosed to Others

Your Personal Information will only be disclosed as permitted by applicable laws. Generally, we will not disclose your Personal Information to third parties except in the following, limited circumstances:

  • To service providers and other vendors that assist Radix ILS in the use of Personal Information;
  • To service providers that assist us to service your business account(s) with us, including but not limited to any external legal counsel, third-party fund administrator, financial institution, auditor, consultant and other professional advisor;
  • Radix ILS’s pension, healthcare insurance and other benefits providers as well as other general employee service providers;
  • Our authorised employees (when there is a legitimate reason for sharing in accordance with our policies and procedures) and systems administrators
  • Where you specifically request or authorize us to do so;
  • Where we reasonably believe that disclosure is required or permitted by any applicable laws or regulations, including any compliance by us with same.

We require any third parties to whom we disclose your Personal Information to use only the Personal Information required for the services for which we agree to work with them, and to protect the confidentiality and security of this Personal Information.

Safeguarding Personal Information

We maintain physical, electronic, and procedural safeguards consistent with commercially reasonable practices to protect your Personal Information. Please note that no method of transmission over the internet or form of electronic communication is completely secure. We will always aim to protect your Personal Information, we cannot guarantee its complete security.

Retaining your Personal Information

We will retain your Personal Information for no longer than is necessary for the purpose of its use, and always for as long as required under applicable laws and consistent with good practice. Personal Information that is no longer relevant to your relationship with us will be deleted in a reasonable amount of time, consistent with applicable legal requirements, and our internal data management policies, procedures and retention periods.

International Personal Information Transfer

Radix ILS is based in and operates only from Bermuda. However, it is possible that as part of our business, services will be given by third parties based in other jurisdictions, which may have different privacy and data protection laws than those that apply in your home jurisdiction. Further, we may also transfer your Personal Information overseas to comply with reasonable requests under our legal or regulatory obligations. Regardless of the location of your Personal Information, we will continue to take reasonable steps and adopt appropriate safeguards against risk (proportional to the potential harm, sensitivity and context of the Personal Information) to adequately protect your Personal Information against loss, unauthorized access, destruction, use, modification, disclosure or other misuse.

Your Rights

Under PIPA you have a number of rights in relation to your Personal Information. You can exercise your rights by contacting us using the details below. Under Part 3 of PIPA, you have certain rights with respect to your Personal Information and you may submit to reasonable written requests to the Radix ILS Privacy Officer to:

  • Access (i) your Personal Information that is in Radix ILS’s custody or control; (ii) the purposes for which Radix ILS has been or is using your Personal Information; and (iii) the names of persons or types of persons and circumstances for which your Personal Information has or is being disclosed;
  • Correct an error or omission in any of your Personal Information which is under Radix ILS’s control;
  • Block, which is to cease, or not to begin, using your Personal Information for the purposes of advertising, marketing, or public relations, or where the use of that Personal Information is causing or is likely to cause substantial damage or substantial distress to you or another individual; and
  • Erase or destroy Personal Information about you where that Personal Information is no longer relevant for the purposes of its use (however, there may be circumstances where Radix ILS will be legally entitled to retain it).

Where we rely on your consent in order to use your Personal Information, you have the right to withdraw such consent to further use.

Cookies

To protect your privacy, we do not use third party cookies or other technologies to collect data when you browse on this site.

Complaints

If you believe your Personal Information has been misused you have a right to complain to the Office of the Privacy Commissioner for Bermuda at privcom@privacy.bm. The Privacy Commissioner’s Office’s address is Maxwell Roberts Building, 4th Floor, 1 Church Street, Hamilton HM11, Bermuda.

Contacting Us

If you have any questions or concerns about this Privacy Notice or our data privacy and protection policy, please contact the Radix ILS Privacy Officer at:

  • Radix ILS Holdings Ltd.
  • 3rd Floor, Windsor Place
  • 22 Queen Street
  • Hamilton HM11
  • Bermuda
  • privacy@radixils.com

Privacy Notice Updates

This Privacy Notice is subject to change in accordance with changes to applicable laws or our internal policies and procedures.

Any changes to this Privacy Notice will be effective upon publication of the revised Privacy Notice.