Worldwide: Global Corporate Insurance & Regulatory Bulletin

Last Updated: 19 March 2013
Edited by Martin Mankabady , Lawrence R. Hamilton and David W. Alberts

Europe - Solvency II update

TIMING

It was announced on 20 February 2013 that the European Parliament will not consider Omnibus II until its 21-24 October 2013 plenary session. This represents a delay of four months from the previously announced date (10-13 June 2013) and will inevitably result in yet further delay to the implementation of Solvency II.

EIOPA PLANS

The European Insurance and Occupational Pensions Authority ("EIOPA") has announced a plan to bring in Solvency II interim measures from 1 January 2014. These will take the form of guidelines covering the system of governance (including risk management and the process of developing an own risk and solvency assessment), pre-application of internal models and reporting to supervisors.

These guidelines are not intended to anticipate Solvency II but instead to prepare supervisors and undertakings for the new regime in a consistent way. The guidelines will be addressed to national supervisory authorities and will be subject to the "comply or explain" procedure.

EIOPA has said that it plans to hold a public consultation on the proposed guidelines in April/May 2013 and that the guidelines will then be tabled to the EIOPA Board of Supervisors in autumn 2013.

EIOPA has also stated an intention to develop a supervisory handbook that would work as a guidebook for supervision in Solvency II, setting out good practices in all the relevant areas. This handbook is intended to assist in the implementation of a more consistent framework for the conduct of supervision.

UK - Lloyd's publishes Solvency II guidance notes

Lloyd's has published guidance notes on Solvency II in order to provide managing agents with as much clarity and certainty as possible in order to assist in planning. Although Solvency II is still scheduled to enter into force on 1 January 2014, Lloyd's plans are based on an assumption of a 1 January 2016 implementation date - the guidance notes make clear that this assumption is subject to change as further clarification emerges from the EU.

The guidance notes provide information on Lloyd's approach to completing its Solvency II review work, an overview of Lloyd's 2013 Solvency II timetable, and the impact of the Solvency II delay.

Two areas that Lloyd's is said to be monitoring are: (i) the proposal by the European Insurance and Occupational Pensions Authority to introduce Solvency II interim measures from 1 January 2014; and (ii) the FSA's proposed ICAS+ approach (i.e. using Solvency II work to meet ICAS requirements) for capital requirements.

Neither of these is expected to have a significant impact on Lloyd's or its agents. Regarding interim Solvency II measures, Lloyd's considers that the progress that has already been made towards implementing Solvency II and the plans that have been made for transitioning to Solvency II as business as usual should prevent any significant impact. Regarding ICAS+, Lloyd's considers that this is largely consistent with the approach that Lloyd's has already introduced for setting capital from 2013 onwards; Lloyd's agents successfully used Solvency II internal models to meet ICAS requirements during 2012 and to set capital for the 2013 year of account, and Lloyd's intends to continue to use this approach.

UK - FSA comments on the resolution framework for insurers

On 12 February 2013, the FSA Director of Insurance, Julian Adams, gave a speech on the lessons for insurance supervisors from the financial crisis, in which he commented on the resolution framework for insurers.

One of the key issues discussed was the challenge of reconciling the need to maintain the provision of insurance (in order to protect policyholders and avoid disruption to economic activity) with allowing insurers to fail. The FSA wants insurers to be able to exit the market in an orderly fashion which provides continuity of access to critical services. To address this challenge, the FSA needs to have confidence that no insurer is too big, too complex or too interconnected to fail.

It was noted that, although the current system whereby failing insurance firms go into run-off (possibly combined with a scheme of arrangement) has generally proven adequate for dealing with general insurance companies, the FSA has no experience of large failures, particularly with regard to life insurance groups.

The FSA considers that continuity of cover could be at risk in the event of an insurer insolvency. Particular concerns are: (i) run-off involves a trans-generational risk for policyholders whose contracts mature later; (ii) schemes of arrangement are complex and court led processes and Part VII transfers are dependent on the existence of a third party purchaser; and (iii) the value of a firm is significantly destroyed as it descends towards insolvency, leaving less for policyholders and possibly meaning the overall net cost cannot be absorbed by the Financial Services Compensation Scheme ("FSCS").

