Privacy Notice

Privacy Notice

Last Updated:  February 26, 2026

Private Client Select Insurance Services LLC (“Private Client Select”) ( “Private Client Select”, “we”, or “us”) is committed to protecting the privacy of the individuals we encounter in conducting our business.  “Personal Information” is information that identifies and relates to you or other individuals (such as your dependents).  Our aim is responsible handling of Personal Information, balancing our commitments to transparency and non-discrimination with the benefits of activities like research and data analytics.

Our processing of Personal Information will be undertaken consistent with the requirements of applicable privacy laws.

This Privacy Notice describes how we handle Personal Information that we collect through:                 

• this website (“the Site”), the software applications made available by us for use on or through computers, mobile devices, or other Internet-connected devices (the “Apps”), our social media pages linked from our websites (our “Social Media Pages”) (collectively, including the Site, the Apps and our Social Media Pages, referred to as the “Private Client Select On-line Services”); and
• other means (for example, from your application and claim forms, telephone calls, e-mails and other communications with us, as well as from claim investigators, medical professionals, witnesses, or other third parties involved in our business dealings with you).

By using the Private Client Select On-line Services, you signify your acceptance of this Privacy Notice.  

Please note: This Privacy Notice is supplemented by Privacy Notices tailored to our specific relationships with you, including Privacy Notices that are sent to individuals as required under applicable laws and regulations.

Insurance Company and Insurance Broker Privacy Practices

Most of the information we collect from or about you we collect on behalf of the insurance companies that sell you the policies that you obtain through us or that we manage for you.  We use this information to administer and service your policy. Our collection and use of that information is governed by the applicable insurance company’s privacy notices, and not this notice.  Please review the applicable insurance company’s/ies’ privacy notices to understand how your information will be used. 

In addition, we may receive information about you from your insurance brokers, producers or from other third parties who pass this information to us on your behalf.  We use this information to evaluate what different types of policies to suggest to you, and to procure policies at your instruction and on your behalf.  Our agreements with these brokers place limits on what we can do with the information we receive from them.  Please review the applicable broker’s/s’ or other third party’s/ies’ privacy notices to understand how this information will be used. 

This notice only applies to information that we collect about you that we do not share with or process on behalf of these insurance companies or receive from a broker or other third party acting on your behalf.

Other Third Party Privacy Practices

In addition, this Privacy Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party (such as Producers) operating any site or service to which the Private Client Select On-line Services link.  The inclusion of a link on the Private Client Select On-line Services does not imply endorsement of the linked site or service by us or by our group companies.

Please note that we are not responsible for the collection, usage, and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other software application developer or provider, social media platform, operating system, or wireless service provider, or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

More Information

1. Whom to Contact About Your Personal Information
2. Personal Information That We Collect
3. How We Use Personal Information
4. International Transfer of Personal Information
5. Sharing of Personal Information
6. Security and Storage
7. Retention of Information
8. Personal Information of Other Individuals
9. Marketing Preferences
10. Social Security Numbers
11. Questions and Concerns
12. Other Information We Collect Through our Private Client Select On-line Services
13. How We Collect Other Information
14. Use of Services by Minors
15. Data Collection by AI Systems
16. Changes to This Privacy Notice
17.  Contact Us   

1.  How to Contact PCS with Inquiries Regarding Your Personal Information

Please e-mail any questions you have about our use of your Personal Information to: privacy@privateclientselect.com.

2.     Personal Information That We Collect

Depending on your relationship with us (for example, as a consumer policyholder, a person benefiting under another policyholder’s policy, or a claimant; a witness; a commercial broker, or appointed representative; or other person relating to our business), the Personal Information about you and your dependents that we collect may include:

