Privacy Notice

Marsh McLennan Agency Privacy Notice
Effective as of December 3, 2020
You can download this privacy notice here.

Marsh & McLennan Agency LLC (the “Company”) believes strongly in protecting the privacy and confidentiality of Internet users who visit this website (“site”). This Privacy Notice explains the way which this site collects personal information, how we may use this information, and the ways in which we protect it. Generally, personal information is information that can be used to identify you or your activities on this site or through services offered on this site. 

This Privacy Notice applies solely to data collected via the site; there may be additional personal (and other) information we have or collect about you pursuant to other relationships. 

Scope of this Privacy Notice
Except where noted in the State Privacy Notices section of this Privacy Notice, this Privacy Notice applies solely to data collected via the Site.  We gather this information when you:

• Visit or use our websites and/or applications,
• Provide us with the personal information required to fulfill the services we offer
• Send messages to us
• View or click on online content
• Create an account

What Data Do We Collect?

"Personal information" is information that identifies you as an individual or relates to an identifiable individual.  The type of personal information we may collect may relate to the performance of this site and, when applicable, the product or service being offered to you. 
Generally, we may collect the following types of personal information about you and, if required for the services provided, about your dependents or beneficiaries:

Individual Contact and Demographic Information (including Family Members)
Name, address, email address, telephone number, gender, marital status, date and place of birth, employer, job title and employment history, and/or your relationship to the policyholder, insured, beneficiary or claimant.

Identification details
Identification numbers issued by government bodies or agencies (e.g. depending on the country where you reside, this may include your social security or national insurance number, passport number, ID number, tax identification number, or driver’s license number).

Financial information
Payment card number, bank account number and account details, income and other financial information.

Insurable Risk Information
The information necessary to secure insurance products, provide risk consulting services, and/or offer guidance on other financial products and services to you – which may include, only to the extent necessary, the following:     

• Health data
  Current or former physical or mental medical conditions, health status, injury or disability information, medical procedures performed, relevant personal habits (e.g. smoking or consumption of alcohol), prescription information, medical history;
  
  
• Criminal records data
  Criminal convictions, including driving offences; and
  
  
• Other special categories of personal information
  Racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning an individual’s sex life or sexual orientation.

Policy Information
Information about the insurance quotes individuals receive and the policies they obtain.

Credit and Anti-fraud Data
Credit history and credit score, individual information about fraud convictions, allegations of crimes and sanctions details received from various anti-fraud and sanctions databases, or regulators or law enforcement agencies.

Current and/or Previous Claims
Information about current and/or previous claims, which may include health data, criminal records data and other Special Categories of personal information (as described in the Insured Risk definition above).

Marketing Data
Whether or not the individual has consented to receive marketing from us and/or from third parties.

Site Related Information
Information related to the operation of a website, which may include log-in credentials, IP address and other site related information

HOW DO WE COLLECT DATA?
Information Provided by You, Your Representatives or Third Parties
We may collect information from you, your representative, your employer, association, group, or benefit program sponsor and/or third parties that have roles in delivering services to you, your employer, association, group or benefit program sponsor. These may include insurance companies, plan administrators and vendors, brokers or agents, credit agencies, and financial institutions. You might provide this information when you visit this site; apply for insurance coverage; enroll in an association, group, or benefits program; communicate with us through email, chat and instant messenger; speak to a Marsh representative by phone or in a call center; or send mail/faxes to our office. In addition, your employer, association, group or benefit program sponsor or someone acting on their behalf may provide us with information about you.

If you supply us with personal information about other people, you represent that you have the authority to provide this information on their behalf.  In these instances, you further represent that the individuals to whom this information relates have been informed of and understand the reason(s) for obtaining the information, the manner in which this information will be used and disclosed, and have consented to such use and disclosure.

Information Collected by Automated Means
We use various tools to enhance your user experience and track users of our websites, including cookies and web beacons.  These tools may collect personal information including your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.

