PURPOSE FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
- Establishing and maintaining communications with you;
- Where you have requested a service from Marsh, 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 Marsh 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, email 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 Marsh.
- Where you register with us and/or request an insurance quote: If you register with the site, or request an insurance quote, we may ask you for your name, email 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, age, personal identification numbers, credit card numbers, credit records, banking information, payment records, medical and health information, employment and income information;
- Information we acquire from and/or transfer to other persons (such as government agencies, industry associations, auditors, claims adjusters, your insurer and your employer) to verify your identity and the accuracy of the information you have provided;
- Information about you received from Marsh affiliates, insurers, other intermediaries, third party providers and others for underwriting or claims purposes (such as previous insurance and claims history) about our Clients and Participants; and
- Information we receive from consumer reporting agencies.
Following the quote, if you decide to proceed, we will collect personal information necessary to finalize the relevant quote and proceed with the transaction, such as your name, address, post code, contact telephone number, email address, billing address or payment details, as relevant to the product. We will use your personal information to administer your policy, process claims etc. and generally manage your relationship with us. Please see the Disclosure of Your Information to Others section for information on the categories of recipients of the personal data.
- 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 email address, so that, if you choose, we can update you by email when others also comment on the content, and also so that we can manage the content in line with our acceptable use policy. You should be aware that the information you provide there will be made publically available to Marsh employees and other users of the site.
Website Navigational Information / Cookies
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).
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.
In the normal course of performing services for our clients, personal information may be shared within Marsh 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 Marsh, 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 Marsh 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.
The transfer of personal information is governed by European Union (EU) standard contractual clauses, the EU-US Privacy Shield or equivalent data transfer agreements to protect the security and confidentiality of your personal information.
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 Marsh itself or substantially all of Marsh 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
Marsh preserves the right to disclose without your prior permission any personal information about you or your use of this site if Marsh has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of Marsh, 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
Your knowledge of and consent to Marsh’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 Marsh);
- Your express consent or acknowledgement contained within a written, verbal or electronic application or claims process; and
- Your verbal consent solicited by Marsh (or our agent) for a specified purpose.
Where Marsh 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. Marsh will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain personal information or withdrawing consent for Marsh 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 Marsh does not require your consent to engage in the processing or disclosure of personal information. Marsh 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 Marsh (or one of its affiliates);
- The transfer or processing is necessary for the performance of a contract, concluded in your interest, between Marsh (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
Marsh 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.
Marsh 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 Marsh 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 emailing us at email@example.com 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, Marsh does not provide online access to its customers to view or amend personal information in its database.
st. M.Pymonenka 13
5V input, 2 floor, office 21
04050 m. Kyiv, Ukraine
Your personal information will be stored and can also be accessed at the Marsh 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 Marsh provides to you) by writing 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.