Purpose

The purpose of this policy is to define the acceptable collection, usage, and disclosure of information by Exante Consulting Limited (Exante).

This policy is mandatory. By accessing any Information Technology (I.T.) resources that are owned or leased by Exante, users agree to abide by the terms of this policy.

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Scope

This policy represents Exante's position and applies to all teams & groups including all Exante companies where a local company specific policy has not been defined.

• All Information Technology (I.T.) resources provided by Exante.

• All users (including Exante staff, contractors, sub-contractors and authorized third party commercial service providers) of Exante’s I.T resources.

Where Exante companies choose to deviate from Exante policy they are required to provide their own policy overriding this policy.

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Introduction 

Exante (“us”, “we”, or “our”) operates  Exante.io and any related subdomains and provides parametric insurance innovation, product development, consulting, and software services (hereinafter referred to as “Service”). Our Privacy Policy governs your engagement with Exante, and explains how we collect, safeguard, and disclose information that results from your use of the Service.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions. Our Terms and Conditions (“Terms”) govern all use of the Service and together with the Privacy Policy constitutes your agreement with us (“agreement”).

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Definitions 

SERVICE means the exante.io website and any application operated by Exante at related subdomains.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR THE SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the Services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using the Service. The User corresponds to the Data Subject, who is the subject of Personal Data. 

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Information Collection and Use 

We collect several distinct types of information for various purposes to provide and improve the Service to you.

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Types of Data Collected 

Personal Data:

When you visit one of our websites or custom-built applications, we collect your IP address and standard web log information, such as your browser type and the pages you accessed on our website.

While using the Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

• Email address

• First name and last name

If you have opted in to allow us to do so, we may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the associated unsubscribe link. 

We may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team or store results when you respond to a survey.

Usage Data:

We may collect information that your browser sends whenever you visit the Service (“Usage Data”).

This Usage Data may include information such as your computer's Internet Protocol address, browser type, browser version, the pages of the Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking Cookies Data:

We use cookies and similar tracking technologies to track the activity on the Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as tags and scripts to collect information and to improve and analyze the Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of the Service.

Examples of Cookies we use:

• Session Cookies: We use Session Cookies to operate the Service.

• Security Cookies: We use Security Cookies for security purposes.

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Use of Data

Exante uses the collected data for various purposes:

(a) To provide and maintain the Service.

(b) To notify you about changes to the Service.

(c) To allow you to participate in interactive features of the Service when you choose to do so.

(d) To provide customer support.

(e) To gather analysis or valuable information so that we can improve the Service.

(f) To monitor the usage of the Service.

(g) To detect, prevent and address technical issues.

(h) To fulfill any other purpose within the goal of operating and maintaining the Service.

(i) To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including billing and collection. 

(j) If you have opted in, to provide you with news, updates, and general information on our Services.

(k) In any other way we may describe when you provide the information.

(l) For any other purpose with your consent.

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Retention of Data 

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. 

We will also retain Usage Data for internal analysis purposes. Usage Data is retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of the Service, or we are legally obligated to retain this data for longer time periods.

We store and process your personal information using third party servers located in secure data centres in Europe and the United Kingdom. This information is protected by physical, electronic and procedural safeguards in compliance with applicable regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorise access to personal information only for those employees who require it to fulfil their job responsibilities.

We utilise commercially reasonable physical, technical, and administrative security measures to help protect information under Exante control against loss, misuse, and alteration. For example, we use a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session, your personal information and to protect Exante accounts and systems from unauthorised access. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered, or destroyed by breach of our administrative, managerial, and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data.

If Exante learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using Exante services, you agree that Exante may communicate with you electronically. Exante may post a notice on the website if a security breach occurs. We may also send an e-mail to you at the e-mail address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach) you should notify us.

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Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Exante will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

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Disclosure of Data

We may disclose personal information that we collect, or you provide:

(a) Disclosure for Law Enforcement.

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

(b) Business Transaction.

If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

(c) Other cases.

Exante does not share your personal information with third parties for promotional or marketing purposes.

We may share your personal information with:

• our subsidiaries and affiliates.

• contractors, the Service providers, and other third parties we use to support our business.

• For any other purpose disclosed by us when you provide the information.

• With your consent in any other cases.

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Security of Data 

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

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The Service Providers

We may employ third party companies and individuals to facilitate the Service (“Service Providers”), provide the Service on our behalf, perform service-related services, or assist us in analyzing how the Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

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Analytics 

We may use third-party Service Providers to monitor and analyze the use of the Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of the Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page.

We also encourage you to review the Google's policy for safeguarding your data.

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Links to Other Sites

The Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

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Children's Privacy

The Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

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Changes to this Privacy Policy 

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on the Service, prior to the change becoming effective.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

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Roles and Responsibilities

Chief Technology Officer (CTO)

The CTO is responsible for:

• The implementation of this policy and all other relevant policies.

• Ensuring adequate procedures are in place to ensure compliance with this policy and all other relevant policies.

• Conducting a quarterly review of the networks in accordance with this policy.

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Enforcement

• Exante reserves the right to take such action as it deems appropriate against individuals who breach the conditions of this policy. Exante staff, contractors, sub-contractors or 3rd party staff who breach this policy may be subject to disciplinary action, including suspension and dismissal as provided for in Exante disciplinary procedure.

• Breaches of this policy by third party commercial service providers may lead to the withdrawal of Exante information technology resources to that third party commercial service provider and/or the cancellation of any contract(s) between Exante and the third party commercial service provider.

• Exante will refer any use of its I.T. resources for illegal activities to the Gardai.

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How to contact us

If you have any questions about this privacy policy, the data we hold, or you would like to exercise one of your data protection rights, please do not hesitate to contact our Chief Technology Officer by email at: aidan@exante.io

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How to contact the appropriate authority

Should you wish to report a complaint or if you feel that Exante has not addressed your concern in a satisfactory manner, you may contact the Data Protection Commissioner’s Office. p to date contact information can be found here: https://www.dataprotection.ie/en/contact/how-contact-us

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