This privacy policy is issued by ICE Insurance (“Privacy Policy”) and applies to all websites and other online platforms managed and/or owned by or on behalf of ICE Insurance (“the Site”). You (hereinafter referred to as “the user”) agree and acknowledge that by accessing the Site and any page thereof ICE Insurance is entitled to collect and use the user’s personal information as set out in this Privacy Policy and the terms of use. By continuing to access or use the Site or by using an email address provided on the Site the user takes note and consents to the use of his/her personal data as described in this Privacy Policy. The user is advised not to access or use the Site or send personal data if he/she does not want ICE Insurance to store or use the data as described in this Privacy Policy.
ICE Insurance reserves the right to vary or amend this Privacy Policy at any time and ICE Insurance is under no obligation to inform the user about such variations or amendments. The most recent version of the Privacy Policy will govern ICE Insurance’s use of the user’s information and will always be available on the Site. By continuing to access or use Site after any changes become effective, the user agrees to accept the revised Privacy Policy.
ICE Insurance respects the user’s privacy and is committed to privacy protection principles. This Privacy Policy describes how the user’s personal data is collected and used and how ICE Insurance fulfils its obligations under applicable data protection law. The headings used for each of the paragraphs of this Privacy Policy do not affect its interpretation. “Personal Data” means personal data that has been collected from users through various functionalities of the Site or by the use of an e-mail address given on the Site.
This Privacy Policy should be read in conjunction with the Terms of Use. Any defined terms used in this Privacy Policy but not defined herein bear the definition given in the Terms of Use.
1. Collecting user data
1.1 ICE Insurance may collect, store and use the following kinds of personal data:
1.1.1 information about the user’s computer and about the user’s visits to and use of the Site (including the user’s IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
1.1.2 information that the user provides when using the various functionalities on the Site (including but not limited to registering, commenting and subscribing) (such information shall include but not limited to the user’s name, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details);
1.1.3 information that the user provides to ICE Insurance when using the services on the Site, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use);
1.1.4 information that the user posts to the Site for publication on the internet (including but not limited to the user’s user name, profile pictures and the content of the user’s posts);
1.1.5 information contained in or relating to any communications that the user sends to One Alliance or sends through the Site;
1.1.6 any additional personal information which ICE Insurance may request from the user from time to time following on from contact the user made with ICE Insurance through the Site. Such information may be necessary or unnecessary for the provision of services on the Site as indicated in any particular case. In no event, however, will the user be requested to provide sensitive personal data about the user or other persons. Please avoid sending ICE Insurance such types of data; and
1.1.7 any other personal information that the user chooses to send to ICE Insurance.
1.2 Before the user discloses to ICE Insurance the personal data of another person, the user must obtain that person’s consent to both the disclosure and the processing of that personal data in accordance with this Privacy Policy.
2. Using personal data
2.1 Personal data and data submitted to ICE Insurance through the Site will be used for the purposes specified in this Privacy Policy or on the relevant pages of the Site.
2.2 ICE may use the user’s personal data to:
2.2.1 administer the Site and business;
2.2.2 Notify the user of any changes to the Site
2.2.3 enable the user’s use of the services available on the Site;
2.2.4 supply to the user services purchased through the Site;
2.2.5 send the user marketing and non-marketing communications that ICE Insurance considers may be of interest to the user unless the user informs ICE Insurance that he/she does not wish to receive such communications;
2.2.6 Inform the user about ICE Insurance events or other related events
2.2.7 Manage subscriptions and participation at registered events;
2.2.8 Send the user information and services as requested by him/her;
2.2.9 administer claims;
2.2.10 execute monitoring and training;
2.2.11 develop new services;
2.2.12 send the user email notifications that the user has specifically requested;
2.2.13 provide third parties with statistical information about ICE Insurance’s users (but those third parties will not be able to identify any individual user from that information);
2.2.14 deal with enquiries and complaints made by or about the user relating to the Site;
2.2.15 keep the Site secure and prevent fraud;
2.2.16 verify compliance with the terms and conditions governing the use of the Site (including but not limited to monitoring private messages sent through the Site private messaging service);
2.3 If the user submits personal data for publication on the Site, ICE Insurance will publish and otherwise use that information in accordance with the licence the user grants to ICE Insurance.
3. Disclosing personal information
3.1 ICE Insurance may disclose the user’s personal data to any of its employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Privacy Policy.3.2 ICE Insurance may disclose the user’s personal data to affiliates of ICE Insurance insofar as reasonably necessary for the purposes set out in this Privacy Policy.
3.3 ICE Insurance may disclose the user’s personal data:
3.3.1 to the extent that it is required to do so by law;
3.3.2 in connection with any ongoing or prospective legal proceedings;
3.3.3 in order to establish, exercise or defend ICE Insurance’s legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
3.3.4 to contracted event co-sponsors in cases where the user is registered for such an event;
3.3.5 to third parties in corporate reorganisations, disposals or acquisitions;
3.3.6 if necessary to protect the interests of ICE Insurance or other users.3.4 Except as provided in this Privacy Policy or with the user’s consent, ICE Insurance will not sell, rent, distribute or otherwise make the user’s personal data commercially available to any third party
4. International data transfers
4.1 Personal data that ICE Insurance collects may be stored and processed in and transferred between any of the countries in which ICE Insurance operates in order to enable One Alliance to use the information in accordance with this Privacy Policy.
