Last Updated: 27/08/2026

1. Purpose

Davies Group Limited with its registered office at 5th Floor, 20 Gracechurch Street, London, EC3V 0BG, United Kingdom, and its entities and subsidiaries (hereinafter referred to as ‘Davies Group’) is committed to being transparent about how it processes your personal information.

The purpose of this Privacy Notice is to outlines how Davies Group will collect, hold, process, and share your personal information, to assist you in making informed decisions when using our website and/or accessing our products and services.

The objective of this Privacy Notice is to ensure transparency in personal information handling and maintain compliance with relevant data protection regulations, such as Bermuda Personal Information Protection Act (PIPA) and other applicable data protection regulations.

2. Scope

This Privacy Notice applies to all Davies entities, including all regulated entities, in the following territories:

In this Privacy Notice, the terms “we”, “our” or “us” refer to Davies Group, who is the organisation responsible for the use of your personal information.

3. Definitions

The following key terms and definitions are used in this Privacy Notice and should be interpreted in accordance with applicable privacy and data protection laws.

4. The types of personal information we collect

We collect and process the following types of personal information:

• When you browse our website, we use cookies to collect usage data, which may include, but is not limited to, your IP address, browser type/version, browsing behaviour on our site (including the pages that you visit, the time spent on those pages and the date and time of your visit) and your geolocation data. More information about the types of cookies we use and our reasons for using them can be in our Cookie Policy.
• Personal identifiers, contact details, and characteristics, such as your name, country of residence, address, phone number and email address.
• Transaction Data includes details about payments to and from you and other details of forensic accounting services which you have instructed us to provide.
• Due Diligence and Anti-Money Laundering (AML) Data, including documentation and information required for client onboarding, identity verification, and screening checks (e.g. passport details, national identification numbers, or information about political exposure or criminal convictions, where legally required).
• Legal and Contractual Information, including copies of correspondence, signed contracts, declarations, or dispute resolution materials containing personal identifiers, where necessary for fulfilling legal obligations or maintaining business records.
• Sensitive Categories of Personal information including health and/or medical diagnosis information, which may be held, used, and processed for the purpose of providing the services offered by Davies Group.
• We may collect personal information relating to children, but only if consent has been obtained (where required) from a parent or guardian, and the information is relevant to the products and services we provide.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy notice.

5. Where we obtain your personal information from

The personal information we process may be collected from a variety of sources including, but not limited to:

• Experts.
• Fraud prevention agencies and organisations.
• Industry regulators, government authorities, supervisory bodies, and ombudsman services, including (where applicable) data protection authorities, financial regulators, and dispute‑resolution bodies that oversee our industry or operations.
• Insurance companies.
• Insurance industry databases.
• Intermediaries, such as claims management companies.
• Law enforcement agencies.
• Loss adjusters and claims investigators.
• Other third parties.
• Our clients.
• Our website cookies.
• Social media.
• Public sources.
• Third party data providers/search systems.
• Your Insurer/Underwriter.
• Send information to us as a part of our investigations into an investigation you have asked us to perform or an insurance claim you have made.
• Complete any form or create an account on our website i.e. direct interactions.
• Subscribe to our publications.
• When you subscribe to our publications, request to receive marketing materials, or provide feedback such as comments on our website blogs or articles.

During the course of providing our services, we may also collect personal information from you directly, for example when the information is needed to progress your claim.

6. How we use your personal information

The purpose for which we will use personal information will depend on your relationship with our organization. We may use personal information for the following purposes:

• To provide and manage our services, including claims handling, insurance support, and consulting services etc.
• To manage our relationship with clients and business partners.
• To comply with legal and regulatory obligations.
• To protect our business, systems, and data (including fraud prevention, security monitoring, complaint handling, maintaining or servicing accounts, operating user accounts for security purposes, providing customer service, processing or verifying customer information, processing payments, providing analytics services, providing storage, or providing similar services;) and to improve our services, systems, and customer experience.
• To manage recruitment and employment processes.
• To send marketing communications (where permitted by law).

We process personal information based on the lawful bases set out under applicable data protection laws.

7. Our lawful bases for processing your personal information

We may collect, use, or disclose your personal information in the following ways, where permitted or required under applicable data protection laws.