• General identification and contact information 
  Your name; address; e-mail and telephone details; gender; marital status; family status; date of birth; passwords on our systems; educational background; physical attributes; activity records, such as driving records; photos; employment history, skills, and experience; professional licenses and affiliations; relationship to the policyholder, insured or claimant; and date and cause of death, injury, or disability.
• Identification numbers issued by government bodies or agencies 
• Social Security or national insurance number; passport number; tax identification number; military identification number; or driver’s or other license number.
• Financial information and account details 
• Payment card number; bank account or other financial account number and account details; credit history and credit score; assets; income; and other financial information.
• Medical condition and health status 
• We may receive current or former physical or mental or medical condition; health status; injury or disability information; medical procedures performed; personal habits (for example, smoking or consumption of alcohol); prescription information; and medical history.
• Other sensitive information 
• In certain cases, we may receive sensitive information about you for example, if you apply for insurance through a third-party that is a professional, trade, political, religious, or community organization.  In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting, and investigating fraud.  We may also obtain sensitive information if you voluntarily provide it to us (for example, if you express preferences regarding medical treatment based on your religious beliefs). We do not use or disclose sensitive personal information for purposes other than those specified under applicable privacy laws.
• Telephone recordings 
  Recordings of telephone calls to our representatives and call centers.
• Photographs and video recordings 
  Photographs or video recordings created in connection with our insurance or other business activities, including without limitation during property inspections and for claims assessment, processing, settlement, and disputes, or for other relevant purposes as permitted by law.
• Information to investigate or prevent crime, including fraud and money laundering 
  For example, insurers commonly share information about their previous dealings with policyholders and claimants for this purpose.
• Information enabling us to provide products and services 
  Location and identification of property insured (for example, property address, vehicle license plate or identification number); travel plans; age categories of individuals you wish to insure; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organization; other insurance you hold; and details on products for which you have or seek a warranty.
• Marketing preferences, customer feedback, and survey responses
  You may let us know your marketing preferences, enter a contest, prize draw, or other sales promotion, or respond to a voluntary survey.
• Information on Your Use of Private Client Select On-Line Services
  Information on how you use the Private Client Select On-Line Services, such as Site pages you view, links you follow, how you use an App, and other usage information.
• Social media account and information from Apps 
  We may receive certain Personal Information about you when you use our Apps or Social Media Pages, including your social media account ID and profile picture.  If you elect to connect any of your other social media accounts to your account(s) on the Private Client Select On-line Services, Personal Information from your other social media account(s) will be shared with us, which may include Personal Information that is part of your profile relating to those accounts or your friends’ profiles.
• Information from Other Sources 
  We and our service providers may supplement the Personal Information we collect with information from other sources, such as publicly available information from social media services, commercially available sources, and information from our affiliates or business partners.

3.     How We Use Personal Information

We use this Personal Information to:

• Communicate with you and others as part of our business.
• Respond to your requests.
• Submit applications for insurance policies, and administer insurance policies on your behalf, including without limitation processing claims.
• Send you important information regarding changes to the policies managed through us, other terms and conditions, our Private Client Select On-line Services, and other administrative information.
• Make decisions about whether to provide insurance and assistance services, and other products and services which we offer, and provide such products and services, including claim assessment, processing, and settlement; and, where applicable, management of claim disputes.
• Assess your eligibility for payment plans and process your premium and other payments.
• Provide improved quality, training, and security (for example, with respect to recorded or monitored phone calls to our contact numbers).
• Prevent, detect, and investigate crime, including fraud and money laundering, and analyze and manage other commercial risks.
• Conduct research and analysis, including analysis of our customer base and other individuals whose Personal Information we collect as explained in this Privacy Notice.
• Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed.
• Identify you to anyone to whom you send messages through any of the Private Client Select On-line Services.
• Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; data analytics; business continuity; and records, document, and print management.
• Resolve complaints, and handle requests for data access or correction.
• Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering, sanctions, and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence).
• Establish and defend legal rights; protect our operations or those of any of our group companies or business partners, our rights, privacy, safety, or property, and/or that of our group companies, you, or others; and pursue available remedies or limit our damages.

