Declaration
By submitting this application I declare that all statements and particulars contained in this Proposal are true. I have made a fair presentation of the risk, by disclosing these material facts which I know or ought to know or, failing that, that I have given Paragon sufficient information to put a prudent insurer on notice that it needs to make further enquiries in order to reveal material circumstances. I undertake to inform Paragon before any contract of insurance is concluded, if there is any material change to the information already provided or any new fact or matter arises which may be relevant to the consideration of my proposal for insurance. I understand that a failure to ensure that the statements and particulars contained in this Proposal are true or a failure to disclose any material facts which would be likely to influence the acceptance and assessment of the Proposal may adversely affect the availability of coverage under the policy or may result in the voiding of the policy in every respect. By signing this document, I authorise Paragon to release information to SEMPRIS and/or any relevant third parties and give permission to Paragon to use my email address, as provided in Section 1, to send their quotations or correspondence.
Initial Disclosure Document (IDD)
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Paragon International Insurance Brokers Ltd (Paragon) who is authorised and regulated by the Financial Conduct Authority (FCA), FRN: 310157.
Registered in England & Wales, company number: 03215272. Registered address: 140 Leadenhall Street, London, EC3V 4QT.
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Please Use the information in this document to decide if Paragon’s services are right for You.
- Definitions
1.1 ‘You’ or ‘Your’ means You, the Client.
1.2 ‘We’ or ‘Us’ or ‘Our’ means Paragon.
- Who regulates Us?
2.1 Paragon is authorised and regulated by the FCA, which is the independent body that regulates financial services in the UK.
2.2 To comply with FCA’s requirements regarding systems, disclosure and management control Paragon has prepared this Initial Disclosure Document (IDD).
2.3 It is possible to check information given in this document by visiting the FCA’s Website http://www.fca.gov.uk/register or by contacting the FCA on (44) 0845 606 1234 or by writing to them at 12 Endeavour Square, London, E20 1JN, UK.
- Ownership and control
3.1 Paragon is a Lloyd’s accredited broker, part of a global independent platform and is based in London.
3.2 Paragon uses insurance markets based in the UK, Europe, Bermuda and North America. Paragon can offer a range of insurance products from insurers based in these countries.
3.3 Paragon is not tied to, or acts as agent of, any insurer except in the collection of monies and the holding of documents involving certain insurers.
3.4 Paragon does not own any shares in any insurance company anywhere in the world or in any Lloyd’s entity.
- Paragon
4.1 Paragon is a trading name of Paragon International Insurance Brokers Ltd.
4.2 Paragon has been established by Paragon to develop a specialised insurance product exclusively for its members.
4.3 Notwithstanding clauses 3.3 and 3.4, Paragon only obtains quotes from one selection of insurers under a Binding Authority (A facility granted to Paragon by certain insurer(s) whereby Paragon can quote and bind insurance cover and issue certificates of insurance on behalf of the insurer(s)).
4.4 All quotes given by Paragon under the facility are under a Binding Authority and as a consequence Paragon will be acting as agent of insurers and not the insured.
- Bribery and Corruption
5.1 Paragon conducts its business in an honest and ethical manner, and it has adopted a zero-tolerance to bribery and corruption.
- Paragon’ Responsibilities
6.1 Paragon will endeavour to provide You with full written terms & conditions for insurance as authorised by the insurer under the Binding Authority granted to Paragon. Paragon will keep You fully informed on a regular basis of its progress or otherwise.
6.2 Unless we have agreed in writing to undertake a full review of all your insurance requirements and existing policies, our responsibility to you will be limited to the insurance policy(ies) we procure on your behalf.
6.3 On receipt of an order to bind cover Paragon will issue You with a certificate of insurance (which may be in electronic form) which will be the formal and binding document evidencing cover on behalf of the insurer. In addition
6.3.1 Paragon will issue a debit note (which may be in electronic form) for the payment of the premium.
6.3.2 Paragon will consider amendments to the cover when requested during the period of insurance.
6.4 Notwithstanding clause 4.4, Paragon will act on behalf of insureds when negotiating and settling claims. Paragon has established a Medico-Legal helpline and will advise insurers when it becomes aware of circumstances and when claims become known to it.
- Data Protection
7.1 Paragon strives to protect the privacy and the confidentiality of personal data that it processes in connection with the services it provides.
7.2 Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controllers’ possession or likely to come into such possession.
7.3 The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the ‘GDPR’).
7.4 Paragon’s services consist of insurance mediation activities - introducing, proposing or carrying out other work preparatory to the conclusion of contracts of insurance, and concluding such contracts, assisting in the administration and performance of such contracts. In order to provide such services Paragon is required to process personal data. Paragon acts as a data controller in respect of the personal data it receives in connection with the services it provides. This means that We decide how Your personal data is processed, and for what purposes as described herein.