• Consent – you have given clear consent for us to process your personal information for a specific purpose. Please note – for any processing we undertake which relies on your consent, you are able to remove your consent at any time by contacting our Data Protection Officer at DPO@davies-group.com.
• Contract – the processing is necessary to enter into or perform a contract with you, or to take steps at your request before entering into a contract.
• Employment Purposes – the processing is necessary in the context of an employment relationship.
• Legal Obligation – the processing is necessary for us to comply with the law.
• Vital Interest – the processing is necessary to protect your life.
• Public Task – the processing is necessary for us to perform a task in the public interest or our official functions, and the task or function has a clear basis in law.
• Legitimate Interest – the processing is necessary for our legitimate interests or the legitimate interests of a third party. For example, when you register to attend an event or webinar, we will use your contact details to contact you about the event/webinar and inform relevant staff, and any partner that we are running the event/webinar with, that you will be attending. We may also use your name for name tags and any other event management requirements, including but not limited to table arrangements, corporate gifting and collateral.

8. Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note – we may process your personal information without your knowledge or consent in compliance with the above rules, where this is required or permitted by law. For example, where the processing relates to the detection and prevention of crime.

9. Automated processing and use of AI technologies

In some circumstances, we may use automation technologies and AI systems to support the processing of personal information, improve operational efficiency, and enhance user experience. These tools do not make decisions about individuals without human involvement, but rather assist with internal workflows, customer interactions, and data analysis. Our current use of automation technologies includes:

• Robotic Process Automation (RPA) – Where virtual workers automate the copying and pasting of information from one system into another.
• Self-Service Platforms – Allows humans to directly interact with an RPA process, enabling human-in-the-loop processing of information.
• Artificial Intelligence (AI) and Machine Learning – To enable virtual workers to learn and understand the data presented and improve effectiveness.
• Intelligent Automation Digital Assistant – An AI supervisor that automatically manages, tracks, and orchestrates virtual worker schedules and activities.
• Computer Vision/Optical Character Recognition – Offers pattern matching within images and can be used to interpret complicated language-based text recognition.
• Natural Language Processing – Translates/extracts human language into computer readable information (think “Hey Siri”) for the purpose of classifying information.
• Conversational AI – Uses AI and Natural Language Processing to enable real-time conversations with customers via the use of chatbots.
• API End-points – Uses virtual workers to bridge the gap between old systems and new ones by copying and pasting information across.
We do not anticipate that any of the automation technologies described above will produce legal or similarly significant effects on you, however if this was to change in the future, we would only do so where it is:
• Necessary for the entry into or performance of a contract; and
• Authorised under domestic laws applicable to the organisation; or
• Based on your explicit consent.

10. Who we share your personal information with

Within Davies Group, your personal information will be shared with those team members who need to access it for the processing purposes outlined in this Privacy Notice.

We will only share your personal information with other parties where it is reasonable and necessary to accomplish the processing purposes outlined in this Privacy Notice. This may include (but is not limited to) where we:

• Are required to share information with law enforcement bodies and/or fraud prevention agencies for the purpose of preventing or detecting fraud or criminal activities; or
• Rely on the services of third-party service providers and hosting providers to carry out activities, provide services, or undertake business operations on our behalf. For example, we may use Hotjar in order to better understand our users’ needs and to optimise their service and experience when using our websites. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices, then stores this information on our behalf in a pseudonymised user profile. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

In any such cases, the data we share will be limited to that which is strictly necessary and will be subject to appropriate contractual and confidentiality arrangements being in place.

Additionally, all of our third-party service providers are required to take appropriate security measures to protect your personal information, in line with Davies Group policies, and we do not allow them to use your personal information for their own purposes under any circumstances.

11. International transfers

Davies Group operates internationally and personal information may be transferred to, accessed from, or processed in countries other than the country in which it was collected, including by Davies Group entities, our Global Capability Centre in India, and authorised third-party service providers.

