Privacy Policy

Last updated: July 2026

Crewsure Insurance Services Limited is committed to protecting personal information and handling it fairly, lawfully and transparently.

This Privacy Policy explains how we collect, use, share and protect personal information in connection with our website, insurance products, quotations, policy administration, claims handling, complaints, regulatory obligations and related services.

Crewsure Insurance Services Limited is registered in England and Wales under company number 09325907. Our registered office is 2 St James’s Street, London SW1A 1EF and we trade from Room 821, Lloyd’s of London 1986 Building, One Lime Street, London EC3M 7DQ. Crewsure is an Appointed Representative of ES Risks Limited, which is authorised and regulated by the Financial Conduct Authority. (crewsure.com)

For European business, Crewsure Insurance Services (Europe) is a trading style of ES Risks Europe EPE, authorised by the Bank of Greece and authorised and regulated in the UK by the FCA. (crewsure.com)

1. Who this policy applies to

This policy applies to personal information relating to:

• insured persons, seafarers, yacht crew, employees and their dependants;
• policyholders, employers, shipowners, yacht owners and crew managers;
• brokers, insurers, reinsurers, coverholders, claims administrators and service providers;
• website users and people who contact us;
• complainants, witnesses and other persons involved in claims or policy administration.

2. Information we collect

We may collect and process the following types of personal information:

• name, address, email address, telephone number and other contact details;
• date of birth, age, nationality, gender, occupation, rank, employer and vessel details;
• passport, identity, travel and residency information where required;
• policy, quotation, underwriting and claims information;
• medical, health, accident, disability and treatment information;
• next of kin, dependant and family member information;
• bank account and payment information where required for premium, claims or refunds;
• sanctions, anti-money laundering, fraud prevention and regulatory screening information;
• correspondence, call recordings and complaint records;
• website usage data, enquiry form data and cookie information.

Some of the information we process may be special category data, including medical and health information. We may also process information relating to criminal offences where necessary for fraud prevention, sanctions screening, legal claims or regulatory compliance.

3. How we collect information

We may receive personal information from:

• you directly;
• your employer, shipowner, yacht owner, crew manager or recruitment/placement agency;
• brokers, intermediaries, insurers, reinsurers and Lloyd’s market participants;
• claims administrators, medical providers, assistance companies and loss adjusters;
• sanctions, fraud prevention, credit reference and compliance screening providers;
• regulators, law enforcement bodies, courts, tribunals and ombudsman services;
• our website, enquiry forms and client systems.

4. Why we use personal information

We use personal information for the following purposes:

• providing quotations and assessing insurance risk;
• arranging, administering and renewing insurance policies;
• issuing insurance documentation and certificates;
• managing premium, bordereaux, accounting and payment processes;
• handling claims, including medical assistance, repatriation, death, disability, accident and healthcare claims;
• administering dependants’ healthcare and employee benefit schemes;
• preventing, detecting and investigating fraud, sanctions breaches, money laundering, financial crime or other unlawful activity;
• complying with legal, regulatory, tax, audit and reporting obligations;
• handling complaints and disputes;
• defending, bringing or settling legal claims;
• improving our products, systems, controls and services;
• maintaining records for governance, audit and compliance purposes;
• sending business communications, service updates and, where permitted, marketing communications.

5. Our lawful bases for processing

We process personal information where one or more of the following lawful bases applies:

• Contract: where processing is necessary to arrange, administer or perform an insurance contract or related service.
• Legal obligation: where processing is necessary to comply with regulatory, tax, accounting, sanctions, anti-money laundering or other legal obligations.
• Legitimate interests: where processing is necessary for our legitimate business interests, including underwriting, claims handling, fraud prevention, business administration, governance, audit and service improvement.
• Recognised legitimate interests: where applicable under the Data (Use and Access) Act 2025, including certain processing for crime prevention, safeguarding, emergencies and other specified legitimate interests. (GOV.UK)
• Consent: where we ask for consent, for example for certain uses of health information or marketing.
• Vital interests: where processing is necessary to protect someone’s life or safety, for example in a medical emergency.

For special category data, including health and medical information, we rely on additional conditions under data protection law, including processing for insurance purposes, legal claims, substantial public interest, explicit consent where required, and the provision or management of healthcare or related services.

6. Insurance market processing

Insurance is provided through a chain of participants. We may share personal information with brokers, coverholders, Lloyd’s managing agents, insurers, reinsurers, claims administrators, medical providers, assistance providers, auditors, regulators and other parties involved in placing, administering or performing insurance contracts.

