Privacy Policy

EarthRe Insurance IFSC Limited (“EarthRe”, “we”, “us”, or “our”) is a reinsurer licensed by the International Financial Services Centres Authority (IFSCA) and operating from Unit No 47, The Platform, 11T2, Block 11, TS2, Sangath, Ground Floor, Block 11, Road 1A, Zone 1, GIFT SEZPA, GIFT City, Gandhinagar, Gujarat, India.

We are committed to safeguarding the privacy and confidentiality of all personal data entrusted to us in the course of our reinsurance operations, website usage, and business interactions. This Privacy Policy describes our practices regarding the collection, use, storage, sharing, and protection of personal information.

By accessing our website (earthre.in) or engaging with us in a business capacity, you acknowledge that you have read, understood, and agreed to be bound by the terms of this Privacy Policy.

This Privacy Policy applies to:

• All visitors to the EarthRe website (earthre.in)
• Cedants, brokers, intermediaries, and business partners who interact with us in the course of reinsurance business
• Job applicants and prospective employees
• Any individual whose personal data we process in connection with our operations

This policy does not apply to third-party websites or platforms that may be linked from our website. We encourage you to review the privacy policies of any third-party sites you visit.

For the purposes of this Privacy Policy:

• EarthRe: EarthRe Insurance IFSC Limited, a company incorporated and licensed to conduct reinsurance business from IFSC, GIFT City, under the regulatory purview of IFSCA.
• DPDP Act: The Digital Personal Data Protection Act, 2023, and any rules or regulations made thereunder.
• Personal Data: Any information that identifies or can reasonably identify a natural person, directly or indirectly.
• Sensitive Personal Data: Financial account details, health or medical information, biometric data, official identifiers (such as PAN or Aadhaar), and any other category prescribed under applicable law.
• Data Principal: The individual to whom personal data relates.
• Data Fiduciary: EarthRe, in its capacity as the entity that determines the purpose and means of processing personal data.
• Processing: Any operation performed on personal data, including collection, storage, use, disclosure, transfer, or deletion.

1. Information you provide to us

• Name, designation, organisation, business email address, and telephone number provided through our contact form, enquiry submissions, or direct correspondence
• Professional credentials, employment history, and qualifications submitted by job applicants
• Treaty and risk information shared by cedants and brokers in the ordinary course of reinsurance business
• AML/KYC documentation including identity and address proof, PAN, and beneficial ownership information required by applicable regulations

2. Information collected automatically

• IP address, browser type and version, operating system, and device identifiers
• Pages visited, time spent on site, referring URLs, and clickstream data collected through cookies and analytics tools
• Approximate geographic location derived from IP address

3. Information from third parties

• Business contact information from cedants, brokers, or reinsurance intermediaries
• Publicly available information from regulatory filings, company registries, and professional databases used for due diligence
• Sanctions screening and fraud prevention data from authorised third-party providers

We do not knowingly collect personal data from individuals under the age of 18.

By providing your personal data to us or by continuing to use our website, you consent to the collection, storage, processing, and use of your information in accordance with this Privacy Policy.

Where we rely on consent as the lawful basis for processing, you have the right to withdraw your consent at any time by contacting us at compliance@earthre.in. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal, and may limit our ability to provide certain services or respond to your enquiries.

For data processed on the basis of a legal obligation, regulatory requirement, or legitimate business interest, withdrawal of consent does not prevent such processing.

EarthRe has designated a Compliance Officer to handle all privacy-related queries, complaints, and requests. If you have any concerns regarding the collection, storage, or use of your personal data, you may contact:

Compliance Officer EarthRe Insurance IFSC Limited Unit No 47, The Platform, 11T2, Block 11, TS2, Sangath, Ground Floor, Block 11, Road 1A, Zone 1, GIFT SEZPA, GIFT City, Gandhinagar, Gujarat, India CIN: U65020GJ2025PLC170845 Email: compliance@earthre.in

We will endeavour to acknowledge your complaint within 72 hours and resolve it within 30 days of receipt.

We process personal data for the following purposes:

• Reinsurance operations: to evaluate, underwrite, price, and administer reinsurance treaties and facultative contracts, and to process and settle claims
• Regulatory compliance: to meet obligations under IFSCA regulations, the DPDP Act, AML/CTF/KYC requirements, and other applicable Indian law
• Due diligence: to verify the identity and credentials of cedants, brokers, and business partners
• Communication: to respond to enquiries, provide business updates, and maintain our relationships with counterparties
• Website analytics: to understand how our website is used and improve its content and performance
• Recruitment: to evaluate job applications and communicate with candidates
• Security and fraud prevention: to protect our systems, detect fraudulent activity, and maintain network integrity

We do not sell, rent, or trade personal information to third parties for commercial purposes. We may disclose personal data to:

• Retrocessionaires and reinsurance intermediaries: in the ordinary course of risk transfer, treaty placement, and claims administration
• Regulators and statutory authorities: including IFSCA, the Financial Intelligence Unit (FIU-IND), and other competent bodies where required by law
• Professional advisors: including legal counsel, statutory auditors, appointed actuaries, and management consultants, each bound by professional confidentiality obligations
• Technology and service providers: including cloud infrastructure, data analytics, and IT support vendors who process data under written data processing agreements
• Group companies and affiliates: to the extent necessary for operational and compliance purposes, subject to appropriate confidentiality safeguards

If you wish to restrict the sharing of your personal data with any specific category of third party, please write to us at compliance@earthre.in. We will accommodate such requests to the extent permitted by our legal and regulatory obligations.

Cookies

Our website uses cookies and similar tracking technologies to enhance your browsing experience and gather usage analytics. Cookies are small text files stored on your device.