4.     International Transfer of Personal Information

Due to the global nature of our business, for the purposes set out above we may transfer and process Personal Information to parties located in other countries.  For example, we may transfer Personal Information to another country if you are in another country, or if we are processing a claim involving another country. We may also transfer information internationally to our group companies, service providers, business partners, and governmental or public authorities to process the Personal Information.  By providing Personal Information and other information to Private Client Select, including through the Private Client Select On-line Services, and/or by sending a communication to a "privateclientselect.com" e-mail address, you understand and consent to the collection, use, processing disclosure, and transfer of such information in the United States and other countries or territories, which may not offer the same level of data protection as the country where you reside, in accordance with the terms of this Privacy Notice. Please note that any communication you send to a "privateclientselect.com" e-mail address will be routed through the United States. 

Further, if you are a resident of Canada, the European Union or the United Kingdom, the disclosure below applies to Private Client Select processing of your data. 

1. International Transfer of Personal Information to Canada, European Union and the United Kingdom

If our processing of your Personal Information is subject to GDPR, UK GDPR, and/or PIPEDA, and unless subject to an exemption, you may have the following rights with respect to your personal information:

• Right of Access: You have the right to view and request copies of your personal information.
• Right to Rectification: You have the right to request that your inaccurate or outdated personal information be updated or corrected.
• Right to be Forgotten/Right to Erasure: You have the right to request your personal data be deleted, upon providing verification to us.
• Right to Restrict Processing: You have the right to request the restriction or suppression of our processing of your personal information.
• Right to be Informed: You have the right to be informed about the collection and use of your personal information.
• Right to Data Portability: You have the right to ask for your personal information to be transferred to you or to another controller.
• Right to Withdraw Consent: You have the right to withdraw previously given consent to process your personal information.
• Right to Object: You have the right to object to the processing of your personal information.
• Right to Object to Automated Processing: You have the right to object to decisions being made with your personal information solely based on automated decision making or profiling.

We will need to verify your identity to process any requests described in this Section and may deny your request if we are unable to verify your identity. Government or other identification may be required.

If you are a resident of the European Economic Area (“EEA”), when we process your personal information, we will only do so in the following situations:

•             We need to use your information to perform our responsibilities under our agreement with you.

•             We have a legitimate interest in processing your personal information. For example, we may process your personal information to send you marketing communications, to communicate with you about the Private Client Select Site, and to provide and improve the Private Client Select Site.

•             We have your consent to do so.

If your personal data is subject to GDPR or UK GDPR, we will transfer personal data from the EEA to a location outside the EEA only when there has been a documented adequacy determination, or where we have confirmed adequate privacy protections. If your personal data is subject to PIPEDA, we will transfer personal data from Canada to locations outside Canada only where we have confirmed adequate privacy protections. If we transfer personal data to a third party acting as our agent, we will also obligate the third party to have adequate privacy protections in place.

5.     Sharing of Personal Information

Private Client Select does not make any “sale” of Personal Information. Private Client Select may make Personal Information available to:

