Released: October 31, 2014
PURPOSE FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
- Establishing and maintaining communications with you;
- Where you have requested a service from the Company, assisting you in the completion of your application, the assessment of your eligibility for any such requested service, the processing and maintenance of the service, as well as any applicable renewal of such service;
- Responding to your inquiries about applications, accounts and other services;
- Making proposals for future service needs;
- Allowing our affiliated companies to notify you of certain products or services offered by our affiliated companies;
- Processing transactions through service providers;
- Sharing with associations for those clients/participants obtaining insurance coverage by being a member of the association;
- Sharing with financial institutions and other organizations where we have joint marketing agreements;
- Meeting legal, security, processing and regulatory requirements;
- Protecting against fraud, suspicious or other illegal activities; and
- Compiling statistics for analysis of our sites and our business.
WHAT INFORMATION WE COLLECT
The information gathered by The Company from this Site falls into two categories: (1) information voluntarily supplied by visitors to our Site and (2) tracking information gathered as visitors navigate through our Site.
Information voluntarily provided by you
When using this Site, you may choose to provide us with information to help us serve your needs. The Personal Information that we collect will depend on how you choose to use this Site.
- Where you request a brochure or report
If you request a brochure or report or further information from us, we require you to submit your name, e-mail address, the name of your organization, and the country in which you are based so we may send you the material you have requested, and to enable us to identify if you are an existing client of The Company.
- Where you register with us
If you register with the Site, we may ask you for your name, e-mail address, country, telephone number and the reason for your communication, as well as information about your position and organization and such other information as is reasonably necessary so that we can provide you with the quote. On the data submission form, we shall indicate by way of an asterisk, which information is optional and which information is mandatory. This information can include:
Information you provide on applications or other forms, which may include your name, address, email address,;
Information about you received from Company affiliates, ; and
Information we receive from consumer reporting agencies.
- Where you submit content
Finally, if you submit content regarding any of the information that you view on our Site, we will ask for your name and e-mail address, so that, if you choose, we can update you by e-mail when others also comment on the content, and also so that we can manage the content in line. You should be aware that the information you provide there will be made publically available to The Company employees and other users of the Site.
Website Navigational Information
As you navigate the Site, we may also collect information through the use of commonly-used information-gathering tools, such as cookies and web beacons (collectively “Website Navigational Information”). Website Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Site (such as the web pages viewed and the links clicked).
There are different kinds of cookies with different functions:
(i) Session cookies: these are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.
(ii) Persistent cookies: a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
(iii) First-party cookies: the function of this type of cookie is to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between the Company’s servers and your computer’s hard drive. They are not used for anything other than for personalization as set by you. These cookies may be either Session or Persistent cookies.
(iv) Third-party cookies: the function of this type of cookie is to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the Third-party’s server and your computer’s hard drive. These cookies are usually Persistent cookies.
The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized, the Company’s Sites are not compatible with DNT.
For information on all of these categories of cookies, and for more information generally on cookies please refer to aboutcookies.org.
Where strictly necessary
These cookies are essential in order to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, services you have asked for, such as obtaining a quote or logging into your account, cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
These cookies collect information about how visitors use a Site, for instance which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to the Site, all of which enables us to see how visitors use the Site in order to improve the way that our Site works. These cookies do not collect information that identifies a person, as all information these cookies collect is anonymous and is used to improve how our Site works.
These cookies allow our Site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, a Site may be able to remember your log in details, so that you do not have to repeatedly sign in to your account when using a particular device to access our Site. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have requested such as viewing a video or commenting on an article. The information these cookies collect is usually anonymized. They do not gather any information about you that could be used for advertising or remember where you have been on the internet.
Please consult your web browser’s ‘Help’ documentation or visit aboutcookies.org for more information about how to turn cookies on and off for your browser.
- Web Beacons
The Site may also use web beacons (including web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of the Site and interaction with e-mails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Site tied to the web beacon, and a description of a Site tied to the web beacon. We use web beacons to operate and improve the Sites and e-mail communications. We may use information from web beacons in combination with other data we have about our clients to provide you with information about the Company and our services. We will conduct this review on an anonymous basis.
- IP Addresses
When you visit our Sites, the Company collects your Internet Protocol (“IP”) addresses to track and aggregate non-Personal Information. For example, the Company uses IP addresses to monitor the regions from which users navigate the Sites. IP addresses will be stored in such a way so that you cannot be identified from the IP address.
DISCLOSURE OF INFORMATION TO OTHERS
Third parties to whom we disclose information are required by law and contractual undertakings to keep your Personal Information confidential and secure, and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances, in compliance with all applicable legislation, which purposes are as follows:
- To assess eligibility for coverage, process and maintain insurance coverage, renewal of coverage or related products and services—we disclose to the insurance companies, reinsurers, intermediaries or other brokers that make available the coverage;
- To associations for those Clients/Participants obtaining insurance coverage by being a member of the association;
- To notify you or allow our affiliated companies to notify you of certain products or services offered by our affiliated companies;
- For legal, claims settlement and valuation services;
- To update information with credit bureaus and insurance reporting agencies;
- To process transactions through data processing service providers;
- If the information is a credit card number, to process credit card payments—through third party payment processing, clearing and settlement systems in association with various banks; and
- To other financial institutions with whom we have joint marketing agreements.
If these third parties wish to use your Personal Information for any other purpose, they will have a legal obligation to notify you of this and, where required, to obtain your consent. Contact us at http://www.brinknews.com/contact/ for more information on these third parties.
