Privacy Notice

In the course of its business Radix ILS may come in to possession of certain “Personal Information” with us. 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, process and share Personal Information from you in the business process of Radix ILS.

Personal Information Collected

Although Radix ILS will underwrite reinsurance business (which is not in scope of PIPA), 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. In particular, we may collect:

  • Contact Information, including business details;
  • KYC Information, including credit information; and
  • Financial Information.

Purposes of Personal Information

The Personal Information you provide to us may be processed 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.

Processing of Personal Information

There are a number of bases on which we may process your Personal Information:

  • Performance of contractual obligations mutually accepted by Radix ILS and you;
  • Where you have given consent expressly to such processing, which consent you have the right to withdraw at any time;
  • The processing is necessary for the purposes of pursuing our legitimate interests; and/or
  • The processing is necessary to comply with a legal obligation, court order, direction of a regulatory authority or to otherwise commence or or defend legal claims.

Information Disclosed

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 processing of Personal;
  • To service providers that assist us to service your business account(s) with us, including but not limited to any external counsel, third-party fund administrator or bank;
  • Where you specifically request or authorize us to do so;
  • Where we reasonably believe or are advised by counsel that disclosure is required or permitted by any applicable law or regulation, including any compliance by us with same.

We require third parties to use only the information required for the services for which we agree to work with them, and to protect the confidentiality and security of this 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 as long as required under applicable laws and consistent with good practice. 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.

Intermediaries and Business Partners

For brokers, intermediaries and business partners, we may collect and process personal data including:

  • General information such as your name, address, contact phone numbers and email addresses;
  • Identification information such as passport details, driving licence 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;
  • If you attend an event with us, we may collect relevant details such as your event preferences and dietary requirements.

We will collect data from you directly as part of our onboarding processes for business partners and intermediaries. In addition to this we will collect data from:

  • Invoices, contracts, policies, correspondence, and business cards;
  • Publicly available sources such as internet search engines;
  • Service providers who conduct sanctions checks.

Employee Data

During any employment term Radix ILS will be required to collect and process your personal data 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.

In order to run our business and meet our employers’ obligations, we will share your personal data with a number of third parties involved in providing you with your remuneration, benefits, and other general employee services.

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 data.

The personal data 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.

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 regulatroy obligations. Regardless of the location of your Personal Information, we will continue to safeguard the retention and protection against unauthorised use of your Personal Information.

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 are entitled to a copy of the Personal Information that we hold about you, subject to certain restrictions. Depending on the jurisdiction in which you are based, you may have the right to request from us access to and rectification or erasure of your Personal Information, the right to restrict processing, object to processing and in certain circumstances the right to data portability. Where we rely on your consent in order to process 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 Commissioners 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:

  • Peter Dunlop
  • Radix ILS Holdings Ltd.
  • 3rd Floor, Windsor Place
  • 22 Queen Street
  • Hamilton HM11
  • Bermuda

privacy@radixils.com