This privacy notice is issued by Mission Underwriting Europe Limited, trading as Kyntra Specialty (“we”, “us” and “our”), and relates to our use of personal data (“data”) concerning living persons in connection with our website and our commercial property and liability underwriting business. 

We write commercial property insurance, and commercial combined (property and liability) insurance, for businesses and property owners across the Republic of Ireland, distributed through insurance brokers. Our book includes both consumer and non-consumer (commercial) policyholders, so the individuals whose data we process include private policyholders as well as corporate insureds, employees, and members of the public making liability claims. 

Do we process personal data? 

We may process data from the following categories of persons (collectively “Insurance Contacts”): 

• insured persons, insurance applicants and policyholders (“Insureds”); 

• beneficiaries and other persons named in the insurance policy (“Beneficiaries”); 

• persons filing a claim under an insurance policy (“Claimants”); 

• persons who serve as a witness in light of an insurance claim (“Witness”); and 

• any other person who has had dealings with the Insured in respect of the Insured’s financial interest in their insurance policy. 

Additionally, we may process data from the following categories of persons other than Insurance Contacts: 

• individuals working for one of our business partners (“Business Contacts”); 

• individuals who otherwise interact with us online or offline, for instance by filing a general request for information via our website (“General Contacts”); and 

• individuals who use and visit our website (“Website Visitors”). 

In each case, we respect your privacy rights and your rights as a data subject. We will manage and protect your data accordingly, whilst it is in our hands, in accordance with all applicable data protection legislation, including the EU General Data Protection Regulation and the Irish Data Protection Act 2018, and in accordance with this privacy notice. 

Who is the Data Controller? 

For the purpose of this Privacy Notice and applicable data protection law, Mission Underwriting Europe Limited, trading as Kyntra Specialty, acts as controller and is responsible for the processing of your personal data described in this notice, including personal data of Website Visitors. 

Mission Underwriting Europe Limited is a company registered in Ireland (Company No. 657936), with its registered office at 13–18 City Quay, Dublin 2, D02 ED70, Ireland, and is regulated by the Central Bank of Ireland (Reference No. C423592). 

For enquiries relating to how your data is processed, you can contact us at: dpo@missionunderwriters.eu. 

How Will We Use Your Data? 

We will use data in the normal course of business to: 

• Administer insurance policies. 

• Underwrite insurance policies (including aggregating data with other similar data for actuarial purposes). 

• Handle claims on insurance policies for Claimants. 

• Deal with any complaints that you may have. 

• Verify your identity. 

• Confirm with third parties that you have received insurance cover. 

• Where we have a legal basis to do so, help us to identify and market products that may be of interest to you. 

• Detect and prevent financial crime. 

We may use your data, in the course of our business, for the prevention and detection of fraud. Where we suspect fraud, this may entail: 

• Sharing your data with An Garda Síochána and other relevant public bodies or regulatory authorities. 

• Undertaking fraud searches. 

• Checking your data against fraud prevention databases. 

What is the Purpose of Data Processing? 

For persons who are Insurance Contacts, we require to process your data in order to arrange and administer a contract of insurance. 

The legal bases for processing your data are as follows: 

• Processing your data is necessary for the arrangement of the insurance contract between the Insured and the insurer providing capacity, and for the performance of the insurance contract to which you are a party. 

• Processing your data is necessary for our compliance with certain legal obligations (such as the detection and prevention of financial crime). 

• Processing your data is necessary in pursuit of our and the relevant insurer’s legitimate interests in arranging the Insured’s insurance contract. 

How Did We Receive Your Data? 

If you are an Insured, we will typically have received your data from an insurance broker arranging insurance on your behalf or on behalf of an insurer. 

On occasion, we may also receive or collect your personal data directly from you, such as when you are a Website Visitor or where you are otherwise in direct contact with us. We may also receive your personal data from the following sources: 

• Persons and companies you are affiliated with or related to, including your family members, employer or representative; 

• Information automatically collected when you visit or use our website; 

• Credit reference agencies; 

• Reinsurance companies and other third-party insurers with whom you have, had, are applying for, or have filed a claim under an insurance policy; 

• Sanctions lists, court judgments, insolvency registers and other public databases used for fraud prevention purposes; 

• Government bodies, such as the Revenue Commissioners, where relevant to identity or financial-crime checks; 

• The Companies Registration Office and other publicly available registers; 

• Supervisory, regulatory and other public authorities; 

• In the event of a claim, third parties including the other party to the claim (claimant/defendant), witnesses, experts (including medical experts), loss adjusters, external counsel, and claims handlers; 

• Service providers, such as organisations operating our website; and 

• Other public and non-public sources, including information that is publicly available online. 

