We value your privacy.

Blue Ocean Data Solution Ltd. (“Breeze”, “we” or “us”) is committed to protecting the privacy of the individuals we encounter in conducting our business. Our aim is responsible handling of customer information, balancing the benefits of activities like research and data analytics with our other commitments, including transparency and non-discrimination.

This Privacy Policy (“Policy”) describes the type of information we may collect from you or that you may provide when you visit a Breeze website, mobile application (“App”) or any other interface that links to this Privacy Policy (“Site” or “Sites”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Information That We Collect

We collect and hold a range of information from and about users of our services who have applied for insurance, are insured, or have submitted a claim under our insurance policies. Depending on your relationship with us (for example, as a commercial policyholder; insured business benefiting under another policyholder’s policy, or claimant; witness; commercial broker or appointed representative; or other person relating to our business), Information collected about you and your dependents may include:

Information that may allow you to be personally identified, such as name, postal address, email address, telephone number, and social security number ("personal information").
Business details, such as the number of employees that work at your company, your company's average income, and your company's Federal Employer ID Number (FEIN).
Financial information and account details to enable us to facilitate underwriting and process payments to or from you or your agent.
Recordings of telephone calls to our representatives and to call centers.
Identification numbers issued by government bodies or agencies.
Medical condition and health status
Photographs or video recordings created in connection with our insurance or other business activities, including for claims assessment, processing, settlement, and disputes, or for other relevant purposes as permitted by law.
Information to investigate or prevent crime, including fraud and money laundering.
Information enabling us to provide products and services including:
location and identification of property insured (for example, property address, vehicle license plate or identification number); travel plans; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organization; other insurance you hold; and details on products for which you have or seek a warranty.
Information about your internet connection, the equipment you use to access our Website, and usage details.
Marketing preferences, customer feedback and survey responses.

We and our service providers may supplement the Information we collect with information from other sources, such as publicly available information from social media services, commercially available sources and information from our affiliates or business partners.

How We Collect Your Information

We collect your information in different ways. For example, we gather information from:

applications and other forms related to our products and through conversations with Breeze representatives, including our agents.
use of breezeai.com, our mobile sites and applications, our social media sites and applications, and interactions with our online advertisements.
transactions or experiences with us, such as payments, underwriting, and claims.
non-Breeze parties, including consumer reporting agencies that provide us with information such as driving records, claim histories, and credit information.

Where it is reasonable and practicable to do so, we collect information directly from you or from your insurance broker. This information may be collected using various means including in writing, in person, by telephone, by email or through other electronic messages.

Legal Basis for processing your Personal Information

We are required to have a lawful basis (as defined) in order to process your personal data and the relevant bases which we use are show in the table below.

Purpose of processing

Providing quotations; arranging and administering insurance policies
Arranging Premium Finance/ Consumer Credit
Provision of information on products and services (Marketing)
To notify you of changes in our service
To prevent and detect fraud, money laundering and other financial crimes
To meet general legal or regulatory obligations
Statistical analysis

Lawful Basis

Necessary for the performance of an insurance contract
Necessary for the performance of a consumer credit contract
Our legitimate interests or your explicit consent
Our Legal and Regulatory obligations
Our legitimate interests – to refine and enhance the products and pricing which we can offer

Marketing

We may contact you by email, text, telephone, mail or other agreed means to keep you up to date about our products and services. The legislation allows us to do this in our own commercial interests for certain communications with previous customers. In other circumstances we can only do so with your explicit consent. In all cases you can opt out from receiving such communications at any time.

Disclosure of your Personal Information

As a necessary part of providing you with the services described above we may need to disclose your personal data to other third parties. These may include: Premium Finance companies, Computer bureaux/Software Houses, Insurers, Other Insurance Intermediaries, Insurance Industry databases, Government databases, Credit agencies, Regulatory authorities, the Police and other law enforcement bodies.

Fraud prevention and detection

To prevent and detect fraud we may at any time:

Share information about you with other organisations and public bodies including the Police
Check and/or file your details with fraud prevention agencies and databases
Undertake credit searches and additional fraud searches

We can supply on request further details of the databases which we use.

Credit Search Consent

To make sure you get the best price and terms for your Insurance, we will use the widest possible range of Insurers available to us including some who now carry out searches of their own to protect customers from fraud and to verify identity. They do this using publicly available data which they obtain from a variety of sources, including a credit reference agency and other external organisations to whom they may need to pass some of your personal information. Their search will appear on your credit report whether or not you take out or renew a policy with them. As well as these searches, some Insurers may use a credit check to ascertain the most appropriate payment options for you. This credit check will also appear on your credit report whether or not you take out or renew a policy with them.