• Our group companies
  Where appropriate, other Private Client Select group companies may have access to and use of Personal Information in connection with the conduct of our business.
• Other insurance and distribution parties 
  In the course of marketing and providing insurance and processing claims, Private Client Select may make Personal Information available to third parties such as other insurers; reinsurers; insurance and reinsurance brokers, and other intermediaries and agents; appointed representatives; distributors; affinity marketing partners; and financial institutions, securities firms, and other business partners.
• Our service providers
  External third-party service providers, such as medical professionals, accountants, actuaries, auditors, experts, lawyers, and other outside professional advisors; travel and medical assistance providers; call center service providers; property inspections providers, IT systems, support, and hosting service providers; printing, advertising, marketing, and market research and analysis service providers; banks and financial institutions that service our accounts; third-party claim administrators; document and records management providers; claim investigators and adjusters; construction consultants; engineers; examiners; jury consultants; translators; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
• Recipients of your social sharing activity
  Your friends associated with your social media account(s), other website users, and your social media account provider(s), in connection with your social sharing activity, such as if you connect another social media account to your Private Client Select On-line Services account or log into your Private Client Select On-line Services account from another social media account. By connecting your Private Client Select On-line Services account and your other social media account you authorize us to share information with your social media account provider and you understand that the use of the information we share will be governed by that other social media website’s Privacy Notice. If you do not want your Personal Information shared with other users or with your other social media account provider(s), please do not connect other social media accounts with your Private Client Select On-line Services account and do not participate in social sharing using our Private Client Select On-line Services.
• Providers of Internet-connected devices and associated software
  Private Client Select may make the Personal Information you provide to us via our Apps available to providers of Internet-connected devices and/or associated operating systems and/or software as set forth in the terms of use and/or privacy notices you agree to with those providers.
• Governmental authorities and third parties involved in court action 
  Private Client Select may also share Personal Information with governmental or other public authorities (including, without limitation, workers’ compensation boards, courts, law enforcement, tax authorities, and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers, and other advisors and representatives as we believe to be necessary or appropriate to: (a) comply with applicable law, including laws outside your country of residence; (b) comply with legal process; (c) respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) enforce our terms and conditions; (e) protect our operations or those of any of our group companies; (f) protect our rights, privacy, safety, or property, and/or that of our group companies, you or others; and (g) allow us to pursue available remedies or limit our damages.
• Other Third Parties
  We may share Personal Information with payees; emergency providers (fire, police, and medical emergency services); retailers; medical networks, organizations, and providers; travel carriers; credit bureaus; credit reporting agencies; and other people involved in an incident that is the subject of a claim; as well as purchasers and prospective purchasers or other parties in any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer, or other transaction relating to all or any portion of our business, assets, or stock. 
• Should you prefer, we will not disclose confidential personal information about you to non-affiliated third parties other than applicable insurance companies or as otherwise permitted by law. You may opt out of those disclosures; that is, you may direct us not to make those disclosures (other than disclosures required or permitted by law). Should you wish to opt out of disclosures to non-affiliated third parties you may contact us by e-mail at privacy@privateclientselect.com.
• Personal Information may also be shared by you, on message boards, chat, profile pages and blogs, and other services to which you are able to post information and materials (including, without limitation, our Social Media Pages and Apps). Please note that any information you post or disclose through these services will become public information and may be available to visitors who access the Private Client Select On-line Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Private Client Select On-line Services.

6.     Security and Storage

Private Client Select undertakes appropriate technical, physical, legal, and organizational measures, which are consistent with applicable privacy and data security laws, designed to protect all Personal Information.  Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have with us has been compromised), or if you have other data security questions or concerns related to Private Client Select, please immediately notify us via email at: privacy@privateclientselect.com.

Private Client Select carefully chooses service providers to whom we provide Personal Information, and we require each service provider to use appropriate measures reasonably designed to protect the confidentiality and security of the Personal Information.

If we believe the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail.

7.     Retention of Information

We retain personal information about you for as long as necessary to provide you the Private Client Select Site. In some cases, we retain personal information for longer, if doing so is necessary to comply with our legal obligations, or as otherwise permitted by applicable law. Afterwards, we retain some information in a de-identified and/or aggregated form but not in a way that would identify you personally.

8.           Personal Information of Other Individuals

If you provide Personal Information to Private Client Select regarding other individuals, you agree: (a) to inform the individual about the content of this Privacy Notice, and any other applicable Private Client Select Privacy Notice provided to you; and (b) to obtain any legally required consent of Personal Information about the individual in accordance with this Privacy Notice and other privacy notices and applicable regulations.

9.     Marketing Preferences

We will provide you with regular opportunities to tell us your marketing preferences, including in our communications to you. You can also contact us by e-mail at privacy@privateclientselect.com to tell us your marketing preferences and to opt out.

If you no longer want to receive marketing-related e-mails from Private Client Select on a going-forward basis, you may opt out of receiving these marketing-related emails by clicking on the link to “unsubscribe” provided in each e-mail or by contacting us at the above email address (privacy@privateclientselect.com). We will endeavor to comply with your opt-out request(s) within a reasonable time. Please note that if you opt out as described above, we will not be able to remove your Personal Information from the databases of third parties with whom we have already shared your Personal Information (i.e., those third parties to whom we have already provided your Personal Information as of the date on which we respond to your opt-out request).  Please also note that if you do opt out of receiving marketing communications from us, we may still send you other important administrative communications from which you cannot opt out.