What Types of Data Do We Process? 

The data we process depends on your relationship with us as set out above, and whether collection is permitted by applicable law. We collect and process the following categories of data: 

Categories of Personal Information	Relationship with us
Website usage data and related identifiers, such as technical information including the Internet Protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, operating system and platform, pages viewed, and page interaction information. See our Cookie Policy for further detail.	Website Visitors
Individual details – name, address, date of birth, nationality, marketing preferences and, where relevant to a claim, family details and their relationship to you. Contact details, and further individual information in relation to a claim being made under a policy of insurance, including special category data – such as medical/health information where the nature of a personal injury claim necessitates this, or criminal offence data where relevant to a fraud or underwriting assessment. Identification details – identification numbers issued by government bodies or agencies, such as a passport number, PPS number or tax identification number, used for identity verification purposes. Employment history – employer, job title, professional licences and educational/professional qualifications, where relevant to your role or occupation. Financial information – such as bank account or payment card details, and financial information relevant to a claim or underwriting assessment, including property valuation. Policy/contractual information – details about quotes you receive and policies you hold and with whom you hold them. Fraud and credit-related data – such as credit history, sanctions screening results, and information received from anti-fraud databases relating to you. Risk coverage details – information necessary to assess the risk to be insured and provide a quote, such as construction type, occupancy, security and claims history. Previous and current claims – information about previous and current claims, including other related insurances. Special categories of Personal Information and criminal offence data – limited to health data (in connection with personal injury liability claims) and criminal offence/conviction data (in connection with fraud prevention or underwriting checks).	Insureds Beneficiaries Claimants
Contact details, and further individual information about you in relation to a claim being made under a policy of insurance, including special category data – such as medical/health information – if the nature of the claim necessitates this.	Witnesses
Professional information and contact details, such as information about your employer, your position/title, and your professional contact details.	Business Contacts
Your marketing preferences.	Website Visitors Business Contacts General Contacts
Inferences drawn from the above-referenced categories of information, to assess risk.	All Insurance Contacts
Any other information you voluntarily share with us, e.g. when you contact our customer service or otherwise engage with us.	Website Visitors All Insurance Contacts Business Contacts General Contacts

We only process your special category and/or criminal offence data where strictly necessary. When we do, we will ask for your explicit consent where this is required under applicable data protection law, or we rely on a specific authorisation in law that allows us to process this information. 

Our Lawful Basis for Processing Your Data 

We will only use and process your data where we have a purpose and a legal ground to do so. We use and process data for the purposes and legal grounds set out below, depending on your relationship with us: 

Purpose	Relationship with us	Legal Ground
To consider an application for an insurance policy, assess and evaluate risk, determine the scope, coverage and premium of the policy and, where applicable, provide insurance cover and associated services. To manage and administer policies and claims, including assessing and evaluating claims and, where relevant, paying a settlement. To comply with legal and regulatory obligations, including fraud and money-laundering prevention.	Insureds Beneficiaries Claimants	Necessary to perform, or take steps to enter into, a contract with you. Necessary to comply with legal and regulatory obligations. Necessary for our legitimate interests in managing our business, administering policies and claims, and assessing risk.
To manage and administer claims, including assessing the merits of a claim and, where relevant, paying a settlement.	Witnesses	Necessary for our legitimate interests in managing our business, including administering claims.
Communicating with you, responding to your queries and complaints, and operating, securing and improving our website.	Website Visitors	Legitimate interest in operating our website and communicating with you upon your request.
Contacting you about products or services that may interest you, including direct marketing.	Insureds Claimants Website Visitors General Contacts	Legitimate interest in communicating with you; depending on your location, we may also seek your consent before sending direct marketing.
Carrying out audits and investigations, and resolving complaints, grievances or misconduct.	Website Visitors Insurance Contacts Business Contacts General Contacts	Legitimate interest in managing our business effectively; legal obligation where applicable.
Preparing for and responding to enquiries, investigations or proceedings by governmental, administrative, judicial or regulatory authorities, including civil litigation.	Website Visitors Insurance Contacts	Legitimate interest in managing our business and ensuring proceedings are handled effectively.
Complying with legal and regulatory obligations, including the prevention and detection of fraud and money laundering.	Business Contacts General Contacts	Legal obligation.
In connection with a potential asset or business transaction, providing reasonable diligence material or meeting disclosure obligations.	Website Visitors Insurance Contacts Business Contacts General Contacts	Legitimate interest in managing our business.
Debugging to identify and repair errors that impair intended website functionality.	General Contacts	Legitimate interest in maintaining a functioning website.