• Strictly necessary cookies: essential for the website to function correctly
• Analytics cookies: used to understand visitor behaviour and improve site content (e.g., page views, session duration)
• Preference cookies: used to remember your settings across visits

You may disable cookies through your browser settings at any time. Doing so may affect the functionality of certain parts of our website.

Automatic data collection

When you visit our website, we automatically collect technical data including your IP address, browser type, device identifiers, and pages visited. This data is used in aggregated and anonymised form to improve our website and monitor for security threats.

Third-party analytics

We may use third-party analytics tools (such as Google Analytics) to collect and analyse website usage data. These providers operate under their own privacy policies and data processing agreements with us.

Our website may contain links to third-party websites and platforms, including professional networks such as LinkedIn. These sites operate independently and are governed by their own privacy policies. EarthRe is not responsible for the privacy practices, content, or security of any third-party website.

We encourage you to review the applicable privacy policy before submitting any personal information to a third-party site.

EarthRe implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security controls include:

• Encryption of data in transit using TLS and at rest using industry-standard protocols
• Role-based access controls limiting data access to authorised personnel on a need-to-know basis
• Regular internal and external security assessments and vulnerability testing
• Employee training on data protection and information security
• Incident response procedures to detect, report, and address data breaches promptly

Personal data is stored primarily in secure electronic systems. Physical records are retained for the minimum period required by applicable law and then securely destroyed.

While we take all reasonable steps to protect your information, no method of data transmission over the internet or electronic storage is entirely secure. We cannot guarantee absolute security.

Access to and use of the EarthRe website is permitted solely for lawful, non-commercial purposes. The following are strictly prohibited:

• Scraping, data mining, or automated extraction of any content or data from our website
• Using our website or its content for any unlawful, fraudulent, or harmful purpose
• Attempting to gain unauthorised access to our systems, servers, or databases
• Reproducing or distributing website content without our prior written consent

Violations of these restrictions may be actionable under applicable law, including the Information Technology Act, 2000, and the DPDP Act, 2023.

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including to meet legal, regulatory, accounting, and reporting obligations.

• Reinsurance treaty, underwriting, and claims records: minimum seven years from contract expiry, or as required by IFSCA regulations
• AML/KYC records: minimum five years from the end of the business relationship, or as prescribed by applicable law
• Website analytics data: retained in aggregated or anonymised form after 24 months
• Recruitment data (unsuccessful applicants): up to 12 months, unless you provide consent for longer retention
• Correspondence and general business records: up to seven years

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised.

Subject to applicable law, including the DPDP Act, 2023, you may have the following rights in respect of your personal data:

• Right of access: to obtain confirmation of whether we process your personal data and to receive a copy of it
• Right to correction: to request rectification of inaccurate or incomplete personal data
• Right to erasure: to request deletion of your personal data where it is no longer required for the purpose collected, subject to legal retention obligations
• Right to restrict processing: to request that we limit processing of your data in certain circumstances
• Right to withdraw consent: where processing is based on consent, to withdraw it at any time without affecting prior processing
• Right to grievance redressal: to lodge a complaint with our Compliance Officer or with the competent data protection authority

To exercise any of these rights, please write to us at compliance@earthre.in with sufficient detail to identify yourself and your request. We will respond within the timeframe prescribed by applicable law.

We may communicate with you via email, telephone, or written correspondence for purposes including responding to enquiries, sharing updates relevant to our business relationship, and sending regulatory or compliance-related notices.

If you no longer wish to receive marketing or business development communications from us, you may opt out at any time by writing to compliance@earthre.in or by using the unsubscribe mechanism in our emails. Please note that transactional, regulatory, and compliance communications cannot be opted out of while a business relationship subsists.

To the fullest extent permitted by applicable law, EarthRe shall not be liable for any indirect, incidental, or consequential loss or damage arising from:

• Unauthorised access to or use of our servers or personal data stored therein, beyond our reasonable control
• Interruptions or errors in the operation of our website
• Reliance on information published on our website, which is provided for general informational purposes only

Nothing in this policy limits our liability for gross negligence, wilful misconduct, or any liability that cannot be excluded by law.

As a reinsurer with global cedants, retrocessionaires, and service providers, personal data may be transferred to and processed in jurisdictions outside India. Where such transfers occur, we take appropriate safeguards to ensure that personal data receives a standard of protection consistent with this policy and applicable Indian data protection law.

EarthRe operates from IFSC, GIFT City, which is subject to a distinct regulatory framework under IFSCA. Our data practices comply with applicable IFSCA guidelines and relevant provisions of the DPDP Act, 2023.

Severability: If any provision of this Privacy Policy is found to be invalid or unenforceable, the remaining provisions shall continue in full force and effect.

Governing law: This Privacy Policy is governed by the laws of India. Any disputes arising in connection with this policy shall be subject to the exclusive jurisdiction of the courts at Ahmedabad, Gujarat.

Amendments: We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. Material changes will be notified by updating the effective date at the top of this page. Continued use of our website or services after such changes constitutes acceptance of the updated policy.

This Privacy Policy is reviewed at least annually by EarthRe’s Board of Directors. Material modifications require approval by the Compliance Officer and, where required by applicable regulation, ratification by the Board. Changes required by amendments to applicable law or IFSCA regulations are incorporated automatically and take effect from the date such law or regulation comes into force.

Effective date of current version: 1 December 2025

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact:

Compliance Officer EarthRe Insurance IFSC Limited Unit No 47, The Platform, 11T2, Block 11, TS2, Sangath, Ground Floor, Block 11, Road 1A, Zone 1, GIFT SEZPA, GIFT City, Gandhinagar, Gujarat, India CIN: U65020GJ2025PLC170845 Email: compliance@earthre.in