Where Lloyd’s market participants are involved, personal information may also be processed in line with the London Market Core Uses Information Notice, which explains common insurance market uses of personal information.

7. Sharing information

We may share personal information with:

• insurers, reinsurers, Lloyd’s managing agents and Lloyd’s market participants;
• brokers, coverholders, agents and intermediaries;
• claims administrators, medical providers, hospitals, assistance companies and repatriation providers;
• employers, shipowners, yacht owners, crew managers and scheme sponsors, where appropriate;
• professional advisers, auditors, accountants, lawyers and compliance consultants;
• IT, hosting, CRM, payment and document management providers;
• banks, payment service providers and premium processors;
• fraud prevention, sanctions screening and financial crime databases;
• regulators, tax authorities, law enforcement agencies, courts, tribunals and ombudsman services;
• prospective purchasers or transferees of all or part of our business, subject to appropriate safeguards.

We will only share information where it is necessary, lawful and proportionate.

8. International transfers

Because Crewsure operates in the international marine, yachting and insurance markets, personal information may be transferred outside the UK and EEA, including to insurers, reinsurers, claims administrators, medical providers, assistance companies, brokers, employers and service providers in other countries.

Where required, we will use appropriate safeguards, such as adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to EU Standard Contractual Clauses, contractual protections or another lawful transfer mechanism. The DUAA also updates and clarifies aspects of the UK international transfer regime. (GOV.UK)

9. Security

We use appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure. These measures include access controls, confidentiality obligations, secure systems, staff training, data protection policies and contractual controls with service providers.

10. How long we keep information

We keep personal information only for as long as necessary for the purposes for which it was collected.

In insurance, we may need to retain information for extended periods because claims can arise long after a policy has expired, and because we must meet regulatory, audit, tax, accounting and legal obligations.

Retention periods may vary depending on the type of information, the policy, the claim, the jurisdiction and any applicable legal or regulatory requirement.

11. Automated decision-making and profiling

We may use systems and data tools to support underwriting, pricing, sanctions screening, fraud prevention, claims triage, compliance checks and administration.

Where any decision is made solely by automated processing and has a legal or similarly significant effect, we will comply with applicable safeguards, including providing relevant information, enabling representations or challenge, and allowing human intervention where required. The DUAA creates a more permissive framework for automated decision-making but retains important safeguards. (GOV.UK)

12. Marketing

We may send business-to-business communications about our products and services where permitted by law.

We will only send electronic marketing to individuals where we have a lawful basis to do so, such as consent or the soft opt-in where applicable. You may opt out of marketing at any time by contacting us at enquiries@crewsure.com.

13. Cookies and website data

Our website may use cookies and similar technologies to operate the site, improve functionality, analyse usage and support security.

Some cookies are necessary for the website to function. Other cookies may require consent. The DUAA allows certain low-risk storage and access technologies to be used without explicit consent in limited circumstances, but we will continue to apply appropriate transparency and choice. (GOV.UK)

Please see our Cookie Policy for more information.

14. Your rights

Subject to applicable legal limits and exemptions, you may have the right to:

• be informed about how your personal information is used;
• access your personal information;
• request correction of inaccurate information;
• request deletion of information;
• restrict processing;
• object to processing;
• request data portability;
• withdraw consent where processing is based on consent;
• challenge certain automated decisions;
• complain about how your information is handled.

The DUAA clarifies aspects of subject access requests, including “stop the clock” rules where further information is required and the need for reasonable and proportionate searches. (GOV.UK)

15. Complaints about data protection

You may contact us if you have a concern about how we use your personal information.

We will consider and respond to data protection complaints in accordance with applicable law. The DUAA requires organisations to provide a process for individuals to complain about data protection concerns and to inform individuals about the outcome. (GOV.UK)

You may also complain to the Information Commissioner’s Office:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Website: ico.org.uk

16. Contact details

For privacy or data protection queries, please contact:

The Data Protection Officer
Crewsure Insurance Services Limited
Room 821, Lloyd’s of London 1986 Building
One Lime Street
London
EC3M 7DQ
United Kingdom

Email: enquiries@crewsure.com
Telephone: +44 (0) 20 7046 0866

17. Changes to this policy

We may update this Privacy Policy from time to time to reflect legal, regulatory, operational or business changes. The latest version will be published on our website.