Will We Use Automatic Decision-Making or Profiling? 

We use a variety of technologies in calculating risk and insurance premiums, and to compare insurance risks against industry averages and patterns. This is considered profiling and/or automated decision-making, and is necessary to enter into a contract with you – to confirm that the premium reflects the associated risk – and/or is authorised under applicable law. As a result of these profiling activities, you may be offered a different insurance policy and/or premium, or cover may be declined. 

Profiling may also be used to identify fraud patterns. Where, exceptionally, special categories of personal data (such as health data relevant to a personal injury claim) or criminal offence data are relevant to profiling, we will ask for your prior explicit consent unless we can rely on another basis in applicable law. 

Will Third Parties Receive Your Data? What Are Their Interests? 

We share your personal data with other entities within the Mission group. Employees only have access to and process data where this is necessary to perform the tasks allocated to them, with suitable organisational and technical measures in place to safeguard this. 

We also share your personal data with the following categories of third parties: 

• Our service providers (e.g., IT vendors supporting our information security and technology, external counsel and other legal advisers, consultants, auditors, website and data hosting providers, marketing agencies, accountants, etc.); 

• Governmental authorities, including our supervisory regulatory authorities and law enforcement agencies; 

• Business Contacts; 

• Contractors, brokers or financial institutions; and 

• Other third parties (i) upon your request; (ii) to protect and defend our rights and property; (iii) to detect and/or prevent fraud or money laundering, including via anti-fraud and sanctions databases; (iv) in the event of a sale, merger or reorganisation of our assets or other restructuring; and/or (v) where we are, or believe in good faith that we are, under a legal obligation to share your data. 

International Data Transfers 

The recipients with whom we share your data may be located in countries that have data protection laws different to those of your own country, and in some cases may not have an adequate level of data protection, meaning local laws may provide a lower standard of protection than applies within your jurisdiction. 

We only transfer your data to such jurisdictions in compliance with applicable data protection law and transfer restrictions, and we implement appropriate safeguards where required. Where we transfer your data from the EEA to other group companies or recipients located outside the EEA (including the United Kingdom, where other Mission group entities are based), we rely on the European Commission’s Standard Contractual Clauses (“SCCs”), seek assurances of Binding Corporate Rules, or, in exceptional circumstances, rely on a derogation under applicable data protection law (for example, where the transfer is necessary for the defence of legal claims). 

You may contact us for further information on the transfer mechanism used, or for details of the safeguards implemented. 

How Long Will We Keep Your Data? 

Your data will be retained only for as long as is necessary for us to effectively administer your policy of insurance. This means your data will be retained until claims under your policy are time-barred; or as long as is necessary to defend against legal claims; or for as long as is required by law; whichever period is the longest. 

What Are Your Rights to the Data? 

As a data subject, you have rights with respect to the processing of your personal data under our control, as follows: 

• Access: You may ask us what personal data we process and request copies of it. This is limited to personal data and does not include commercial data such as underwriting data. 

• Rectification: You may ask us to rectify or update personal data that is inaccurate or incomplete. 

• Erasure: You may ask us to delete your personal data in certain instances (for example, where it is no longer necessary for the purpose for which it was collected, or there is no longer a legitimate interest for us to process it). 

• Restriction of processing: In certain circumstances (such as where you question the accuracy or lawfulness of our processing) you may ask us to stop processing your data until your request is resolved. 

• Data portability: In certain cases, you may ask us to send an electronic copy of your personal data to you or to another organisation. 

• Object: You may object to any processing of your personal data, including profiling, based on the ground of legitimate interest. 

• Withdraw consent: Where processing is based on consent, you may withdraw it at any time; this will not affect processing carried out before withdrawal, and only applies where consent was the original basis for processing. 

Each of these rights is subject to applicable data protection law and is not absolute. 

To exercise these rights, or if you have a complaint about how we process your data, please contact: dpo@missionunderwriters.eu 

If we are unable to resolve your complaint, you also have the right to lodge a complaint about the processing of your personal data with the competent data protection authority. As we are established and regulated in Ireland, this is: 

• The Data Protection Commission, Ireland (our lead supervisory authority). 

For other jurisdictions, a full list of EU data protection authorities is available via the European Data Protection Board.