Automated decision making and Profiling (if relevant)

For our on-line systems we carry out automated decision making to decide whether we can provide insurance to you and at what price. For all our quotation systems we may use external data from Credit agencies, Electoral Roll, etc. to help in decision-making on pricing and risk acceptance. This may be regarded as “profiling” as defined in the legislation. The legislation for both of these requires safeguards in the event that they have a legal or similarly significant effect on individuals. We do not consider that our processing poses such risks but you have rights to further information on these processes as explained below.

Retention Period

Your data will not be retained for longer than is necessary and will be managed in accordance with our data retention policy. In most cases the period will be for a maximum of 7 years following the expiry of an insurance contract unless we are required to retain the data for a longer period due to business, legal or regulatory requirements.

Your Rights

The right to be informed about how we use your personal data (This Privacy Notice)
The right to see a copy of the personal information we hold about you. (In most cases this will be free of charge)
The right to have personal information rectified if inaccurate or incomplete
The right of erasure of your personal information where there is no compelling reason for its continued processing
The right of erasure of your personal information where there is no compelling reason for its continued processing
The right to data portability which, subject to certain conditions, allows you to obtain and reuse your personal data across different services
The right to object to certain processing including for the purposes of direct marketing
Rights to information in relation to automated decision making and profiling

If you have a complaint about how we use your personal information, please contact us at the address below. You also have the right to lodge a complaint with the Information Commissioner’s office at any time. For further information on this Privacy Notice, to access your personal information or to exercise any of your other rights, please contact The Data Protection Manager, Eyal Goldberg at 201 Haverstock Hill, Second Floor C/O Fkgb, London, England, NW3 4QG
and at eyal@breezeai.com

Privacy Policy

Updated: 05/09/2022

Information That We Collect

Information that may allow you to be personally identified, such as name, postal address, email address, telephone number, and social security number ("personal information")
Business details, such as the number of employees that work at your company, your company's average income, and your company's Federal Employer ID Number (FEIN)
Financial information and account details to enable us to facilitate underwriting and process payments to or from you or your agent.
Recordings of telephone calls to our representatives and to call centers
Identification numbers issued by government bodies or agencies
Medical condition and health status
Photographs or video recordings created in connection with our insurance or other business activities, including for claims assessment, processing, settlement, and disputes, or for other relevant purposes as permitted by law.
Information to investigate or prevent crime, including fraud and money laundering

Information enabling us to provide products and services including:
location and identification of property insured (for example, property address, vehicle license plate or identification number); travel plans; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organization; other insurance you hold; and details on products for which you have or seek a warranty.

Information about your internet connection, the equipment you use to access our Website, and usage details.
Marketing preferences, customer feedback and survey responses

How We Collect Your Information

We collect your information in different ways. For example, we gather information from:

applications and other forms related to our products and through conversations with Breeze representatives, including our agents.
use of breezeai.com, our mobile sites and applications, our social media sites and applications, and interactions with our online advertisements.
transactions or experiences with us, such as payments, underwriting, and claims.
non-Breeze parties, including consumer reporting agencies that provide us with information such as driving records, claim histories, and credit information.

Your agents or brokers
Third-parties you have asked to provide your personal info to us
Publicly available services
Service providers
Other insurers
Credit check bodies
Law enforcement or dispute resolution bodies
Marketing organizations

We will only collect and use your personal information in accordance with applicable privacy laws. Some laws require your consent to collect certain personal information from you and we will first obtain your consent where required by law to do so.

Our websites also utilize technology such as tracking pixels and cookies, which may collect data such as your IP address, referring websites, and unique or returning visitors. This data may be linked with personal information we have collected, such as your name or contact information.

How We Use Your Information

We collect, hold, use and disclose personal information so that we can provide you with products and services including:

Arranging and administering insurance
Risk analysis and underwriting
Management of claims, including investigation and settlement
Accounting and auditing
Complaints and disputes management
Legal, regulatory and compliance purposes
Direct marketing
Perform other activities as required or permitted by law.

Without your personal information, we may not be able to issue insurance coverage, administer your insurance, answer your questions or concerns, or process your claim.

Our websites are not intended for children. We do not knowingly collect any personal information from children under 16-years old.

