This Privacy Notice explains how SoteriaRe collects, holds, uses, and discloses personal information and other information about you in connection with your use of www.soteriare.com (this “Website”) for business purposes and in delivering its reinsurance products and services (collectively "Services").

This Privacy Notice applies only to this Website and the Services. If you use other websites and/or other products or services offered by us or any of our affiliated entities, please review the applicable privacy policy (or policies) associated with those websites, products, and service.

This Privacy Notice is intended to provide individuals with clear and easily accessible information about our practices and policies with respect to personal information and is intended to comply with the requirements of the Personal Information Protection Act 2016 of Bermuda (“PIPA”).

This Website may contain links to third party websites that are not operated or controlled by SoteriaRe (“Third Party Websites”). Please note that the Third-Party Websites are not subject to this Privacy Notice. We are not affiliated with, nor do we control, any of these third parties. Your use of any such Third-Party Website, and such Third-Party Website’s collection, processing, or use of your personal information, is subject to the privacy policy (if any) and any applicable terms and conditions associated with such Third-Party Website. Please review the privacy policy (if any) and applicable terms and conditions associated with each Third-Party Website for information about that third party’s privacy and data protection practices. We shall not be responsible or liable for any loss or damage in connection with any aspect of any Third-Party Website, including, without limitation, its privacy and/or data protection practices or the content of such Third-Party Website.

Who we are

This Website is made available to you by Soteria Reinsurance Ltd., a wholly owned subsidiary of Soteria Reinsurance Holdings LLC, (together referred to in this Privacy Notice as “SoteriaRe^SM”, “we” and “us”) a wholly owned subsidiary of FMR LLC, the parent company of Fidelity Investments. In this Privacy Notice, FMR LLC and all other subsidiaries and affiliates of FMR LLC are referred to as “Affiliated Companies”.

How and why we obtain and use personal information

We, our Affiliated Companies, and our unaffiliated third party service providers (e.g., technology service providers, providers of administrative services, etc.) may collect personal information and other information about you when you use this Website, and when you interact with us, our Affiliated Companies, or our service providers regarding this Website. We, our Affiliated Companies, or our service providers may also collect certain information through the software (e.g., web browsers) and devices that you use to access this Website or any of the services or other electronic communications from us (for example, device type, browser type, internet protocol address, pages visited on this Website, and time spent on this Website or using the services).

We may also collect personal information from third parties including vendors and ceding companies to assist with the pricing of the risk or fulfilment of regulatory obligations.

Personal information means any information about an identified or identifiable individual such as your name, postal and email addresses, and telephone, fax, and mobile numbers. Please note that information by which an individual cannot be identified (for example, anonymous, de-identified, or aggregate information) is not considered personal information and therefore is not subject to this Privacy Notice.

We may use the information that we, our Affiliated Companies, or our service providers collect:

• To allow you to use this Website, and to facilitate and personalize your interactions and experiences with us;
• To respond to inquiries from you and fulfill requests from you;
• To market and communicate to you and your firm;
• To provide and improve this Website, the Services, and develop, offer, and deliver other products and services;
• For our and other Affiliated Companies’ respective business purposes, such as reporting, planning and analytical purposes, and training and quality control purposes;
• To detect and prevent fraudulent, malicious, or illegal activity, for risk control and mitigation purposes, and to fulfill legal, judicial, contractual, and regulatory requirements; and
• In connection with corporate business transactions, such as a merger, joint venture, corporate reorganization, or sale of a business.

Please ensure that you provide a copy of this Privacy Notice to any third parties whose personal information you provide to us.

How we share information about you with our affiliates

We may share information about you, including personal information, with various service providers and Affiliated Companies that are providing services to us, such as administrative, business and data processing services. In addition, we may share information about you with Affiliated Companies for use in their businesses, including developing, marketing, offering, and delivering their products and services.

How we share information about you with third parties

We do not share information we collect about you with unaffiliated third parties for their use in marketing their products and services. We may share certain information with the following entities:

• Unaffiliated service providers and other third parties with which we or our Affiliated Companies have a business relationship;
• Government agencies, other regulatory bodies and law enforcement officials as permitted or required by law (for example, for fraud prevention or to respond to subpoena);
• Other third parties, as directed by you; and
• Reinsurance companies that we interface with.

Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide the services specified by us.

How we protect personal information about you

We employ reasonable physical, administrative, technical, and organizational measures proportional to the potential harm, sensitivity and context of the personal information used by us which are designed to protect personal information, and we regularly adapt these controls to respond to changing requirements and advances in technology.

International transfers of your personal information

Our business operates internationally and as such your personal information may be transferred to and used by our Affiliated Companies and our service providers located in other jurisdictions (including the US and other jurisdictions with privacy and data protection regimes that differ from Bermuda). Where your personal information is transferred to a third party located outside of Bermuda, we will take steps to ensure that your personal information is adequately protected and transferred in accordance with any applicable data transfer requirements, and that such third party recipients is obliged to provide a comparable level of protection to that provided by SoteriaRe.

Cookies and similar technologies

SoteriaRe and our service providers may use cookies and similar technologies (“cookies”) to support the operation of and maintain our digital offerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor’s device (for example, computer, tablet, or mobile phone). Cookies help us to collect information about users of our digital offerings, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our digital offerings. SoteriaRe cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

Both SoteriaRe and our service providers that we hire may use cookies and other technologies, such as web beacons, pixel tags, or mobile device ID, in online advertising as described below. Most browsers and mobile devices offer their own settings to manage cookies. If you use those settings to refuse or delete cookies it may negatively impact your experience using our digital offerings, as some features and services on our digital offerings may not work properly, or we may not be able to recognize you, your device, or your online preferences. Depending on your device and operating system, you may not be able to delete or block all cookies.