In the normal course of performing services for our clients, Personal Information may be shared within the Company and its affiliates for research and statistical purposes, system administration and crime prevention or detection. This may require Personal Information to be accessed or moved to a country different from the one where the Personal Information was collected. When you supply us with information containing third party Personal Information (names, addresses, or other information relating to living individuals), we will hold and use that Personal Information to perform general insurance and other services for you on the understanding that the individuals to whom the Personal Information relates have been informed of the reason(s) for obtaining the Personal Information, the fact that it may be disclosed to third parties such as the Company, and have consented to such disclosure and use.
Because a number of the service providers we use are located in the United States, including certain Company affiliates, your Personal Information may be processed and stored inside the United States, and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under US laws.
However, we shall take measure to adequately protect your Personal Information regardless of where it is processed or stored.
As we continue to develop our business, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. Also, if either the Company itself or substantially all of the Company assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third party purchaser in these circumstances
Other Legally Required Disclosures
The Company preserves the right to disclose without your prior permission any Personal Information about you or your use of this Site if the Company has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of the Company, employees, other users of this Site, or the public; (b) enforce the terms and conditions that apply to use of this Site; (c) as required by a legally valid request from a competent governmental authority; or (d) respond to claims that any content violates the rights of third-parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental request
CALIFORNIA’S “SHINE THE LIGHT” LAW
California Civil Code Section 1798.83 requires any operator of a website to permit its California-resident customers to request and obtain from the operator a list of what personal information the operator disclosed to third parties for direct marketing purposes, for the preceding calendar year; and the addresses and names of such third parties. The Company does not share any personal information collected from this site with third parties for their direct marketing purposes.
Your knowledge of and consent to the Company’s collection, use and disclosure of your Personal Information is critical. We rely on the following actions by you as indications of your consent to our existing and future Personal Information practices:
- Your voluntary provision of Personal Information to us directly or through another insurance broker or representative or your employer for the purpose of acquiring an insurance contract or related service or product (including information previously provided to the Company);
- Your express consent or acknowledgement contained within a written, verbal or electronic application or claims process; and
- Your verbal consent solicited by the Company (or our agent) for a specified purpose.
Where the Company relies on consent for the fair and lawful processing of Personal Information, the opportunity to consent will be provided when the Personal Information in question is collected. Your consent may be given through your authorized representative such as a legal guardian, agent or holder of a power of attorney.
Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw this consent at any time. the Company will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain Personal Information or withdrawing consent for Company to collect, use or disclose your Personal Information could mean that we cannot obtain insurance coverage or other requested products, services or information for you.
If you wish to withdraw your consent please refer to the Questions or to Withdraw Consent section below.
However, there are a number of instances where the Company does not require your consent to engage in the processing or disclosure of Personal Information. The Company may not solicit your consent for the processing or transfer of Personal information for those purposes which have a statutory basis, such as:
- The transfer or processing is necessary for the performance of a contract between you and the Company (or one of its affiliates);
- The transfer or processing is necessary for the performance of a contract, concluded in your interest, between the Company (or one of its affiliates) and a third party;
- The transfer or processing is necessary, or legally required, on important public interest grounds, for the establishment, exercise, or defense of legal claims, or to protect your vital interests; or
- The transfer or processing is required by applicable law.
LIMITING COLLECTION AND RETENTION OF PERSONAL INFORMATION
The Company will collect, use, or disclose Personal Information that is necessary for the Identified Purposes or as permitted by law. If we require Personal Information for any other purpose, you will be notified of the new purpose, and subject to your consent (where appropriate), that new purpose will become an Identified Purpose.
The Company will collect Personal Information by fair and lawful means. We will normally retain Personal Information as long as necessary for the fulfillment of the Identified Purposes. However, some Personal Information may be retained for longer periods as required by law, contract, or auditing requirements.
We have in place physical, electronic and procedural safeguards appropriate to the sensitivity of the information we maintain regarding Clients and Participants. Safeguards will vary depending on the sensitivity, format, location, amount, distribution and storage of the Personal Information. They include physical, technical, and managerial measures to keep Personal Information protected from unauthorized access. Among such safeguards are the encryption of communications via SSL, encryption of information while it is in storage, firewalls, access controls, separation of duties, and similar security protocols. However, due to the nature of the Internet and related technology, we cannot absolutely guarantee the security of Personal Information, and the Company expressly disclaims any such obligation.
ACCURACY, ACCOUNTABILITY, OPENNESS AND CUSTOMER ACCESS
Our knowing about changes to some of your Personal Information (e.g. email address) may be key to effectively communicating with you at your request. If any of your details change you can update us by e-mailing us at firstname.lastname@example.org or log in to the site and update your contact information. Please keep us informed of changes to your Personal Information.
You have the right to access your Personal Information and request rectification of any Personal Information in the file that may be obsolete, incomplete or incorrect. However, to secure your Personal Information, the Company does not provide online access to its customers to view or amend Personal Information in its database.
Global Privacy Leader
Marsh & McLennan Companies, Inc.
1166 Avenue of the Americas,
New York, New York 10036
Your Personal Information will be stored and can also be accessed at the Company office with which you do business. For a complete list of our offices, click here.
QUESTIONS OR TO WITHDRAW CONSENT
You may exercise your right to withdraw your consent to applicable uses or disclosures of your Personal Information (which may limit or terminate the products and services that the Company provides to you) by writing or sending an email to us at the above address. We will need to validate the identity of anyone making such a request to ensure that we do not provide your information to anyone who does not have the right to such information.
Normally we will respond to access requests within 30 days.