How We Protect Your Information

We maintain physical, electronic, and procedural safeguards to protect your information and to comply with federal and state laws. In addition, we review our policies and practices, monitor our computer networks, and test the strength of our security. We retain customer information for legal, auditing, regulatory, and business purposes.

We hold your personal information in various internal systems and databases including shared drives, email, and in document management systems. We maintain physical, electronic, and procedural safeguards to protect the security of personal information from misuse and loss, as well as unauthorized access, modification or disclosure.

Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information you might have with us has been compromised), or if you have other data security questions or concerns related to Breeze, please immediately notify us. (See the "Contact Us" section below.)

When Breeze provides your information to a service provider, the service provider will be selected carefully and required to use appropriate measures reasonably designed to protect the confidentiality and security of your information.

If we believe the security of your information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail.

How We Share Your Information

We will share information about you only as permitted by law.

We share customer information, including information about our transactions with you (such as payments) and experiences with you (such as a claim), within our Breeze and with our service providers and agents to help meet your product and service needs. We share your information:

for our everyday business purposes, for public policy purposes, and as permitted (such as with consent or as necessary to complete a transaction you request) or required by law.
as needed, to handle your claim.
in connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of our business or operating unit.
with companies that perform marketing or other services for us or with whom we have joint marketing agreements. These agreements allow us to provide a broader selection of insurance and financial products to you.
as needed, to protect against fraud and unauthorized transactions and in connection with the investigation, establishment, and defense of legal rights.

We may make your personal information available to third-parties as permitted by applicable law to administer our insurance policies or when required by law to do so. We may provide your personal information to:

Contractors or third-parties providing services to us related to the administration of insurance policies such as distributors, agents, claims & loss assessors, claims managers, insurance reference bureaus.
Banks and financial institutions for the purpose of processing your application and payments to/from you or your agent.
Third-party administrators, emergency providers, repairers and suppliers, and investigators for the purpose of processing and administering your claims.
Governmental authorities, law enforcement agencies and dispute resolution bodies and agencies.
Third-party companies that provide certain services for us, which may include name and address verification, email distribution, market research and other business-related services.
Third-party companies for analytics, such as Google Analytics, to evaluate use of our webpages by online visitors.
We do not sell any personal information to marketing companies.

International disclosure of personal information

We are an international insurance company, with offices in several countries. In some circumstances and for the purposes set out above, we may disclose personal information to parties, including our own offices, located in other countries. The laws governing personal data protection vary and the country where your personal information is transferred may have different laws than those in the country in which you reside.

We make all reasonable efforts to ensure that the arrangements we have in place with overseas parties impose appropriate privacy and confidentiality obligations on those parties to ensure that the personal information shared is kept secure and used only for the purposes noted above.

Information we collect through automatic data collection techniques

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including the pages you visit within the Website, the date and time of your visit, the amount of time you spend using the Website, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). See "Choices about how we use and disclose your information".for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Sites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Sites.
Web beacons. Pages of the Sites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-party use of cookies and other tracking technologies

Some content or applications, including advertisements, on the Sites are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see "Choices about how we use and disclose your information".

Choices about how we use and disclose your information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking technologies and advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Disclosure of your information for third-party advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you may opt out by emailing us at using the details in the “Contact Us” section below.
Promotional offers from the Company. You may choose not to receive future promotional, advertising, or other Services-related emails from us by selecting an unsubscribe link at the bottom of such emails that you receive from us. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any "Contact Us" request as well as administrative emails (for example, in connection with a password reset request, an email verification, or a payment-related email) that are necessary to facilitate your use of the Services.

Access and Modification

If you wish to access the personal information we may hold about you or if you believe that the personal information we hold about you is not accurate, complete or up-to-date, you can request access to or correction of the information by contacting us (contact details below).

In order to process any request for access or correction of personal information, we may need to obtain a minimum level of information, including:

Full name
Date of Birth
Details of the request, including supporting information, evidencing the individual’s right to access the data

If you are seeking access to, or correction of, information on another person’s behalf, we will also require written authorization from that individual.

We reserve the right to refuse access to personal information under grounds permitted by applicable privacy laws. There is no fee to access or correct your information but there may be a cost charged, if permitted by applicable law, for providing access to personal information, which reflects the cost of locating and providing the information to you.

Your data will not be retained for longer than is necessary and will be managed in accordance with our data retention policy. In most cases the period will be for a maximum of 7 years following the expiry of an insurance contract unless we are required to retain the data due to business, legal or regulatory requirements.