10.     Your Choices

You can choose whether or not to provide personal information through the Site. We will not discriminate against you for exercising any of your rights relating to your personal information and will not (i) deny you goods or services, (ii) provide you with a different level or quality of services, or (iii) charge you different prices for services for doing so.

Consumer Privacy Disclosures

In the preceding 12 months, we collected and disclosed for a business purpose the following categories of personal information about consumers:

Purposes for Collection, Use, and Sharing. We use and disclose the personal information we collect for our commercial purposes, as further described in this Privacy Policy, including for our business purposes with our partners and service providers as follows:

• Legal compliance and auditing related to our interactions with you.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and exercising our related rights.
• Performing and improving out services (by us or our service provider(s)).
• Internal operations.
• Other one-time or short-term uses.

Individual Privacy Rights

If you are a California resident or a resident of another state that provides for individual privacy rights, you may have the following rights in relation to personal information we have collected about you, to the extent required by the applicable law and subject to verification:

• Right to Know/Access: You have the right to request certain information about our collection and use of personal information about you as described below:
• The specific pieces of your personal information collected.
• The categories of your personal information collected.
• The categories of sources from whom your personal information is collected.
• The purpose for collecting your personal information.
• The categories of third parties with whom we have shared your personal information.
• Right to Delete: You have the right to request that we delete certain personal information we have about you.
• Freedom from Discrimination: You have the right to be free from unlawful discrimination for exercising any of your privacy rights.
• Right to Correct: You have the right to request that we correct inaccurate personal information regarding the information you provide us.
• Right to Restrict the Use of Sensitive Personal Information: You have the right to restrict the use of your sensitive personal information.
• Right to Access Information on Automated Decision-Making: You have the right to access information collected through automated decision-making. Additionally, you can opt-out of our use of automated decision-making related to your personal information.

To make a request in relation to the above rights, please contact us using the notice information below. To fulfil your request, we will need to verify your identity. Only you or someone legally authorized to act on your behalf may make a request related to your personal information. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that you authorize them to act on your behalf.

11. Questions and Concerns

Please contact us as set out in the “Whom to Contact About Your Personal Information” section above with any such requests or if you have any questions or concerns about how we process Personal Information.

12.  Other Information We Collect Through our Private Client Select On-line Services

“Other Information” is any information that does not directly reveal your specific identity, such as:

• Browser and device information;
• App usage data;
• Information collected through cookies, pixel tags, and other technologies;
• Demographic information and other information provided by you; and
• Aggregated information 

13.  How We Collect Other Information

We and our third-party service providers may collect Other Information in a variety of ways, including:

• Through your browser or device: Certain information is collected by most websites or automatically through your device, such as your IP address (i.e., your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, device manufacturer and model, language, internet browser type and version, time of the visit, page(s) visited, and the name and version of the Private Client Select On-line Services (such as the App) you are using.  We use this information to ensure that the Private Client Select On-line Services function properly.
• Through your use of the App: When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
• Using cookies; online tracking: Cookies are pieces of information stored directly on the device you are using. Cookies allow us to recognize your device and to collect information such as internet browser type, time spent on the Private Client Select On-line Services, pages visited, language preferences, country website preference. We may use the information for security purposes, to facilitate navigation, to display information more effectively, or to personalize your experience while using the Private Client Select On-line Services. In addition, we may use the information to gather statistical information about the usage of the Private Client Select On-line Services to understand how they are used, continually improve their design and functionality, and assist us with resolving questions about them. Cookies further allow us to present to you the advertisements or offers that are most likely to appeal to you. We may also use cookies to track your responses to our advertisements and we may use cookies or other files to track your use of other websites. We do not respond to browser do-not-track signals at this time.
• We may utilize the following types of cookies: 
• Absolutely Necessary Cookies. These Cookies are essential to enable you to move around a website and use its features. Without these Cookies, services you have asked for, like adding items to an online order, cannot be provided.
• Performance Cookies. These Cookies collect information about how you use the Private Client Select Site. Information collected includes, the Internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, average duration of visit, and pages viewed. These Cookies do not collect information that personally identifies you and only collect aggregated and anonymous information. Performance Cookies are used to improve the user-friendliness of a website and enhance your experience.
• Functionality Cookies. These Cookies allow the Private Client Select Site to remember choices you make (such as your username, language preference, or the area or region you are in) and provide enhanced, more personal features. These Cookies can also be used to remember changes you have made to text size, fonts, and other customizable parts of the Private Client Select Site. The information these Cookies collect may be anonymized, and they cannot track your browsing activity on other websites.