Cookies are small pieces of text that a website places on your computer to help remember information about your visit. Web beacons are tiny graphics with a unique identifier that are embedded invisibly on the web pages. Neither cookies nor web beacons can read data off your computer's hard drive or collect your personal information. We use information collected from cookies and web beacons to improve your experience and the overall quality of our services.

We may also use cookies and web beacons to collect information from third parties (such as Google) to help advertise our products and services, to analyze the effectiveness of our marketing or the performance of our websites, and to determine whether you may be interested in other products or services. We also use web beacons to help deliver cookies and compile analytics. Our cookies and web beacons may also come from third-party service providers who have permission to place such tools on our websites.

You can refuse to accept and delete cookies by adjusting your browser setting. Please note that refusing or deleting cookies may impact your browsing experience on our websites, or prevent you from using some of its services, and it may result in the deletion of any preferences you have set. For more information on how to reject or delete cookies, you should consult with your browser's or device’s help documentation.

We do not use technology that recognizes do-not-track signals from your browser.  You can also opt out of Internet based advertising by installing a browser plugin from the third party where available.  For more information about interest-based advertising, please see: http://www.networkadvertising.org/managing/opt_out.asp. You may also be able to opt out of our use of certain cookies using our Cookie Management Tool, where available, linked at the bottom of the Site.

 

In addition, in the course of seeking network security and consistent service for all users, software programs may be employed to monitor network traffic, identify unauthorized access or access to nonpublic information, detect computer viruses and other software that might damage our computers or the network, and monitor and fine-tune our network’s performance.

These programs may detect additional information from your computer such as your IP address, addresses from network packets, and other technical information. Any such information is used only for the purpose of maintaining the security and performance of our networks and computer systems.

We may combine the information you provide us and information we automatically collect with information from public or third-party sources.

How Do We Use the Personal Information We Collect?
We will use the information provided by you in order to:

• verify your identity
• register and service your online account
• contact you when necessary and to respond to your requests and inquiries
• process an insurance transaction, enrollment, or service requested by you directly, or through a third party
• allow you to manage the services requested by you, or through a third party
• maintain network security and performance and protect against cyber-attacks
• market our services to you, including ours, those of our affiliates, and those of other third parties
• analyze and improve our products and services and evaluate the overall effectiveness of our marketing activities and overall services
• administer, improve, and personalize the Site
  • In addition to our own analysis, enhancement, and evaluation activities, we work with Google Analytics to collect information about the use of this Site (including how often users visit the Site and what pages users visited prior to visiting the Site) to maintain and improve the Site.  For information about how Google uses the information, see Google’s Terms of Service and the Google Privacy Notice.  You can opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.
• comply with and enforce applicable laws, industry standards, and our own policies
• as otherwise described to you at the point of collection or pursuant to your consent

With Whom Do We Share Your Data?
We may share your personal information to assist with managing and running this site, or deliver other insurance and consulting products or services requested by you, your employer, or association, group or benefit program sponsor.  We may share this information: 

• as necessary to perform the services you request from us
  • We may disclose your personal information to insurance carriers, and third-party brokers/agents in connection with providing quotes, administering claims, binding coverages, and other services. 
• with your employer, association, group or benefit program sponsor (when applicable)
  • To assist in the administration of a group insurance program, we may share program-related personal information required for the administration and governance of the group program.
• with affiliates
  • to enable them to provide services to you or contact you regarding additional products and services that you have expressed an interest in.
• with third party service providers
  • We sometimes contract with other companies and individuals to perform functions or services for us or on our behalf, such as hosting this Site, sending e-mail messages, and making phone calls.  They may have access to personal information needed to perform their functions, but are contractually restricted from using such personal information for purposes other than providing services for us or on our behalf.
• to address legal concerns
  • We may preserve, and have the right to disclose any information about you or your use of this Site, without your prior permission if we have a good faith belief that such action is necessary to: (a) protect and defend the rights, property, or safety of our company or its affiliates, other users of this Site, or the public; (b) enforce the terms and conditions that apply to use of this Site; (c) respond to claims that any content violates the rights of third parties; (d) respond to claims of suspected or actual illegal activity; (e) respond to an audit or investigate a complaint or security threat; or (f) comply with applicable law, regulation, legal process, or governmental requests.