7.5 Insurance is the pooling and sharing of risk in order to provide protection against a possible eventuality. In order to do this, information, including Your personal data, needs to be shared between different insurance market participants.
7.6 In order to facilitate the provision of insurance cover and administer insurance claims as described in 6.4, Paragon relies on a number of legal grounds under the GDPR, primarily contractual necessity, legitimate interests and compliance with legal obligations.
7.7 Unless subject to an exemption under the GDPR, You have the following rights with respect to Your personal data:
- to request a copy of Your personal data which Paragon holds about You;
- to request that Paragon corrects any of Your personal data if it is found to be inaccurate or out of date;
- to request Your personal data to be erased where it is no longer necessary for Paragon to retain such data;
- to object where permissible to the processing of Your personal data at any time;
- to request that Paragon provides You with Your personal data, and where possible, to transmit the data directly to another data controller (known as the right to data portability);
- where there is a dispute in relation to the accuracy or processing of Your personal data, to request a restriction is placed on further processing;
- to object to the processing of Your personal data by automated individual decision-making and profiling;
- to lodge a complaint with the Information Commissioner’s Office (ICO).
7.8 We will keep Your personal data securely for a maximum of 10 years, after which time it will be destroyed securely if it is no longer needed for the lawful purposes for which it was obtained. In some limited cases, it may be necessary to retain Your personal data for longer if We need to hold it for liability claim purposes. If You consent to receiving marketing from Us, any information We Use for this purpose will be held by Us until such time as You notify Us that You no longer wish to receive marketing information from Us.
7.9 Further to 8.5, the insurance market is committed to safeguarding that information. Below is a link to the London Insurance Market Core Uses Information Notice which is designed to help You understand the complexities of the insurance market and how various insurance market participants may process Your personal data in respect of core activities that take place throughout the insurance lifecycle.
http://www.lmalloyds.com/LMA/News/Releases/PR_2017/data_protection_05Dec.aspx
7.10 To exercise all relevant rights, or to raise queries or complaints, please in the first instance contact Paragon’s Data Protection Officer at:
Email: compliance@paragonbrokers.com
Address: Paragon International Insurance Brokers Ltd, FAO: The Data Protection Officer, 140 Leadenhall Street, London, EC3V 4QT
7.11 Please ensure that You review Our updated Privacy Policy which can be found on Our Website at:
https://www.paragonbrokers.com/wp-content/uploads/2018/05/Paragon-Privacy-Notice.pdf
- Financial Services Compensation Scheme (FSCS)
8.1 Certain Clients may be entitled to compensation from the FSCS. This depends on the type of business and the circumstances of the claim. Full information can be obtained from the FSCS Website which is www.fscs.org.uk or the FCA.
- Financial Crime
9.1 UK money laundering regulations requires Paragon to obtain information about You before it can act.
9.2 As part of Paragon’ due diligence checks and information gathering process Paragon will carry out sanctions and financial checks including but not limited to the HM Treasury Financial Sanctions List in line with its internal procedures.
- Insurer Security
10.1 Paragon only uses insurers that have been rated A- or higher by A.M Best or have been rated A- or higher by Standard & Poor’s. Paragon never acts as an insurer.
10.2 Paragon does not guarantee the solvency of any insurer it places business with, or the ability of an insurer to meet policyholder obligations. As a result, final decisions on insurer suitability must rest with You.
- Your Responsibilities
11.1 You are responsible for making, after reasonable search, a Fair Presentation in a clear and accessible manner of all important and relevant information, at least sufficient to put a prudent insurer on notice to make enquiries, and not to make any misrepresentations as required by the Insurance Act 2015.
11.1.1 Please contact Paragon’s Compliance Officer if You wish to discuss this important requirement.
11.1.2 A Fair Presentation is required in order for a reasonable insurer to decide whether to provide insurance or not and, if so, the terms and conditions of such insurance.
11.1.3 The use of an application or proposal form supplied by insurers or Paragon does not relieve or reduce Your responsibility to make a Fair Presentation of important and relevant information in a clear and accurate manner.
11.1.4 If You do not make a Fair Presentation then insurers may be able to void the policy and provide no coverage with no return of premium or amend the terms of the insurance placement to exclude coverage under the placement or reduce the amount of claims to be paid or require You to pay some additional premium.
11.1.5 Your obligation to keep information up to date is on-going therefore We ask that You advise Us as soon as possible of any changes in respect of any of the information You provided so We can pass such changes onto insurers for their acceptance or otherwise.
11.2 You are responsible for checking that all documentation received by You from the insurers clearly reflects the insurance coverage You require. Particular attention should be made to the limits, terms & conditions, any warranties and when and how to advise claims or potential claims to insurers. Also, attention should be given to any condition that requires You to undertake specified actions by a date.
11.3 You are responsible for paying the correct amount of premium and any tax by the due date especially if there is a warranty and Paragon will not be responsible for any consequence of such a failure. Paragon will not be able to pay the market unless it receives the correct amount.
