We at Ambridge Partners LLC (“APL”), Ambridge Europe Limited (“AEL”) and Ambridge Europe GmbH & Co. KG (“AEG”) (collectively “Ambridge” or “we”) have created this Privacy Notice to explain how we collect, use, maintain, protect, disclose and otherwise process personal information in connection with the company’s ambridge-group.com website (the “Website”) and the business contact information we collect. We have provided this brief overview of our information practices for your convenience, but please see below for our full Underwriting & Insurance Services Privacy Notice. 

Our Website is designed for individuals acting in their business capacity, and prospective clients and their representatives. Our Website and services are not intended for personal, family or household use. Accordingly, we treat all personal information covered by this Privacy Notice as pertaining to individuals acting as a business representative, rather than in a personal capacity. 

References to “personal information” in this Privacy Policy are equivalent to “personal data” or “personal information” as defined by the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and/or The California Consumer Protection Act of 2018 (“CCPA”) as applicable.

Please email us at privacy@ambridge-group.com if you have questions about our Privacy Notice.  

Information We Collect

Whose information we collect

We may collect information about individuals who interact with Ambridge (including via our Website), our customers (and their representatives), job applicants, and other individuals.

How we collect the information

We may collect information:

• directly from individuals or their representatives, when they contact us via email, telephone or by any other means;
• from our customers and business partners in the course of providing our services;
• when we receive personal data or personal information from third parties in the course of conducting our day-to-day operations, for example from recruiters, other third-party service providers and business contacts; or
• automatically as you navigate through the Website; information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons and other technologies.

Types of information we collect

The types of information we collect may include:

• personal and business contact information (such as name, employer name, email address, mailing address, and phone number);
• biographical and demographic information (such as date of birth, age, gender, and marital status);
• information of the type that would be included on a resume or curriculum vitae, such as professional credentials, educational history, education, work history, and languages spoken;
• information provided to us in connection with our services; for more information, please see our Underwriting & Insurance Services Privacy Statement;
• information about your internet connection, the equipment you use to access our Website, and other information automatically collected when you access our Website, as further described in the section titled “Cookies and Other Information Collected by Automated Means” below.

Please note that in limited circumstances the personal data that we process may also include sensitive personal data as defined in Art. 9(1) of the data. If you provide us with any sensitive personal information, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Notice. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information to us.

Our Privacy Notice does not apply to information collected by:

• us offline or through any other means, including on any other website operated by Ambridge or any third party (including our affiliates and subsidiaries); or
• any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Creation of personal data

In providing our services, we may also create personal data, such as records of the data subject’s interactions with us and other details of the business relationship.

Our Use of Personal Information

In this section, we set out the purposes for which we process personal information and identify the legal grounds on which we rely to process the information, which are described below. We may use personal information to:

• Manage and communicate with you regarding your relationship with us, including by responding to requests, inquiries, comments, and suggestions;
• Analyze and enhance our communications and strategies (including by identifying emails sent to you have been received and read);
• Operate, evaluate and improve our business (including the provision of underwriting, claims and other insurance-related services), our Website, and other products and services we offer (including to research and develop new products and services);
• Tailor the content we display in our communications and on our Website; 
• Comply with regulatory reporting obligations;
• Comply with legal requirements, judicial process, and our company policies (including to verify users’ identity in connection with access or correction requests or to respond to any government or regulatory request); or
• Protect against, identify, investigate, and respond to fraud, illegal activity (such as incidents of hacking or misuse of our Websites), and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide; or
• process employment applications.

We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.

For more information concerning how we use or process personal information provided to us in connection with underwriting and/or other insurance-related services, please refer to our Underwriting & Insurance Services Privacy Statement.  

To send marketing communications

If you request information from us, we may send you Ambridge-related marketing communications as permitted by law. You have the ability to opt out of such communications by notifying us at privacy@ambridge-group.com.  

In such jurisdictions where the sending of electronic marketing requires a double-opt-in procedure, we will comply with the respective requirements. 

To comply with law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

With your consent

We will request your consent to use your personal information where such consent is required by law.  If we request your consent to use your personal information, you have the right to withdraw your consent at any time in the manner indicated when we requested the consent or by contacting us. If you have consented to receive marketing communications from our third-party partners, you may withdraw your consent by contacting those partners directly. 