4.2 Information and personal data that ICE Insurance collects may be transferred to countries which do not have data protection laws equivalent to those in force in the European Economic Area. In these situations ICE Insurance will ensure (by entering into a written agreement or otherwise) that an adequate level of data protection is maintained by the recipients of the user’s data in accordance with applicable data protection laws of that country.
4.3 Personal data that the user publishes on the Site or submits for publication on the Site may be available, via the internet, around the world. ICE Insurance cannot prevent the use or misuse of such information by others and the user publishes such personal data at his/her own risk. The user acknowledges and agrees that ICE Insurance will not be liable for any direct, indirect, special, punitive, incidental or consequential damages, liability, claim or costs arising from such use or misuse of personal data.4.4 The user expressly agrees to the transfer of personal data described in this Section 4.
5. Retaining personal information
5.1 Personal data that ICE Insurance processes for any purpose or purposes shall be kept for as long as is required by regulations or law.
5.2 Notwithstanding 5.1 above, ICE Insurance will retain documents (including electronic documents) containing personal data:
5.2.1 if ICE Insurance believes that the documents may be relevant to any ongoing or prospective legal proceedings; and5.2.2 in order to establish, exercise or defend ICE Insurance’s legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
6. Security of the user’s personal data
6.1 ICE Insurance will take reasonable technical and organisational precautions to prevent the unlawful destruction, loss, misuse, alteration and all other unlawful forms of processing of the user’s personal data.
6.2 ICE Insurance will store all the personal data the user provides on ICE Insurance’s secure servers.
6.3 The user acknowledges that the transmission of information over the internet is inherently insecure, and ICE Insurance cannot guarantee the security of data sent over the internet.
6.4 When disclosing any personal information via an open network, the user should be mindful that it is potentially accessible to others and consequently can be collected and used by others without the user’s consent. In particular, even when individual data packets are encrypted, the names of the sender and recipient are not. A third party may therefore be able to trace a transaction. Even if both the sender and recipient are located in the same country, data may also be transmitted via such networks to other countries regularly and without controls, including to countries that do not afford the same level of data protection as the country in which the user is accessing the Site.6.5 Personal data may be lost during transmission or may be accessed by unauthorised parties. ICE Insurance does not accept any liability for direct or indirect losses as regards the security of the personal data during its transfer via the Internet. The user must use other means of communication if the user thinks this is necessary or prudent for security reasons.
7. The user’s rights
7.1 The user may instruct ICE Insurance to provide him/her with any personal data One Alliance holds about him/her; provision of such information will be subject to:
7.1.1 the payment of a fee; and
7.1.2 the supply of appropriate evidence of the user’s identity (for this purpose, One Alliance will usually accept a photocopy of the user’s passport certified by a solicitor or bank plus an original copy of a utility bill showing the user’s current address).
7.2 ICE Insurance may withhold personal data that the user requests to the extent permitted by law.
7.3 The user may instruct ICE Insurance at any time not to process his/her personal data for marketing purposes.7.4 The user may also request ICE Insurance to rectify or delete personal data as may be required by applicable data protection law.
8. Cookies
8.1 The Site uses cookies to gather connection data and to understand how users use the Site.
8.2 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.3 Cookies allow the web server to recognise the user’s computer on connection to the Site, which in turn allows the server to make downloading of pages faster than on first viewing. Also cookies may be used to establish statistics about the use of the Site by gathering and analysing various data.
8.4 Cookies do not typically contain any information that personally identifies a user, but personal information that ICE Insurance stores about the user may be linked to the information stored in and obtained from cookies.8.5 Cookies placed on the user’s computer will not be kept longer than necessary for the purposes indicated. It is possible to set the browser on a computer to notify the user when a cookie is being recorded on the user’s computer’s hard drive. It is generally also possible to set the browser to prevent cookies from being recorded on the user’s computer. For the optimal use of the Site, however, ICE Insurance recommends that the user does not block the recording of cookies on the user’s computer. The procedure for refusal of cookies may differ depending on the software product. The user must check with his/her software helpdesk or software supplier if he/she wishes to refuse cookies. If the user chooses not to receive cookies, the user may not be able to use certain functionalities or pages of the Site.
9. Third party websites
9.1 The Site includes hyperlinks to, and details of, third party websites (“External Websites”).
9.2 External Websites are not monitored or maintained by ICE Insurance and ICE Insurance and its affiliates do not endorse or accept any responsibility for their content or operation. The user accesses the External Websites at his/her own risk. This Privacy Policy does not apply to External Websites. ICE Insurance is not responsible for the privacy policies of any External Websites. Please read the privacy policy of each External Website prior to accessing or sending personal data to the site.
10. ICE Insurance’s details
10.1 This Site is owned and operated by ICE Insurance.
10.2 ICE Insurance is registered in England and Wales under registration number 03155942, and our registered office is at 2nd Floor, 109 Uxbridge Road, London, W5 5TL.
10.3 ICE Insurance’s principal place of business is at 112 Houndsditch, London EC3A 7BD.
10.4 The user can contact ICE Insurance by writing to the business address given above or by using the Site contact form or by email or by telephone.