At a domestic level, the FSA is exploring ways to improve the FSCS's operations and to ensure insolvency arrangements allow the best chance of continuity for the most critical policies.

At an international level, the Financial Stability Board ("FSB") has set out minimum standards that should apply to any financial institution that could be systemically significant or critical if it fails. In addition, the chair of the FSB's group on resolving large and complex financial firms is setting up a workshop on insurance resolution. An assessment will then be made of whether a special resolution regime may be needed for insurers and, if so, what characteristics it would require.

UK - Update on the PRA's role as insurance regulator

On 6 February 2013, the FSA Managing Director of the Prudential Business Unit, Andrew Bailey, gave a speech in which he commented on: (i) why the Prudential Regulation Authority ("PRA") will be supervising insurers alongside banks and major investment firms; (ii) the style of supervision the PRA will adopt; and (iii) the issue of systemic risk for insurers.

The reason for locating insurers in the PRA along with banks is said to be that the role of the prudential supervisor is to ensure that the public and users of financial services, including the corporate sector, can be assured of continuous access to the critical services on which they depend.

In terms of the style of supervision the PRA will adopt, the following key points were made:

  • The PRA will be applying judgment around the framework of rules, in order to be focused on the key risks that matter to its objectives. In particular, it will focus on the big risks that threaten the objectives of safety and soundness and policyholder protection.
  • The PRA will be forward-looking to the risks that may arise, e.g. it is focused on the impact of continuing low interest rates, it is considering the prudential impact of possible outcomes on flood insurance in the UK, etc.
  • The PRA faces the challenge of balancing the use of sensible judgment against the risk of creating undue uncertainty which damages the ability of insurers to do business; it was noted that this will require a greater degree of transparency between: (i) the PRA and firms; and (ii) the PRA and firms on one hand and the public and investors on the other.
  • The PRA will be clear and transparent in its judgments and it will be accountable.
  • The PRA will take the supervision of insurers just as seriously as it takes the supervision of banks. It is putting more emphasis on senior level contact in the new approach in order to deliver key messages clearly to senior management and boards and to understand how firms' governance works in practice.

Regarding the issue of systemic risk for insurers, it was acknowledged that some insurers will pose more risks to the financial system than others, as a result of the interaction of complexity of risk and size, and it was said that supervision should be proportional, with a more enhanced and intensive approach for large and complex firms. A distinction was also drawn between non-life insurance, where the resolution challenge involves ensuring short-term continuity of risk cover, and life insurance, which involves long-term commitments and a greater vulnerability to shocks from the financial markets.

It was, however, said that it does not follow that, just because major banks are systemically important, the same must be true for insurers. Furthermore, if a case can be made for systemic importance of insurers, it does not follow that the same capital treatment of systemic firms and/or a statutory resolution regime are needed as for banks. Any response to perceived systemic risk should be consistent with mitigating the cause of such risk, and work is underway to determine whether insurance would benefit from a special resolution regime that overrides normal insolvency rules in order to enhance the ability to ensure continuity of cover. Although it was considered that the PRA's objective of policyholder protection suggests there is a need for some sort of resolution regime for insurers, it was said that it is important to be clear on what sort of regime would be appropriate.

Following this speech, on 13 February 2013, the FSA sent a letter to firms that will have the PRA as their lead supervisor, setting out detailed information on how firms should prepare for legal cutover to the PRA on 1 April 2013 and including updated FAQs on the transition to the PRA.

