This California Privacy Notice (“Notice”) is provided pursuant to the California Consumer Privacy Act (“CCPA”) and describes how AXIS Capital Holdings Limited and any of its affiliates (“Axis” or the “Company” or “we” or “us” or “our”) processes Personal Information of California consumers. This Notice supplements our other privacy policies and notices, including our AXIS’s Rest of the World Privacy Notice. In the event of a conflict between any other policy, statement, or notice and this Notice, this Notice will prevail as to California consumers covered by the CCPA.
For more information about nonpublic personal information covered by the Gramm-Leach-Bliley Act (“GLBA”), please visit our Financial Privacy Notice here. Our California Applicant Privacy Notice covers Personal Information collected from and about our job applicants. Our California Employee Privacy Notice, located on our Intranet, covers Personal Information collected from and about our employees and related workers.
I. PERSONAL INFORMATION WE COLLECT AND WHY WE COLLECT, USE AND DISCLOSE IT
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.
We may collect, store, use and disclose your Personal Information consistent with applicable laws. Unless otherwise noted, the disclosures herein cover our activities in the twelve months preceding the Effective Date, as well as current practices. The Personal Information we collect about you may vary depending on the nature of your interactions with us and may not include all of the examples listed below.
|Category of Personal Information||Categories of Sources from which Information was Collected||Purposes for Collection, Use, and Disclosure||Categories of Recipients to which Information was Disclosed|
|Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers||Collection and Use|
|Personal information described in Cal. Civ. Code § 1798.80(e), including name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information, medical information, or health insurance information||Collection and Use
|Characteristics of protected classifications under California or federal law, including age and date of birth, marital status, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, disability, marital status||Collection and Use
|Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||Collection and Use
|Internet or other electronic network activity information, including Internet or other similar activity, browsing history, search history, information on a consumer's interaction with a website, application logs, device data and registration, social media account information or advertisement||Collection and Use
|Audio, electronic, visual, thermal, olfactory, or similar information||Collection and Use
|Professional or employment-related information||Collection and Use
|Inferences used to create a profile reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes||Collection and Use
We also collect some Personal Information that does not directly fit within one of the categories defined by the CCPA. For example, we collect the contents of communications you send to us. Unless otherwise specified, the sources of this Personal Information, the purposes for which we use it, and the categories of persons to which we disclose it are the same as those listed for Identifiers. In addition to the other purposes for collection, use, and disclosure of Personal Information described herein, we may collect, use, and disclose Personal Information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may use and disclose Personal Information to other parties in connection with the sale, assignment, merger, or reorganization.
II. SENSITIVE PERSONAL INFORMATION
We collect the categories of Sensitive Personal Information about California consumers that are indicated in the chart below. Note that the Sensitive Personal Information we collect may vary depending on the nature of your interactions with us and may not include all of the examples listed below.
|Category of Sensitive Personal Information||Categories of Sources from which Information was Collected||Purposes for Collection, Use, and Disclosure||Categories of Recipients to which Information was Disclosed|
|Personal Information that reveals a consumer's Social Security, driver's license, state identification card, or passport number||Collection and Use|
|Personal Information that reveals a consumer's account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account||Collection and Use
|Personal Information that reveals a consumer's racial or ethnic origin, religious or philosophical beliefs, or union membership||Collection and Use
|Personal Information collected and analyzed concerning a consumer's health||Collection and Use
|Personal Information collected and analyzed concerning a consumer's sex life or sexual orientation||Collection and Use
III. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:
- Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
- Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
- The information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
- We are otherwise required or permitted to keep your information by applicable laws or regulations.
Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.
IV. HOW WE SHARE AND SELL PERSONAL INFORMATION
Within the preceding 12 months, we have not sold or shared Personal Information for cross-context behavioral advertising. We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.
V. YOUR CCPA PRIVACY RIGHTS
As a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise your privacy rights, please submit a request through our California Consumer Rights Request Form or call us at 1 888 914 9661, PIN 292703.
Any privacy rights request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected Personal Information. In making a request, you will need to verify that you are the authorized user of the subject email address/account and that you are a current resident of the State of California. Please follow the instructions on our website and promptly respond to any follow-up inquires so that we may confirm your identity. If you request that we provide you with specific pieces of information about you, we will apply heightened verification standards.
An Authorized Agent may submit a request on behalf of a Consumer if the Consumer has provided the Authorized Agent with power of attorney in accordance with California law; alternatively, we will (1) require the Authorized Agent to present verifiable written authorization from the Consumer that the Authorized Agent has the Consumer’s permission to submit the request; and (2) independently verify the Consumer’s own identity with us.
Right to Opt Out of Sales and Sharing of Personal Information – As stated above, we will not share or sell your Personal Information to third parties. For this reason, we do not treat Personal Information collected by Axis as subject to a Do Not Share or Sell request and, therefore, we do not offer a way for you to submit such a request.
Right to Limit Use and Disclosure of Sensitive Personal Information – We do not use or disclose sensitive Applicant Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA. For this reason, we do not offer a way for you to submit such a request.
Right to Know – You have the right to know what Personal Information we have collected about you, which includes:
(1) The categories of Personal Information we have collected about you, including
- The categories of sources from which the Personal Information was collected
- Our business or commercial purposes for collecting Personal Information
- The categories of recipients to which we disclose Personal Information
- The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of third parties to which we disclosed that particular category of Personal Information.
(2) The specific pieces of Personal Information we have collected about you
Right to Delete Your Personal Information – You may request that we delete any Personal Information we have collected directly from you. After we have received your request to delete, and have verified your identity, we will delete your information except as allowed by the CCPA, and will direct any service providers and contractors which received your information from us to delete your Personal Information.
As allowed by the CCPA, we will not delete your Personal Information, even following a verifiable consumer request, if it is necessary for us or our service providers and contractors to maintain the information in order to:
- Complete the transaction for which the personal information was collected, provide a good or service you requested, or reasonably anticipated by you within the context of a business’s ongoing business relationship with you, or otherwise perform a contract between us and you.
- Help ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent.
- To enable solely internal uses that are reasonably aligned with the expectations of consumers based on your relationship with us and compatible with the context which you provided the information.
- Comply with a legal obligation. For example, we may not be able to grant your Request to Delete your Personal Information to comply with various federal, state, and local retention laws.
We will retain a record of the deletion as required by law.
Right to Correct Inaccurate Information – If you believe that any Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
Rights Related to Automated Decision-Making – You have the right to opt out of automated decision-making, including profiling, if we use your Personal Information to evaluate certain personal aspects relating to your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
Right to Non-Discrimination for the Exercise of Your Privacy Rights – If you choose to exercise any of your privacy rights under the CCPA, we will not discriminate against you.
California’s “Shine The Light” Law
California law permits customers in California to request certain details about how their personal information is shared with third parties and, in some cases, affiliates if that personal information is shared for those third parties’ and affiliates’ own direct marketing purposes. We do not share personal information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californian customers may request such information by contacting us at [email protected] or 52 Lime Street, London EC3M 7AF.
To make a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident, and provide your current California address to which we will send our response. Your inquiry must specify “California Privacy Rights Request” in the subject line of the email or the first line of the letter and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.
NOTE: As all of these rights and your CCPA rights exist under different legal regimes, you must exercise your rights under each law separately.
How to Contact Us
Please address all inquiries, requests, and other communications regarding your personal information or this Privacy Notice to:
Contact: Data Protection Officer
Email: [email protected]
Address: 52 Lime Street, London EC3M 7AF
Published: 1 January 2023 v2.0