To manage our recruiting and process employment applications

If you submit your information in connection with job opportunities at Ambridge, we may use and disclose the information to process your application (including to contact you and/or your references and former employers if appropriate), to monitor recruitment statistics, and to comply with government reporting requirements. We may also retain statistical information about applicants to help inform our recruitment activities. 

To create pseudonymous data for analytics

We may create pseudonymous data from any information that we collect, including your personal information, by excluding information that makes the data personally identifiable. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.

For compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to (a) enforce the Terms of Use  that govern this Website ( the “Terms”); (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including by performing KYC and AML checks.

Processing of sensitive personal data

We do not seek to collect or otherwise process sensitive personal data, except where:

• The processing is required or permitted by applicable law; 
• The processing is required for the performance of our contractual obligations in connection with services provided to you;
• The processing is required for the performance of our contractual obligations in connection with services provided to you;
• The processing is necessary for the detection or prevention of crime (including the prevention of fraud, money laundering and/or financing terrorism); 
• The processing is necessary for the establishment, exercise or defense of legal rights; 
• We have, in accordance with applicable law, obtained the data subject’s prior consent prior to processing the data subject’s sensitive personal data (as above, this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way); or
• The sensitive personal data is publicly available.

Use for new purposes

• We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.  If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
•  

Our legal basis for the processing activities described above are as follows:

Information We Share

Ambridge may share personal information for the purposes described in this Privacy Notice or a specific “in-time” privacy notice we may provide at the time we collect the information. 

We may share personal information with:

• Other affiliates and subsidiaries within the Ambridge group of companies for purposes consistent with this Privacy Policy, including between Ambridge Partners LLC, Ambridge Europe Limited and Ambridge Europe GmbH & Co. KG;
• Service providers contractors, and other third parties that perform services on our behalf, such as customer service and support providers and technology providers (including technology support, email and web hosting providers, email and text communications providers);
• Governmental and industry regulators;
• Professional advisors, such as lawyers, bankers, accountants, financial advisors, auditors and insurers, where necessary in the course of the professional services that they render to us; or
• The insurers for which we underwrite (and their reinsurers and professional advisors). 

Unless prohibited by applicable law, we reserve the right to transfer the information we maintain to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer all or a portion of our business or assets whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. If we engage in such a sale or transfer, we will – where required by applicable law – make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Notice. After such a sale or transfer, you may contact the recipient with any inquiries concerning the processing of your personal information.

In addition, we may share your information to comply with legal and regulatory requirements, and protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our Website) and claims and other liabilities.

Cookies and Other Information Collected by Automated Means

Ambridge, our service providers, and our business partners, may also collect certain information about the use of our Websites by automated means, such as cookies, web beacons and other technologies. A “cookie” is a text file that websites send to a visitor‘s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Please see our Cookie Notice for more information on cookies.

A “web beacon” is a small electronic file (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).We and our service providers and business partners may collect information about your online activities over time and across third-party websites when you use our Website.

The information that may be collected by automated means includes:

• Details about the devices that are used to access our Website (such as the IP address, and type of operating system and web browser);
• Dates and times of visits to, and use of, our Website;
• Information about how our Website are used (such as the content that is viewed on our Websites and how users navigate between our webpages);
• Details about how individuals interact with our emails (such as whether the email is opened and which links are clicked in the email);
• URLs that refer visitors to our Website; or
• Search terms used to reach our Website.

Web browsers may offer users of our Website the ability to disable receiving certain types of cookies, however, if cookies are disabled, some features or functionality of our Websites may not function correctly.

Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. Please see the Privacy Preferences, Rights and Choices section below for information about how you may opt out of, or limit the use of, your browsing behavior for online behavioral advertising purposes.

Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. Please see the “Privacy Preferences, Rights and Choices” section below for information about how you may opt out of, or limit the use of, your browsing behavior for online behavioral advertising purposes.

Data Retention

We will retain your information only for as long as necessary to fulfill the purpose(s) for which the information was collected, depending on the purpose(s) for which the information was collected, the nature of the information, any contractual relationship that may govern the retention of the data, and our legal or regulatory obligations. 

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have otherwise collected about you, we will dissociate such information from the information attached to your content in accordance with our document retention policy and practices. In some circumstances we may pseudonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.

