PRIVACY NOTICE
Version 1.0 – Published January 1, 2025
Introduction
Symphony Management Ltd. and its affiliated entities including Symphony Broking Ltd. and Aria (SAC) Ltd. (collectively “Symphony”, “Us”, “Our” and “We”) understands that your privacy is important to you and that you care about how your personal data is used and shared. We respect and value the privacy of everyone who visits Symphony’s website, contacts Symphony, and/or where your details are included on servers under Our control. We will only collect and use personal data in ways that are described here, and in a manner that is consistent with Symphony’s obligations and your rights in accordance with Bermuda’s Personal Information Protection Act 2016 (“PIPA”).
Please read this Privacy Notice carefully and ensure that you understand it. Your acceptance of this Privacy Notice is deemed to occur upon your first use of Symphony’s website or when We request your details, and you are directed to this Privacy Notice. If you do not accept and agree with this Privacy Notice, you must stop using Our website immediately and/or inform Us that you do not wish for Us to continue to use your details.
This Privacy Notice is not intended to override the terms of any agreement or other contract which you have with Us or any rights you might have available under PIPA.
1. Who Does This Privacy Notice Apply To?
This Privacy Notice relates to the following types of individuals, where We hold your personal information:
- Individuals who are clients, including prospective clients and former clients;
- Representatives, contacts, shareholders and claimants and other applicable stakeholders associated with current, prospective and former clients;
- Visitors to Our websites;
- Individuals who contact Us with a query, concern, or complaint;
- Employees, contractors, and third-party vendors.
2. Information About Us
Sarah Gregory is Our designated Data Protection Officer. If you have any questions about this Privacy Notice or your personal information held you may direct your inquiries in writing to Our Privacy Officer via email at
3. What Does This Notice Cover?
This Privacy Notice applies to your use of Symphony’s website and the storage and use of your personal data. Symphony’s website may contain links to other websites. Please note that We have no direct control over how your data is collected, stored, or used by other websites and advise you to check the privacy notices of any such websites before providing any information to them.
4. Your Rights
As an individual, you have the following rights, which this Privacy Notice and Symphony’s use of personal data has been designed to uphold:
- The right to be informed about Symphony’s collection and use of personal data;
- The right of access to the personal data Symphony holds about you (see section 10);
- The right to rectification if any personal data Symphony holds about you is inaccurate or incomplete (please contact Us using the details in section 2);
- The right to be forgotten – i.e., the right to ask Symphony to delete any personal data held about you (We hold your personal data for a required time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 2);
- The right to restrict (i.e., prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organization); and
- The right to object to Symphony using your personal data for particular purposes.
If you have any issue or complaint about Symphony’s use of your personal information, please contact Us using the details provided in section 2 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to file a complaint with The Office of the Privacy Commissioner for Bermuda.
For further information about your rights, please contact The Office of the Privacy Commissioner for Bermuda.
5. What Data Do We Collect?
We may collect some or all of the following personal and non-personal data such as:
- Full name;
- Contact information (e.g. email address, telephone number, postal and residential address);
- Identification details (e.g. passport, driver’s license, utility bill, ID number);
- Race and gender;
- Employment status;
- Family status;
- Banking, financial and taxation information;
- Any other information you provide to Us directly or indirectly; and
- Information We collect automatically through cookies and similar tracking technologies through Our websites.
We may collect information We obtain from other sources, such as:
- Insurance companies that We work with;
- Third party claims handlers;
- Our business partners;
- Public databases (where permitted by law);
- Insurance brokers or other intermediaries
- Healthcare service providers;
- Financial institutions; and
- Individuals that you may be associated with (e.g., joint account holders, company employees or directors, family members, etc.)
6. How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in accordance with the purpose(s) for which it was first collected. At all times We will comply with Our obligations and safeguard your rights under PIPA. For more details on security see section 7, below.
Symphony’s use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, for the performance of Our services or because you have consented to Our use of your personal data, or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- Entering into contracts and providing Symphony’s services to you;
- To comply with legal obligations and to cooperate with regulatory bodies to which We are subject;
- To communicate with you;
- To engage in financial transactions with you
- Employment applications and employee contracts;
Symphony shall not use sensitive personal information relating to an individual’s place of origin, race, color, national or ethnic origin, sex, sexual orientation, marital status, physical or mental disability, physical or mental health, family status, religious beliefs, political beliefs or opinions, trade union membership, biometric information or genetic information in order to discriminate against any person contrary to the provision of Part II of the Bermuda Human Rights Act 1981.
Symphony’s websites are not intended for children and we do not knowingly collect information relating to children via our websites. We may collect information on a child as part of a specific service and will only do so with the consent of the child’s parent or other legal guardian.
You have the right to withdraw your consent to Symphony using your personal data at any time, and to request that We delete it.
7. How and Where Do We Store Your Data?
Symphony only keeps your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have a lawful basis to keep it.
Some or all of your data may be stored outside of Bermuda. You are deemed to accept and agree to this by using Symphony’s website and/or submitting information to Us. If Symphony does store data outside Bermuda, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within Bermuda.
Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure all personal data collected by Us.
We maintain a data retention policy which We apply to records in Our care. Where your personal data is no longer required, We will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.
8. Do We Share Your Data?
Symphony may sometimes contract with third parties to provide services to you on Our behalf. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, Symphony will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
We may compile statistics about the use of Symphony’s Website. All such data will be anonymized and will not include any personally identifying data, or any anonymized data that can be combined with other data and used to identify you.
In certain circumstances, Symphony may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority or regulatory obligations.
9. What Happens If Our Business Changes Hands?
Symphony may expand or reduce Our business, and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use that data only for the same purposes for which it was originally collected by Us.
In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
10. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Symphony (where such data is held). Please contact use the contact details in section 2. We may charge a reasonable fee for providing information in response to a privacy access request and will provide a fee estimate on request.
11. Our Use of Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the website may become inaccessible or not function properly.
12. Changes to Our Privacy Notice
Symphony reserves the right to change this Privacy Notice from time to time (for example, if the law changes). Any changes will be immediately posted on Our website, and you will be deemed to have accepted the terms of the Privacy Notice on your first use of Our site following the alterations. We recommend that you check this page regularly to keep up to date on pertinent policies.