The letter notes that, as the PRA will have a different regulatory and supervisory approach to the FSA, existing individual guidance issued by the FSA will not automatically be transitioned to the PRA. Four categories of guidance will be automatically transitioned: (i) individual capital requirements guidance; (ii) individual liquidity guidance; (iii) individual guidance given by the FSA that enables a firm to move from a higher proportionality tier to a lower proportionality tier; and (iv) guidance on the completion and submission of regulatory returns. Other guidance should be reviewed by firms against the PRA's statutory objectives. Any guidance that firms wish the PRA to review (which should not include all guidance previously issued) should be submitted to the PRA by 30 September 2013 and can then be relied upon until the PRA decides whether it remains appropriate or not. Any guidance not referred to the PRA for review will cease to have any status as formal individual guidance from 30 September 2013. The letter notes that this does not mean that firms should necessarily change their behaviour and that this does not change recent risk assessments.

The letter also indicates that the PRA handbook, which will replace the relevant parts of the existing FSA handbook, is expected to be published in March 2013. Following legal cutover, the PRA will amend its own policy materials as an independent body in line with the processes laid down in the Financial Services Act 2012, which will include co-operation with the Financial Conduct Authority and external consultation.

UK - HMRC publishes interim guidance on new corporate tax regime for life insurers

On 14 February 2013, HMRC published interim guidance on the new corporate tax regime for life insurance companies, which commenced on 1 January 2013. The interim guidance relates to:

  • the operation of the rules for allocation of income, gains and profits and losses under the new regime (see here);
  • the operation of the rules for the tax treatment of transfers of long-term business under the new regime (see here); and
  • the interaction of the new regime with the controlled foreign companies legislation (see here).

The interim guidance focuses on key aspects of the new regime and will be replaced by comprehensive guidance on the entirety of the new regime in due course.

Global - IAIS launches self-assessment and peer review on corporate and risk governance

The International Association of Insurance Supervisors ("IAIS") has launched a self-assessment and peer review ("SAPR") on corporate and risk governance, which will assess observance and understanding of the Insurance Core Principles ("ICPs") related to licensing, suitability of persons, corporate governance, and risk management and internal controls (ICPs 4, 5, 7 and 8).

Although not a traditional self-assessment, IAIS members are encouraged to participate in the SAPR. The process will begin with an online survey prepared by an expert team consisting of representatives from the Standards Observance Subcommittee, the Governance and Compliance Subcommittee and the World Bank. Once the four week survey period is closed, the expert team will review the results and produce a draft report setting out a preliminary assessment, which will be circulated to each member who participates in the SAPR.

Members will then be invited to provide comments on and make corrections to the draft report. These will be considered by the expert team, which will then issue a final report to each jurisdiction, following which an aggregate report of the expert team's findings will be prepared.

The SAPR is expected to be completed by the first quarter of 2014.

Global - IAIS publishes comments on consultation on policy measures for global systemically important insurers

On 11 February 2013, the International Association of Insurance Supervisors ("IAIS") published a compilation of the comments it has received on its October 2012 consultation on proposed policy measures for global systemically important insurers ("G-SIIs"). It has published comments organised by responding entity and comments organised by consultation question.

Respondents to the consultation included regulators and other interested parties from Europe, America and Asia, including the Association of British Insurers, the European Commission, the European Insurance and Occupational Pensions Authority, the Institute of International Finance, Insurance Europe, the National Association of Insurance Commissioners and the US Chamber of Commerce.

The IAIS intends to publish the final policy measures in the first half of 2013, along with a list of the first cohort of G-SIIs.

US - New York Department of Financial Services reissues emergency regulations on Superstorm Sandy claims

On 26 February 2013, the New York State Department of Financial Services ("DFS") reissued the emergency regulations originally issued on 29 November 2012 to address the handling of claims relating to losses from Superstorm Sandy. While acknowledging that 94% of the claims relating to residential property policies have been fully resolved, the DFS asserted that "[i]nsurers insuring property in affected areas have not always begun investigating claims, including by deploying insurance adjusters to adjust claims, in a prompt manner...and many claims...are still pending with insurers." Additionally, on 21 February 2013, New York Governor Andrew Cuomo and Superintendent of Financial Services Benjamin Lawsky announced that the DFS was investigating three insurers over their handling of Superstorm Sandy claims. The fact that the DFS apparently did not discuss its concerns with the three insurers before a formal investigation was publicly announced suggests a prosecutorial approach to the industry that commentators have attributed to Superintendent Lawsky's background as a former prosecutor.