Privacy Preferences, Rights and Choices

Your privacy rights

By sending correspondence to privacy@ambridge-group.com or our postal address provided below , you may ask us to take the following actions in relation to your personal information that we hold:

• Opt-out. Stop sending you direct marketing communications.  You may continue to receive service-related and other non-marketing emails. 
• Access.  Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct.  Update or correct inaccuracies in your personal information.
• Delete.  Delete your personal information.
• Transfer.  Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict.  Restrict the processing of your personal information.
• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information.  

You can submit these requests in writing to privacy@ambridge-group.com or our postal address provided below.  We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request.  If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described below or submit a complaint to the data protection regulator in your jurisdiction.

You can find EU data protection regulators here:   

Marketing e-mails – opting out

You may unsubscribe from receiving marketing or other commercial emails from Ambridge by contacting us at privacy@ambridge-group.com or our postal address provided below. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as information about changes in our website terms). 

Choosing not to provide your personal information

You may choose not to provide personal information to us. However, we may not be able to provide services to you if we are required to collect your personal information or if we need your personal information in order to provide the services.  We will tell you what information you must provide to receive our services by designating it as required or through other appropriate means.

International Data Transfers

We may transfer your personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Notice. For example, Ambridge Partners LLC may transfer your personal information outside of the United States, to Ambridge ’s affiliate entities in the United Kingdom, or in Germany. Similarly, Ambridge Europe GmbH & Co. KG might transfer personal information from the EEA. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information. When we transfer personal information across borders, we consider a variety of requirements that may apply to such transfers.  

Specifically, Ambridge Partners LLC  may transfer personal information to the European Economic Area (EEA) pursuant to the recipient’s compliance with standard contractual clauses concluded with us or the group company which is transferring the personal data outside the EEA or with the EU-US Privacy Shield and our internal data transfer agreement.

Ambridge Europe Limited and Ambridge Europe GmbH & Co, KG may transfer personal information from the EEA to:

• Countries that the European Commission has deemed to adequately safeguard personal information;
• Pursuant to the recipient’s compliance with standard contractual clauses concluded with the Ambridge group entity which is transferring the personal data outside the EEA or with the EU-US Privacy Shield and the Ambridge internal data transfer agreement;
• Pursuant to the consent of the individual to whom the information pertains; or
• As otherwise permitted by applicable EEA requirements.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information into or out of the United States or the EEA or a copy of the respective documents.

How We Protect Information

Ambridge maintains reasonable administrative, technical and physical safeguards designed to protect the personal information we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Security Risk is inherent in all internet and information technologies. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Links to Websites and Third-Party Content

For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by Ambridge. These websites and third-party content to which we link may have separate privacy notices or policies. . We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects personally identifiable information.  This Privacy Notice applies only to information collected by our Website. Ambridge is not responsible for the privacy practices of any entity that it does not own or control.

Updates to Our Privacy Notice

Ambridge reserves the right to change this Privacy Notice at any time. When we update this Privacy Notice, we will notify you of changes that are deemed material under applicable legal requirements by updating the date of this Privacy Notice and providing other notification as required by applicable law. We may also notify you of changes to the Privacy Notice in other ways, such as via email or other contact information you have provided. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Notice to check for any changes.

AEG Privacy Notice document download

You may contact us with questions, comments, or complaints about this Privacy Notice or our privacy practices, or to request access to or correction of your information. Our contact information is as follows:

Ambridge Partners LLC
Attn: Legal – Privacy
1140 Avenue of the Americas
5th floor
New York, NY 10036
privacy@ambridge-group.com

For the purposes of European and UK data protection legislation and the GDPR, Ambridge is a data controller of your personal information for individuals located in the UK or Europe. You may contact us with questions, comments or complaints about this Privacy Notice or privacy practices, or to request access to or a correction of your information. 

Individuals located in the United Kingdom may contact Ambridge Europe Limited:

Ambridge Europe Limited

Attn: Legal – Privacy

77 Cornhill, 5^th floor

London EC3V 3QQ

United Kingdom

privacy@ambridge-group.com

Individuals in the Europe may contact Ambridge Europe GmbH & Co. KG,:

Ambridge Europe GmbH & Co., KG

Attn: Legal – Privacy
Friedrich-Ebert-Anlage 36
Frankfurt am Main
Germany  
privacy@ambridge-group.com

If you are a resident within Europe, you also have the right to file a complaint with the supervisory authority of your member state.