Consent

By using the Services, you consent to the terms of this Privacy Policy and to our collection, processing and sharing of personal information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Services. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the Site, and your continued use of the Services thereafter means that you accept those changes.

Residents of California

We may collect customer information from persons other than the individual or individuals applying for coverage. Such customer information as well as other personal or privileged information subsequently collected may, in certain circumstances, be disclosed to third parties without your authorization as permitted by law. If you would like additional information about the collection and disclosure of customer information, please contact your Breeze agent.

Per Cal. Civ. Code § 1798.100-§ 1798.198 (“The California Consumer Privacy Act of 2018”), you have the following rights, subject to our legal and records retention obligations:

To request information from us about the categories of or specific personal information we maintain about you and the categories of the sources of such information.
To request we delete personal information we have collected from you.
To contact us with questions or concerns about our privacy policy or practices.
You will not receive any discriminatory treatment by exercising these privacy rights.

We will respond to all reasonable, verified requests within the amount of time required by applicable law. If you want to exercise any of these rights, please contact us using the details available in the “Contact Us” section.

Residents of Nevada

Nevada law requires us to disclose that you may elect to be placed on our internal “do not call” list should you wish not to receive marketing calls from Breeze. If you have already been placed on our internal “do not call” list please disregard this notice. You may request to be placed on Breeze’s internal “do not call” list by:

contacting your Breeze agent, OR
writing us at the address available in the “Contact Us” section.

Residents of Vermont

Breeze will not share certain customer information across our Breeze family of companies unless authorized by you. This does not limit Breeze from sharing information about your transactions with us (such as your payment history) or your experience with us (such as your claim history) as permitted by law.

Children's Privacy.

The Services are not structured to attract children under the age of 13 years. Accordingly, we do not intend to collect personal information from anyone we know to be under 13 years. If we learn that we have collected personal information from a child under 13 years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at support@Breeze.com.

HIPAA.

Breeze is not an entity that is covered by the Health Insurance Portability and Accountability Act (“HIPAA”). The HIPAA privacy rules apply to health plans, health care clearinghouses, to any health care provider who transmits health information in electronic form in connection with transactions for which the Secretary of Health and Human Services has adopted standards under HIPAA (the “covered entities”) and their service providers (“business associates”). This means that the information that you provide to Breeze is not protected by the HIPAA privacy rules and regulations. You may not submit or otherwise make available any protected health information (as that term is defined under HIPAA) to Breeze.

Contact us

If you have any questions or concerns about how we handle your personal information, please contact us (contact details below).

If you have contacted us with a complaint and you are not satisfied with our response, you may refer your complaint to your state privacy regulatory authority. If you reside in the United States, complaints can be made with the state insurance regulator. If you reside outside the United States and your country has a privacy commissioner, information about submitting complaints should be available on their web site. If you reside in the European Union, you also have the right to lodge a complaint with the Information Commissioner’s office at any time.

For further information on this Privacy Notice, to access your personal information or to exercise any of your other rights, please contact Breeze support email, phone, address

Appendix

California Consumer Privacy Act Supplement

This Supplement ("Supplement") applies only to California residents. It describes our collection and use of Personal Information that is subject to the California Consumer Privacy Act ("CCPA") and your rights under that law. This Supplement does not apply to information that is exempt from or otherwise unregulated by CCPA.

Personal Information we may collect and the purposes for which we may use it "Personal Information" is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer (a natural person who resides in California) or household in California. We collect some or all the following categories of Personal Information about you and your household:

"Identifiers" such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
"CCR Categories" may include the following categories of Personal Information described in the California Customer Records statute: name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
"Protected Classification Characteristics " under California or federal law such as age, marital status, and gender.
"Commercial Information" may include records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
"Biometric Information" means an individual's physiological, biological, or behavioral characteristics that can be used to establish an individual's identity. Examples may include fingerprints; face, hand, palm or vein pattern imagery; voice recordings; or sleep, health, or exercise data that contain identifying information.
"Internet or Other Electronic Network Activity Information" may include, for example, website information, browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement.
"Geolocation Data" about physical location or movements.
"Sensory Data" such as recorded phone call and other audio recordings.
"Professional or Employment-Related Information" such as information about current or past employment.
"Education Information" such as education level.
"Inferences" drawn from other Personal Information to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
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Our Personal Information practices

This section describes our practices with respect to Personal Information. For each category of Personal Information that we collected about consumers and may collect about you and your household, we describe the categories of (1) sources from which the Personal Information has been collected from and (2) Third Parties with whom the Personal Information has been shared.