The emergency regulations amend Insurance Regulation 64, New York's Unfair Claims Settlement Practices and Claim Cost Control Measures Regulation, to require insurers to do the following with respect to Superstorm Sandy claims:

  • Commence investigations within six business days of receiving notice of a claim (instead of within 15 business days - the usual time period for non-Sandy claims). If the insurer wishes to inspect the damaged or destroyed property, the inspection must occur within the six business day period.
  • Furnish to every claimant or its authorized agent a written notification detailing all items, statements and forms, if any, that the insurer reasonably believes will be required of the claimant, within six business days of receiving notice of the claim (instead of within 15 business days - the usual time period for non-Sandy claims).
  • Notify the claimant in writing if the insurer needs more time to determine whether the claim should be accepted or rejected within 15 business days after receipt of proof of loss or requested information. The notification must include the reasons additional time is needed and the anticipated date a determination on the claim will be made.
  • If the claim remains unsettled, unless the matter is in litigation or arbitration, the insurer shall, 30 days from the date of the initial notification, and every 30 days thereafter, send to the claimant or its authorized agent a letter setting forth the reasons additional time is needed for investigation and the anticipated date a determination on the claim will be made.

If the insurer fails to notify the claimant in writing of the insurer's acceptance or rejection of the claim within 15 days, the insurer is required to submit a weekly report to the DFS specifying the following:

  • the date the loss was alleged to have occurred;
  • the date the claim was filed with the insurer;
  • the date a properly executed proof of loss and receipt of all items, statements and forms required by the insurer were received by the insurer;
  • the alleged estimated amount of the loss;
  • the reason given for the extension;
  • the anticipated date a determination will be made on the claim provided to the claimant;
  • how many extensions have been requested on that claim; and
  • the ZIP code where the loss occurred.

Brazil - Privatization of Latin America's major reinsurer

Over the past few months, IRB-Brasil Resseguros S.A. ("IRB") has once again been in the spotlight of the insurance market, this time because the state-controlled company, created in 1939 with the strategic role of being the sole reinsurer authorized to underwrite reinsurance in Brazil, is finally to be privatized.

Although the privatization of the largest reinsurance company in Latin America is worthy of our attention, this news was not a great surprise to the market as there has been pressure for IRB's privatization since 1998.

At the end of the 1990s, when Brazil was going through a wave of privatizations, the President of the time, Fernando Henrique Cardoso, attempted to privatize IRB but was ultimately unsuccessful for several reasons, including: (i) a lawsuit filed with the Brazilian Supreme Court to frustrate the privatization of IRB; and (ii) a failure to pass the legislation required to end IRB's reinsurance monopoly.

The first step in recommencing the privatization process for IRB was taken in January 2007, when Complementary Law 126/2007 was enacted, which brought significant changes to the Brazilian insurance framework and has affected the entire sector since that date.

Among the main changes brought in by the new regulation were: (i) the end of the reinsurance monopoly, with the opening of the market to other accredited players, including foreign companies; and (ii) the transfer of the regulatory authority for the reinsurance market from IRB to the Brazilian Superintendence of Private Insurance (Superintendancia de Seguros Privados - "SUSEP"), which oversees, regulates and licenses the Brazilian reinsurance market.

As a direct effect of opening the market to other reinsurers, fifteen years after the previous attempts the Brazilian market will finally see the privatization of IRB. A bid invitation containing key information was published on 23 January 2013, which established that the process will be conducted by the Brazilian Development Bank (Banco Nacional de Desenvolvimento Econamico e Social).

According to the bid invitation, the privatization will occur by means of an increase of up to 15% in the corporate capital of IRB by the issue of new common shares which cannot be purchased by the Brazilian Federal Government. The price for each share has been set at BRL 2,577.001. Current private preferred shareholders, which are almost entirely local insurance companies due to a requirement imposed by the old regulation, will have preferred rights to subscribe for the new common shares.