We will not disclose, share, sell, or otherwise disclose your information to unaffiliated third parties for their own marketing unless so authorized by you, your employer or association, group or benefit program sponsor. 

Our third-party affiliates, service providers and successors to whom we disclose information are required by law and/or contractual requirements to keep your personal information confidential and secure.  These parties may not use or disclose it except as reasonably necessary to provide services to you, on our behalf, or on behalf of your employer or association, group of benefit program sponsor, or to comply with or as permitted by applicable law.

We may disclose and/or process your personal information without your prior permission, as permitted by law, including instances when we have a good faith belief that it is necessary to: (a) protect the legal rights, safety, and security of our company, our affiliates and business partners, and users of our site; (b) enforce the Terms of Use; (c) respond to claims of suspected or actual illegal activity; (d) respond to an audit or investigate a complaint or security threat; or (e) comply with law or legal process, or a request for cooperation by a government or other entity.  We may also share information that is not reasonably likely to identify you personally for any commercially legitimate business purpose.

What Steps Do We Take to Protect Your Information?
This site and al information submitted by you or on behalf of you through this site may be collected, stored, and processed in countries other than the one in which you reside, including, but not limited to, the United States.

We restrict access to your personal information to employees of ours, our affiliates, and third-party service providers who reasonably need it to support this site or provide our products or services.  We have implemented physical, administrative, and technical safeguards to protect your personal information from unauthorized access.  However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our systems, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet.

What Rights and Obligations Do You Have with Respect to Your Data?
Accessing and Correcting Your Information
Keeping your information accurate and up-to-date is very important.  Inaccurate or incomplete information could impact our ability to deliver relevant services to you.  Please let us know about any changes that may be required to your personal information using the contact information below.

Securing Your Own Information
By using this site, you agree that you will take measures to protect this information, including the maintenance of any username and password in a confidential manner, and restricting system access to only those who may need such access on your behalf.

SOME OTHER MATTERS
Cross–Border Transfer of Personal Information
This Privacy Notice is provided in accordance with and subject to U.S. law.  If you access this Site from a location outside the United States, you agree that your use of this Site is subject to the terms of this Privacy Notice and the Terms of Use.

Business Transactions
In the event we sell some or all of our assets, it is possible your personal information could one of the assets transferred to the purchaser.  We may disclose and/or transfer your personal information to a third-party purchaser under these circumstances. 

Children
This site is not intended for children, and we do not knowingly collect, use, or disclose information of children under the age of thirteen (13) without the consent of their parents or legal guardians.  In an instance where such information was collected, it would be purely accidental and unintentional. 

State Privacy Notices

• State of California – page down to access the California Resident Privacy Notice which are applicable as of January 1, 2020 and apply solely to consumers who are California residents. 

Changes to This Privacy Notice
The Privacy Notice is subject to change at any time.  If we make changes to this Privacy Notice, we will update the “Effective date” at the top of this page.  Any changes we make to this Privacy Notice become effective immediately, so you should review this Privacy Notice regularly for changes. 

Questions, Requests or Complaints
If you have any questions, requests, concerns or complaints about this Privacy Notice, or our privacy practices in general, they should be directed to the Company at compliance@marshmma.com or:

Marsh & McLennan Agency LLC
Corporate Communications
360 Hamilton Avenue, Suite 930
White Plains, NY 10601

________________________________________________________________
STATE OF CALIFORNIA PRIVACY NOTICE – as prescribed by the California Consumer Privacy Act
effective Date:  January 1, 2020

Scope of this Privacy Notice
These California Resident Privacy Terms are effective January 1, 2020 and supplement the information contained in Marsh & McLennan Agency LLC’s governing website Privacy Notice.  This notice applies solely to consumers who are California residents. 