We may collect analytics data or use third party analytics tools such as Google Analytics to help us measure traffic and usage trends for our digital offerings and to understand more about the demographics of our users. You can learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy, opens in new window. You can also view Google’s currently available opt-out options, opens in new window.

Advertising on Non-SoteriaRe Digital Offerings

SoteriaRe may advertise our products and services on digital offerings not affiliated with us and we contract with third party advertising companies to display these ads. These third-party advertising companies may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, internet protocol address, and pages visited.

SoteriaRe and these third-party online advertising companies may use the data collected, along with other information we have about you and your SoteriaRe relationships, to serve relevant ads to you. The advertisements may be relevant to your interests, as determined by your activity on SoteriaRe and non-SoteriaRe websites. These advertisements are known as “interest-based advertisements”.

You may opt-out of receiving interest-based advertisements from online advertising companies, including those used by SoteriaRe, by clicking on the AdChoices icon and following the opt-out instructions.

If you generally want to “opt-out” of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in a self-regulatory programs like the Digital Advertising Alliance (DAA) program or the Network Advertising Initiative (NAI), please follow the instructions at WebChoices: Digital Advertising Alliance’s Consumer Choice Tool for Web US (aboutads.info), opens in new window and NAI Consumer Opt Out (networkadvertising.org), opens in new window to place an “opt-out” cookie on your device indicating that you do not want to receive interest-based advertisements. If you want to “opt-out” of receiving online interest-based advertisements on mobile devices, please follow the instructions at YourAdChoices.com | AppChoices, opens in new window and Mobile Opt Out - NAI: Network Advertising Initiative (thenai.org), opens in new window.

Connecting with SoteriaRe on social media platforms

SoteriaRe may provide experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect and use information you provide by interacting with us via social media, such as photographs, opinions, or a social media account ID. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social media platforms, is also subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Children’s privacy

SoteriaRe’s Website is not directed to individuals under the age of thirteen (13). We do not intentionally collect or use information on our Website and services from those we know are under the age of thirteen, and we request that these individuals do not provide personal information through our digital offerings. If we do provide a Website that is intended to be used by individuals under the age of thirteen, it will have a separate privacy policy.

Individuals’ rights under PIPA

PIPA, once fully in force, provides for certain legal rights relating to an individual’s personal information that SoteriaRe collects and uses. Once such PIPA provisions are effective, an individual may submit a reasonable written request to SoteriaRe to:

• Access (i) their personal information that is in the custody or control of SoteriaRe; (ii) the purposes for which SoteriaRe has been or is using their personal information; and (iii) the names of persons or types of persons and circumstances for which their personal information has or is being disclosed;
• Correct an error or omission in any of their personal information which is under the control of SoteriaRe;
• Cease, or not to begin, using their 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 the individual or another individual; and/or
• Erase or destroy personal information about the individual where that personal information is no longer relevant for the purposes of its use (noting that there may be circumstances where SoteriaRe will be legally entitled to retain it).

Any request must be in writing and provide sufficient detail to enable us to identify the personal information to which the request relates. In certain circumstances (described below), we may not be obligated to comply with a rights request, and you can request a review by the Privacy Commissioner of our decision, action or failure to act, and you may initiate a complaint against us with the Privacy Commissioner.

SoteriaRe may refuse to process access to personal information in the following circumstances:

• Personal information is protected by legal privilege;
• Disclosure of the personal information would reveal confidential information of SoteriaRe or of a third party that is of a commercial nature (redaction should be considered);
• Personal information is being used for a current disciplinary or criminal investigation or legal proceedings, and refusal does not prejudice the right of the individual to receive a fair hearing;
• Personal information was used by a mediator or arbitrator, or was created in the conduct of a mediation or arbitration for which the mediator or arbitrator was appointed to act under an agreement or by a court;
• Disclosure of the personal information would reveal the intentions of SoteriaRe in relation to any negotiations with the individual to the extent that the provision of access would be likely to prejudice those negotiations;
• Disclosure of the personal information could reasonably be expected to threaten the life or security of an individual;
• Personal information would reveal personal information about another individual (redaction should be considered); and
• Personal information would reveal the identity of an individual who has in confidence provided an opinion about another individual and the individual providing the opinion does not consent to disclosure of their identity (redaction should be considered).

How to contact us

If you have questions regarding your rights, and how we collect, use, and disclose your personal information or this Privacy Notice, please contact our Data Protection Officer at PrvcyOffc@FMR.COM. Our offices in Bermuda are located at Pembroke Hall, 42 Crow Lane, Pembroke HM19, Bermuda.

Updates

We may change this Privacy Notice in accordance with changes to applicable laws or our internal policies and procedures, and without notice to you, by posting an updated Privacy Notice on this Website or otherwise providing you with a copy of the updated Privacy Notice. When we make changes to this Privacy Notice, we will change the “Last Updated” date specified at the beginning of this Privacy Notice. All changes shall be effective from the date the updated Privacy Notice is published, unless otherwise specifically stated in the updated Privacy Notice. We encourage you to review this Privacy Notice on a regular basis so that you will be aware of any changes to it.