The bid invitation indicates that all preferred shares will be converted into common shares, and a new type of shares called "Golden Shares" will be issued to the Government. The Golden Shares will have specific veto powers in relation to the following matters:

  • change of IRB's corporate name or purpose;
  • transfer of corporate control;
  • changes to IRB's trademark;
  • definition of underwriting and retrocession general policies;
  • corporate transactions such as mergers, transformations, amalgamations, spin-offs, etc. that might result in a loss of rights for the Golden Shares; and
  • any changes to the Golden Shares' rights.

Notwithstanding the above, the bid invitation also states that 50,000 shares currently owned by the Government will be offered to IRB's employees at a price of BRL 2,319.30, which is 10% less than the subscription price for the new shares mentioned above. The remaining shares belonging to the Government are to be transferred to BB Seguros Participasaµes S.A., the insurance arm of Banco de Brasil, a financial institution which is also owned by the Government.

A condition for the privatization is that the new controlling group must commit to making its best efforts to achieve an initial public offering of IRB's stock within five years of the privatization.

Such conditions demonstrate the Government's desire to make IRB more competitive. Although IRB remains the largest reinsurer in Brazil2 six years after the opening of the market, during which 11 players have enrolled with the same status as local reinsurers, the Brazilian Government believes that the entire market will benefit and grow as a result of the privatization of IRB, which will result in an increase in retention capacity and a decrease in insurance and reinsurance prices.

Footnotes

1 Currently, the corporate capital of IRB is BRL 1,350 billion, divided into 500,000 common shares and 500,000 preferred shares. The Brazilian Federal Government owns all the common shares.

2 According to SUSEP's statistics, IRB has collected approximately BRL 1.7 billion in reinsurance premium in the past year, far much than the second major local authorized reinsurer Munich Re, which has collected approximately BRL 363 million in premium.

Previously published in February 2013.

Visit us at mayerbrown.com

Mayer Brown is a global legal services provider comprising legal practices that are separate entities (the "Mayer Brown Practices"). The Mayer Brown Practices are: Mayer Brown LLP and Mayer Brown Europe – Brussels LLP, both limited liability partnerships established in Illinois USA; Mayer Brown International LLP, a limited liability partnership incorporated in England and Wales (authorized and regulated by the Solicitors Regulation Authority and registered in England and Wales number OC 303359); Mayer Brown, a SELAS established in France; Mayer Brown JSM, a Hong Kong partnership and its associated entities in Asia; and Tauil & Chequer Advogados, a Brazilian law partnership with which Mayer Brown is associated. "Mayer Brown" and the Mayer Brown logo are the trademarks of the Mayer Brown Practices in their respective jurisdictions.

© Copyright 2013. The Mayer Brown Practices. All rights reserved.

This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

 
In association with
Up-coming Events Search
Tools
Print
Font Size:
Translation
Channels
Mondaq on Twitter
 
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
 
Email Address
Company Name
Password
Confirm Password
Position
Mondaq Topics -- Select your Interests
 Accounting
 Anti-trust
 Commercial
 Compliance
 Consumer
 Criminal
 Employment
 Energy
 Environment
 Family
 Finance
 Government
 Healthcare
 Immigration
 Insolvency
 Insurance
 International
 IP
 Law Performance
 Law Practice
 Litigation
 Media & IT
 Privacy
 Real Estate
 Strategy
 Tax
 Technology
 Transport
 Wealth Mgt
Regions
Africa
Asia
Asia Pacific
Australasia
Canada
Caribbean
Europe
European Union
Latin America
Middle East
U.K.
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement

Mondaq.com (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of www.mondaq.com

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about Mondaq.com’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.

Disclaimer

Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.

Registration

Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.

Cookies

A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

Links

This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.

Mail-A-Friend

If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.

Security

This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at enquiries@mondaq.com.

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.