Marsh & McLennan Agency LLC (“We”) strive to protect the privacy and confidentiality of the personal information with which we are entrusted.  This California Resident Privacy Notice explains the personal information we collect or process about California residents in connection with the services we provide or offer to you, including through any site, application, or product that links to this Privacy Notice (the “Service”), how we use, share, and protect that personal information, and what your rights are with respect to your personal information that we gather and process.

In this California Resident Privacy Notice, "personal information" has the same meaning as under the California Consumer Privacy Act (“CCPA”): information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, Personal information does not include information that has been de-identified or aggregated.

Please also note that in certain cases, we may collect your personal information for the Service pursuant to a contract we have with a commercial client (our “Client”).  In such circumstances, we may be acting as a “service provider” and are obligated to process the personal information we collect or are provided in connection with the Service in accordance with instructions from or the contract with our Client, which is the business ultimately responsible for determining how your personal information will be handled.

Accordingly, if you are using the Service in connection with your role as an employee of our Client, or by virtue of some other relationship with, our Client, we encourage you to review that Client’s privacy notice to understand the full scope of how your personal information will be handled.

Further, in any case where we are acting as a service provider to a Client, if you or your authorized agent (together referred to hereinafter, where applicable, as “you”) wish to exercise any rights that may be available to you under certain data privacy laws (for example, the right to access or deletion under the CCPA if you are a resident of California as described below), you should direct your request to our Client, who is the party responsible for receiving, assessing, and responding to your requests, as we do not have any obligation, and, notwithstanding anything in this Privacy Notice to the contrary, may elect not, to respond to your requests. If you are not certain whether we are acting as a service provider to a Client in your particular circumstance, please contact us through one of the methods described at the end of this Privacy Notice. 

What Personal Information Do We Collect and Share, and for What Purpose?
In the past 12 months, we may have collected and shared the following types of personal information from or about users of the Service:

We may also use or share de-identified information that is not reasonably likely to identify you for commercially legitimate business purposes. We do not sell personal information to any third parties, and have not done so in the preceding 12 months.

Your Rights as a California Resident
Under California law, some California residents have specific rights regarding their personal information as described below.  These rights are subject to certain exceptions.  Further, if we have collected or processed your personal information in connection with a product or service we are providing to our Client that is a company, partnership, sole proprietorship, nonprofit or government agency, and you are an employee, owner, director, officer, or contractor of that entity, rights 1-3 below are not available to you until at least January 1, 2021.

When required, we will respond to most requests within 45 days, unless it is reasonably necessary for us to extend our response time.

1. Right to Disclosure of Information

You have the right to request that we disclose certain information regarding our practices with respect to personal information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:

• The categories of personal information we have collected about you in the last 12 months.
• The categories of sources for the personal information we have collected about you in the last 12 months.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.
• If we sold your personal information for a business purpose, a list of the personal information types that each category of recipient purchased.
• If we disclosed your personal information to a third party for a business purpose, a list of the personal information types that each category of recipient received.

1. Right to Delete Personal Information

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will determine if retaining the information is necessary for us or our service providers to:

• Complete a transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation; and/or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If none of the above retention conditions apply, we will delete your personal information from our records and direct our service providers to do the same.

How to exercise the above rights
To exercise your rights to disclosure or deletion described above, please submit a verifiable consumer request to us by visiting our online privacy rights portal by visiting https://privacyportal-cdn.onetrust.com/dsarwebform/ee9df2bb-0ef3-4485-bc63-4db420e77359/d069761e-0a4e-47ed-b3f3-dca1bcf32e6e.html
Alternatively, you may call us at 800-960-0416.