Where we transfer, disclose, store, or otherwise make personal information available outside the country in which it was collected, we will take appropriate steps to protect that data in accordance with applicable data protection laws. These steps may include:

• conducting due diligence on overseas recipients and service providers;
• relying on adequacy decisions, recognised comparable protection mechanisms, or equivalent legal safeguards where available;
• entering into appropriate contractual arrangements, such as standard contractual clauses, model contract clauses, intra-group transfer arrangements, data processing agreements, or other equivalent contractual protections;
• carrying out transfer risk assessments where required or appropriate;
• implementing supplementary technical and organisational measures;
• ensuring overseas recipients are required to protect personal information to a standard that is comparable or equivalent to the protection required under applicable data protection laws;
• limiting overseas transfers to what is necessary for the relevant purpose.

If you would like to understand more about this, please send an email outlining your query to DPO@davies-group.com.

For a list of Davies Group subsidiaries and legal entities, please refer to our Global Privacy Notice.

12. How long we keep your personal information for

We will keep your personal information for as long as necessary to fulfil the purposes that we describe in this Privacy Notice, including to satisfy any applicable legal, tax-related, forensic, and other business requirements.

To determine the appropriate retention period, we also consider a number of additional factors, such as the:

• Nature and sensitivity of the personal information.
• Potential risk of harm from unauthorised use or disclosure of the personal information.
• Requirements of the organisation on whose behalf we use personal information, where applicable.

13. How we keep your information secure

Davies Group has implemented an Information Security Management System (ISMS), which is globally certified to the International Organisation for Standardization (ISO) 27001 standard for Information Security. This demonstrates our commitment to managing risks related to the security of the personal information we own and handle. We implement a range of technical, organisational, and physical security measures aligned with industry standards to protect your personal information from loss, misuse, unauthorised access, disclosure, alteration, or destruction. Our robust controls, policies, and procedures ensure that only authorised personnel have access to your information, maintaining its security throughout its lifecycle. These measures are further supported by an internal audit function and annual external certification.

14. Your rights

Davies Group is committed to processing your personal information in compliance with all applicable laws and regulations. Under relevant data protection regulations, you may be entitled to exercise certain individual rights, including:

• Right to Access Your Personal Information: You have the right to request access to the personal information we hold about you. This includes the ability to understand what information we use, how we use it, and why.

• Right to Access Your Medical Records: If applicable, you may request access specifically to medical records that relate to you.

• Right to Rectification: You have the right to ask us to rectify personal information you think is inaccurate, or to complete information you think is incomplete.

• Right to Request Blocking, Erasure, or Destruction: You may request that we block, erase, or destroy your personal information in certain circumstances. Please note – there may be certain circumstances under which we are obliged to retain your personal information.

• Right to Make a Complaint or Request a Review: If you believe your rights under PIPA have been violated, you may ask the Privacy Commissioner to conduct a review, or you may make a formal complaint. You can do this by following the link to their website: https://www.privacy.bm/contact-us. PIPA expects individuals to first raise the matter directly with the organisation, allowing them an opportunity to resolve it.

These rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access.

To exercise any of the rights outlined above, please contact us at SAR@davies-group.com. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

15. How to complain

We aim to meet the highest standards to safeguard your privacy. However, if you have any concerns about Davies Group use of your personal information, you can make a complaint to our Data Protection Officer by emailing DPO@davies-group.com, or by writing to:

Data Protection Officer
Davies Group
3rd, and 4th Floors
No.2 Smithfields
Stoke-on-Trent, ST1 3DH
United Kingdom

Additionally, as per Bermuda PIPA if you believe that your personal information has been mishandled or that we have not complied with the regulation, you have the right to lodge a complaint with the Office of the Privacy Commissioner for Bermuda.
Link: https://www.privacy.bm/contact-us

16. Contact us

Our Group Data Protection Officer is Adam B Smith.

If you have any questions that could not be answered by this Privacy Notice or if you wish to receive more in-depth information about any of the content within it, please contact us at:

Post: Data Protection Officer, Davies Group, 3rd, and 4th Floors, No.2 Smithfields, Stoke-on-Trent, ST1 3DH, United Kingdom

Email: DPO@davies-group.com

17. Changes to this privacy notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a copy of the updated Privacy Notice (displayed electronically) when we make any substantial changes. We may also notify you in other ways from time to time about changes to the processing of your personal information.