11.4 The procedure for advising insurers of circumstances and claims are shown in the insurance documents issued by Paragon and it is Your duty to be fully aware of them. When requested, Paragon can assist with the notification of claims and circumstances to insurers.
11.5 You must ensure that payments are made to the bank account as advised by Paragon.
11.6 All sums will be held by Paragon in a Non-Statutory Trust bank account until payment is due to insurers, or clients if return of premium or claims monies, and any interest earned from monies held on account will be payable to Paragon.
11.7 Paragon may drawdown its commission before paying the premium to insurers.
11.8 Paragon acts as the agent of insurers in the collection and holding of insurance premiums and claims monies.
11.9 If You have any doubt about Your responsibilities under any insurance arranged by Paragon please immediately contact Our Compliance Officer who will be pleased to assist.
- Paragon’s Remuneration
12.1 Paragon’s remuneration will be commission payable by insurers which is a percentage of the premium paid by You.
12.2 You are entitled to know details of the commission paid to Paragon which is applicable to Your premium.
12.3 Paragon’s commission is fully earned as at the inception date of insurance placements.
12.4 Paragon may receive profit commission from insurers in the event there is an overall profit to insurers from all the business bound under the Binding Authority as described in clause 4.3.
- Payments to Paragon
13.1 Paragon never accepts payments for premium or its services in cash. Paragon will accept transfers of monies from, or cheques with accounts with, reputable and internationally known banks, and by private/personal credit cards.
13.2 If You Use a premium finance company to pay Your premium this must be advised to Paragon as Paragon is not able to accept payment other than from the insured, unless previously agreed and documented by You and Paragon.
13.3 Paragon will act as an introducer (not a broker or a lender) if You choose to pay for Your insurance premium Using Our approved instalment provider, Premium Credit Limited (PCL) of Ermyn House, Ermyn Way, Leatherhead, Surrey, KT22 8UX.
13.3.1 Paragon only deals with PCL therefore does not represent a fair analysis of the market. Furthermore, We will provide You with information about this payment option on a non-advised basis – i.e. We are not providing You with advice as to the suitability of the premium finance product and You will need to make Your own decision about whether to proceed. It is Your responsibility to ensure You take the time to read any documentation sent by PCL to ensure it meets Your needs and financial circumstances.
13.3.2 If You have any queries or questions either about the service provided by PCL or the terms and conditions, You should in the first instance be directed to them; PCL can be contacted on 0344 736 9836.
13.3.3 If You do elect to finance Your premium payments via PCL, Paragon may receive a payment in return for the work that it undertakes on behalf of PCL. We do not receive a commission for introducing customers to PCL.
- Complaints
14.1 Paragon aims to provide the highest standard of service to all their clients. If at any time You wish to make a complaint, either in writing or verbally, in connection with any matter concerning the services received, or not, from Paragon, or regarding any other business matter involving Paragon, You should address such matters to Paragon’s Compliance Officer:
- Email: complaints@paragonbrokers.com
- Post: Paragon International Insurance Brokers Ltd, FAO: Compliance Officer, 140 Leadenhall Street, London, EC3V 4QT, United Kingdom
- Tel: +44(0) 20 7280 8200
He/she will acknowledge the complaint within three working days and will immediately undertake an independent review and will write to You accordingly.
14.2 Paragon’s complaints procedure is compliant with the requirements of the FCA.
14.3 You have the right to refer complaints directly to Lloyd’s if Paragon has placed cover with any Lloyd’s syndicate; details of insurers will be shown in policy documents. Lloyd’s aim to resolve complaints within 8 Weeks which is in accordance with FCA rules. To make a complaint to Lloyd’s please write to: Lloyd’s, Fidentia House, Walter Burke Way, Chatham Maritime, Chatham, Kent, ME4 4RN. Alternatively You may contact them by telephone on +44(0) 20 7327 5693 or email complaints@lloyds.com.
14.4 If the complaint is not resolved You may be entitled to refer the matter to the Financial Ombudsman Service (FOS). The FOS is an independent service in the UK for settling disputes between policy holders and insurers. It is important to note that eligible complaints must be referred to the FOS within 6 months of the date of the Final Response Letter issued by Paragon or Lloyd’s. Full information can be obtained from their website which is www.fos.org.uk or the FCA.
- Liability
15.1 To the maximum extent permitted by applicable law, Paragon’s liability arising under or in connection with this Agreement in respect of any loss and/or damage shall never exceed £5,000,000.00 in any twelve-month period. Such twelve-month period will start to run from the date that You sign this agreement.
- Entire Agreement
16.1 This document, along with any addendums attached hereto, is the entire agreement between Paragon and You.
16.2 Any changes, amendments or additions are only valid when attached hereto and signed by the respective signatories hereon.
- Governing Law and Jurisdiction
17.1 This IDD shall be construed according to English law and any disputes arising under it shall be determined in the Law Courts of England and Wales.