Only you or a person who can demonstrate that they are legally authorized to act on your behalf may make a verifiable consumer request related to your personal information. 
You may make a verifiable consumer request for access or deletion no more than twice within a 12-month period. The verifiable request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.  Such verification process will involve you confirming details of the personal information we have collected about you, and will increase in scope in the event the nature of your request relates to the disclosure of sensitive personal information or the deletion of any personal information.  In some instances, you may be required to submit proof of your identity (e.g. a driver’s license);

and

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You will not be required to create an account with us in order to submit a verifiable request, though we may communicate with you about your request via a pre-established account if applicable.  However, in order to safeguard the personal information in our possession, if we cannot verify your identity or authority to act on another’s behalf, we will be unable to comply with your request.  We will only use personal information you provide when submitting a verifiable request to confirm your identity or authority, or to fulfill your request.

1. Right to Opt out of Sales of Your Personal Information

As a California resident, you have the right to direct a business that sells your personal information to third parties not to sell your personal information.  This right is referred to as “the right to opt-out.” 
Because we do not sell your personal information, we do not provide any mechanism for you to exercise the right to opt out.

We do not sell Personal Information. As we explain in our Privacy Policy, we and our third party partners use cookies and other tracking technologies to analyze website traffic and facilitate marketing or advertising. You can learn more about the cookies utilized on this Site and opt out of our and our third party partners use of certain cookies using our Cookie Management Tool linked at the bottom of the Site.

1. Right to Non-Discrimination

You may exercise your rights under the CCPA without discrimination. For example, unless the CCPA provides an exception, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We may offer you financial incentives to provide us with personal information that is reasonably related to the information’s value.  This could result in different prices, rates, or quality levels for our products or services. Any financial incentive we offer will be described in written terms that explain the material aspects of the financial incentive program.  You must opt-in to any financial incentive program and may revoke your consent at any time by contacting us as indicated below.

1. Direct Marketing and Do Not Track Signals

Under California’s “Shine the Light” law, California residents may request and obtain a notice once a year about the personal information we shared with other businesses for their own direct marketing purposes.  Such a notice will include a list of the categories of personal information that were shared (if any) and the names and addresses of all third parties with which the personal information was shared (if any).  The notice will cover the preceding calendar year.  To obtain such a notice, please contact us as described below.  In addition, under this law you are entitled to be advised how we handle “Do Not Track” browser signals.  Because there currently is not an industry or legal standard for recognizing or honoring Do Not Track signals, we do not honor Do Not Track requests at this time.

Minors
We do not knowingly collect personal information from children under the age of 13.  If we learn that we have collected any personal information from a child under the age of 13 without verifiable parental consent, we will delete that information from our files as quickly as possible.  If you believe that we may have collected information from a child under 13, please contact us at the email address provided below.

We never sell the personal information of minors under 16 years of age, and would not do so in the future without affirmative authorization of the consumer if between 13 to 16 years of age, or the parent or guardian of a consumer less than 13 years of age.

Questions, Requests or Complaints
To submit general questions or requests regarding this Privacy Notice or our privacy practices, they should be directed to the Company at:

Marsh McLennan Agency
Corporate Communications
360 Hamilton Avenue, Suite 930
White Plains, NY 10601

To submit a request* to access or delete your information, please visit our online request portal by visiting https://privacyportal-cdn.onetrust.com/dsarwebform/ee9df2bb-0ef3-4485-bc63-4db420e77359/d069761e-0a4e-47ed-b3f3-dca1bcf32e6e.html
Alternatively, you may call us at 800-960-0416 or email us at compliance@marshmma.com.

*Please note that, as described above, in certain cases we may collect your personal information as a service provider pursuant to a contract we have with a commercial Client to provide the Service.  In any case where we are acting as a service provider to a Client, you should direct your requests to exercise your rights available under data privacy laws to our Client, who is the party responsible for receiving, assessing, and responding to your requests.  As a service provider, we do not have any obligation, and, notwithstanding anything in this Privacy Notice to the contrary, may elect not, to respond to your requests.