Privacy Policy

PRIVACY NOTICE – 2026

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1.     INTRODUCTION
Your privacy is very important to us. This Privacy Notice will help you understand how Sparrowhawk Re SPC ("us", "we", "our"), as data controller, may collect, use, and store non-public personal information about our prospective and former clients, and website users in accordance with the Cayman Islands Data Protection Act, (as Revised) (the "Data Protection Legislation").

These policies apply to our clients and users of our website and may be changed at any time, provided a notice of such change is given to you.

2.     INFORMATION WE MAY COLLECT
By virtue of your business with us or by virtue of you otherwise providing us with your personal information, we may obtain information relating to you and/or any individuals connected with you including your address, social security number, assets and/or income information, which constitute personal data within the meaning of the Data Protection Legislation.

We may obtain your personal information from sources including: (i) through our website; (ii) subscription agreements and related documents which are maintained by service providers; (iii) in correspondence and conversations with us and our representatives; and (iv) through transactions and during the acceptance and management of your account.

3.     HOW WE USE YOUR INFORMATION
We may collect, store and use your data if it is necessary for the performance of a contract, or if the processing is necessary for compliance with applicable legal or regulatory obligations (including complying with requests from regulatory, governmental, tax and law enforcement authorities). We may use your information to improve and maintain our website or in pursuance of our legitimate interests. We will only process your personal data in pursuance of our legitimate interests where we have considered that the processing is necessary and, on balance, our legitimate interests are not overridden by your legitimate interests, rights or freedoms.

4.     SHARING YOUR DATA
We do not disclose any of this non-public personal information about our clients or prospective or former clients to anyone other than to our affiliates or delegates. In certain circumstances we may be legally obliged to share your data with the relevant regulatory authorities. For example, it may be necessary, under anti-money laundering and similar laws, to disclose information about clients in order to accept their subscriptions. Our affiliates and delegates may process your personal data on the our behalf including with our accountants, attorneys, auditors, brokers, and certain service providers.

5.     SECURITY
We seek to carefully safeguard your private information. We restrict access to non-public personal information about you to those employees and other persons who need to know the information to enable us to provide services to you. We maintain physical, electronic and procedural safeguards to protect your non-public personal information.

6.     RETENTION AND DELETION OF YOUR DATA
We will keep your data for as long as it is required by us to fulfil the purposes outlined in this notice or as required by applicable law. We expect to delete your personal data (at the latest) once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining your data.

7.     YOUR RIGHTS
You may have certain data protection rights under the Data Protection Legislation including to;

  • be informed about the purposes for which your personal data are processed;

  • access your personal data;

  • stop direct marketing;

  • restrict the processing of your personal data;

  • have incomplete or inaccurate personal data corrected;

  • ask us to stop processing your personal data;

  • be informed of a personal data breach (unless the breach is unlikely to be prejudicial to you);

  • complain to the Data Protection Ombudsman; and

  • require us to delete your personal data in some limited circumstances.

8.     CONTACT US
Please contact us if you have any questions about this Privacy Notice or the data we hold about you marking your communication "Data Protection Enquiry". Our contact details are: [insert email address].