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 data. Davies Shared Services India Private Limited (hereinafter referred to as ‘DSSI’) is the Indian subsidiary of Davies Group Limited.

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

The objective of this notice is to ensure transparency in personal data handling and maintain compliance with relevant data protection regulations, such as Indian Digital Personal Data Protection Act (DPDPA), Information Technology Act (“IT Act”) and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules (“SPDI Rules”).

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’ are used to refer to Davies Group, who are the data controller (also referred as data fiduciary) or processor responsible for processing your personal data.

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 data we collect

We collect and process the following types of personal data:

• 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 data 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 data 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 data but is not considered personal data 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 data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

5. Where we obtain your personal data from

The personal data 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.
• Visiting any of the Davies Group office.
• 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 data from you directly, for example when the information is needed to progress your claim.

6. How we use your personal data

The purpose for which we will use personal data will depend on your relationship with our organization. We may use personal data 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 data based on the lawful bases set out under applicable data protection laws.

7. Our lawful bases for processing your personal data

We may collect, use, disclose, store, transfer or otherwise process your personal data where permitted under applicable India data protection laws, in the following circumstances:

• Consent – where you have given us your clear and informed consent to process your personal data for a specific purpose. You may withdraw your consent at any time by contacting our Data Protection Officer dpo.india@davies-group.com and DPO@davies-group.com
• Legitimate Uses (Deemed Consent) – in certain cases, your personal data may be processed without explicit consent, such as:

• • For employment-related purposes (e.g., recruitment, payroll, benefits, attendance, background verification).
  • To comply with legal obligations or judgments.
  • To respond to medical, safety emergencies, threat to life or health, disaster or public-order assistance.
  • Where you have voluntarily shared the data with us for a clear purpose.

8. Change of purpose

We will only use your personal data 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 data 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 data without your knowledge or consent in compliance with the above rules, where this is required or permitted by applicable law. For example, where the processing relates to the detection and prevention of crime.

9. Automated decision-making and profiling

In some circumstances, we may use automated technologies, artificial intelligence systems and analytical or profiling tools to process personal data for specified lawful purposes, including supporting internal workflows, improving operational efficiency, assisting customer interactions, analysing service usage and improving our products and services. These technologies may assist our personnel in reviewing information and making decisions. We do not currently use personal data to make material decisions about you based solely on automated processing without meaningful human review. 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
• Required under applicable laws.
• Based on your explicit consent.

10. Who we share your personal data with

Within Davies Group, your personal data 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 data 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 data, in line with Davies Group policies, and we do not allow them to use your personal data for their own purposes under any circumstances.

11. International transfers

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

Where we transfer, disclose, store, or otherwise make personal data 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 data 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 data for

We will keep your personal data 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 legitimate 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 data.
• Potential risk of harm from unauthorised use or disclosure of the personal data.
• Requirements of the relevant controller, where we are acting in the capacity of processor.

13. How we keep your data secure

Davies Group has implemented an Information Security Management System (ISMS), which is globally certified to the International Organization for Standardization (ISO) 27001 standard for Information Security. This demonstrates our commitment to managing risks related to the security of the personal data we own and handle. We implement a range of technical, organisational, and physical security measures aligned with industry standards to protect your personal data 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 data in compliance with applicable India data protection laws, and you have certain rights in relation to your personal data; however, the exercise of these rights is subject to applicable legal conditions, exemptions, and limitations:

• Right to access: you have the right to access your personal data that the organization holds or ask us for a copy of the personal data we hold about you.

• Right to correction and erasure: you have the right to ask us to correct inaccurate or incomplete information and to erase your personal data in certain situations. Please note – there may be certain circumstances under which we are obliged to retain your personal data.

• Right to withdraw consent: You may withdraw your consent at any time where processing is based on consent. However, withdrawal of consent may impact our ability to provide or continue providing certain services or functionalities that depend on the processing of such personal data.

• Right to grievance redressal: you have the right to file complaints about any actions or concerns related to your personal data. The organization or data protection officer will respond to your complaint within a set time frame. You must try to resolve the complaint through the provided grievance process before going to the Data Protection Board of India.

• Right to nominate: you have the right to nominate or appoint someone else to exercise your data rights if you pass away or become unable to do so due to cognitive or health issues.

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 and to help us respond to your request securely.

We may refuse or restrict a request where permitted by applicable law, including where the request is unrelated to the rights available under applicable law, excessively repetitive, conflicts with judicial procedures or investigations, may negatively affects the privacy or confidentiality of personal data relating to others, or where we are required or permitted to retain or continue processing the personal data under applicable laws.

15. How to complain

We are committed to protecting your personal data and addressing any privacy-related concerns promptly and fairly. If you have a concern about how Davies collects, uses, shares, stores or otherwise processes your personal data, you may contact:

• Group Data Protection Officer: Adam B Smith, Email: DPO@davies-group.com
• India Data Protection Officer and Privacy Contact: Atul Karale, Email: dpo.india@davies-group.com

Please provide sufficient information for us to understand and investigate your concern. We will acknowledge, review and respond to your complaint within the timeframe prescribed under applicable data protection laws.

If your complaint is not resolved to your satisfaction after you have exhausted our internal grievance-redressal process, you may make a complaint to the Data Protection Board of India, where permitted under applicable law. Information about the Data Protection Board of India and its official complaint-submission mechanism will be available through the official channels published by the Government of India.

For information concerning India’s data protection framework, please visit the Ministry of Electronics and Information Technology website: https://www.meity.gov.in/

16. Contact us

Our Group Data Protection Officer is Adam B Smith. Atul Karale acts as our India Data Protection Officer and privacy contact.

If you have any questions about this Privacy Notice or how we process your personal data, wish to exercise your rights, or raise a privacy-related concern or grievance, please contact:

• India Data Protection Officer and Privacy Contact: dpo.india@davies-group.com
• Group Data Protection Officer: DPO@davies-group.com

We will review and respond to your request or grievance in accordance with applicable Indian data protection laws.

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 data.