Privacy Policy

1. Data controller

TEDmar International is a trading name of Acies Management Holdings Limited (company no. 11136744, FCA FRN 830581), registered at 71 Fenchurch Street, London EC3M 4BS ("we", "us", "our"). We are the data controller for personal data collected through this website and in the course of our ports and terminal insurance business.

If you have any questions about this policy or how we handle your data, please contact us at underwriting@ted-mar.com or write to us at 71 Fenchurch Street, London EC3M 4BS.

2. Data we collect

We may collect and process the following categories of personal data:

2.1 Contact and identity data

Name, job title, employer name, business address, email address, and telephone number provided when you contact us, request a quote, or submit a risk for underwriting.

2.2 Professional and insurance risk data

Information relating to ports and terminal operations, risk profiles, claims history, survey reports, policy details, and other underwriting data necessary to assess, place, and manage insurance cover.

2.3 Technical data

IP address, browser type and version, operating system, time zone, device information, and pages visited on our website.

2.4 Cookie data

Information collected via cookies and similar technologies as described in our Cookie Policy.

3. Lawful bases for processing

We process your personal data on the following lawful bases under UK GDPR:

• Contract: where processing is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into a contract (e.g. providing an insurance quotation, binding cover, or handling claims).
• Legal obligation: where processing is necessary to comply with a legal obligation to which we are subject (e.g. FCA regulatory requirements, anti-money laundering checks, and sanctions screening).
• Legitimate interests: where processing is necessary for our legitimate interests or those of a third party, provided your rights do not override those interests. Our legitimate interests include administering and improving our business, marketing our services to industry professionals, and preventing fraud.
• Consent: where you have given clear consent for us to process your personal data for a specific purpose (e.g. receiving marketing communications or accepting non-essential cookies). You may withdraw consent at any time by contacting us at underwriting@ted-mar.com.

4. How we share your data

We may share your personal data with the following categories of recipients:

• Capacity providers and Lloyd's syndicates: insurers and reinsurers to whom we place or delegate risks on your behalf, including Lloyd's of London syndicates and other capacity providers in the London Market.
• Group companies: other entities within the ACIES MGU group for internal administration, compliance, and business management purposes.
• Regulators and authorities: the Financial Conduct Authority (FCA), Lloyd's of London, HM Revenue and Customs, the Information Commissioner's Office (ICO), and other regulatory or law enforcement bodies where required by law.
• Professional advisers: lawyers, auditors, accountants, and loss adjusters acting on our behalf.
• Service providers: IT hosting providers, analytics services (Google Analytics, Microsoft Clarity), email platforms, and other data processors who process data on our behalf under written agreements that require them to protect your data.

We do not sell your personal data to third parties.

5. International transfers

Some of the recipients listed above may be located outside the United Kingdom. Where we transfer personal data internationally, we ensure appropriate safeguards are in place as required by UK GDPR, including:

• transfers to countries recognised by the UK Government as providing an adequate level of data protection;
• the use of International Data Transfer Agreements (IDTAs) or standard contractual clauses approved by the ICO; or
• other lawful transfer mechanisms under UK data protection law.

You may request details of the safeguards we apply by contacting us at underwriting@ted-mar.com.

6. Data retention

We retain personal data relating to insurance policies, claims, and underwriting for a minimum of six years after the expiry or termination of the relevant insurance contract. This period reflects the standard limitation period under English law, regulatory record-keeping requirements under FCA rules, and the potential for late-notified insurance claims in the ports and terminal sector.

Data collected for marketing purposes is retained until you withdraw consent or unsubscribe. Technical and cookie data is retained in accordance with the durations set out in our Cookie Policy.

When personal data is no longer required, it is securely deleted or anonymised.

7. Your rights

Under UK GDPR and the Data Protection Act 2018, you have the following rights:

• Right of access: to request a copy of the personal data we hold about you.
• Right to rectification: to request correction of inaccurate or incomplete data.
• Right to erasure: to request deletion of your data where there is no compelling reason for its continued processing.
• Right to restrict processing: to request that we limit our use of your data in certain circumstances.
• Right to data portability: to receive your data in a structured, commonly used, machine-readable format.
• Right to object: to object to processing based on legitimate interests or for direct marketing purposes.
• Rights related to automated decision-making: not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects.

To exercise any of these rights, please contact underwriting@ted-mar.com. We will respond within one month. There is no fee for making a request, unless the request is manifestly unfounded or excessive.

8. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encrypted communications, access controls, regular security assessments, and staff training on data protection.

While we take all reasonable precautions, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your data.

9. Cookies and tracking technologies

Our website uses cookies and similar technologies to ensure functionality, analyse usage, and improve your experience. For full details of the cookies we use and how to manage your preferences, please see our Cookie Policy.

10. Complaints

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: ico.org.uk/make-a-complaint
• Telephone: 0303 123 1113
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

We would appreciate the opportunity to address your concerns before you contact the ICO. Please contact us first at underwriting@ted-mar.com.

11. Changes to this policy

We may update this privacy policy from time to time. Any changes will be posted on this page with an updated "Last updated" date. We encourage you to review this policy periodically.

12. Contact

For any questions about this privacy policy or our data practices, please contact:

TEDmar International
71 Fenchurch Street, London EC3M 4BS
Email: underwriting@ted-mar.com