Third parties may collect information about your use of the Private Client Select On-line Services and your use of other websites or online services.

You can refuse to accept the cookies we use by adjusting your browser settings. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Site and some online products. 

Further, you may opt out of receiving certain cookies by visiting the Network Advertising Initiative (NAI) opt out page or the Digital Advertising Alliance (DAA) opt out page, or by installing the DAA’s AppChoices app (for iOS; for Android) on your mobile device. When you use these opt-out features, an “opt-out” cookie will be placed on your device indicating that you do not want to receive interest-based advertising from NAI or DAA member companies. If you delete cookies on your device, you may need to opt out again. For information about how to opt out of interest-based advertising on mobile devices, please visit https://thenai.org/opt-out/mobile-opt-out/. You will need to opt out of each browser and device for which you desire to apply these opt-out features.

• Using pixel tags, web beacons, clear GIFs, or other similar technologies: These may be used in connection with some Private Client Select On-line Services and HTML-formatted e-mail messages to, among other things, track the actions of users of the Private Client Select On-line Services and e-mail recipients across the devices they use and compile statistics about usage of the Private Client Select On-line Services and response rates. In some instances, we may combine information collected through these technologies with your Personal Information.
• Using your Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower, or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we may not be able to provide you with the applicable personalized services and content. In addition, we may obtain the precise geolocation of your device when you use our mobile applications for purposes of providing travel or other assistance services to our clients who are enrolled in such services.  In connection with providing travel or other assistance services, and for purposes of developing and improving our actuarial and pricing tools and risk management programs for our commercial insurance clients, we may share your device’s precise geolocation information with our insurance clients and other entities with whom we work to provide our products and services.  You may opt-out of our collection and sharing of precise geolocation information by deleting the mobile application from your device, by disallowing the mobile application to access location services through the permission system used by your device’s operating system, or by following any additional opt-out instructions provided in the privacy notice available within the mobile application.
• Using information provided by you: We collect some information (for example, your location or preferred means of communication) when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you. 
• By aggregating information: We may aggregate and use certain information (for example, we may aggregate information to calculate the percentage of our users who have a particular telephone area code).

Please note that we use and disclose Other Information only for purposes necessary to operate, improve, or secure the services, and only in aggregated or de-identified formats unless otherwise required by law.  If we are required to treat Other Information as Personal Information under applicable law, or if we combine Other Information with Personal Information, then, in addition to the uses listed in the “Other Information We Collect” section above, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.

14.  Use of Services by Minors

The Private Client Select On-line Services are not intended for use by children. Individuals under the age of 18 may not use the Private Client Select On-line Services. The Private Client Select On-line Services does not knowingly collect any information from children. If you are under 18, do not attempt to register for the Private Client Select On-line Services or send us any personal information. By accessing, using and/or submitting information through the Private Client Select On-line Services, you represent that you are not younger than 18 and that you have authority to do so. If you are a parent or legal guardian of a minor child, you may, in compliance with this Privacy Policy, use the Private Client Select On-line Services on behalf of such minor child. Information you provide through the Private Client Select On-line Services on behalf of a minor child will be treated as personal information as provided herein. If you use the Private Client Select On-line Services on behalf of another person, regardless of age, you represent and warrant that you have authority to do so.

15.  Artificial Intelligence & Automated Decision-Making

We may employ artificial intelligence (AI) technologies (“AI Systems”) to enhance the performance and functionality of our services and the Private Client Select Site and/or support certain internal operations and customer facing services, which includes tailoring your experience through automated processing based on your activity using the Private Client Select Site. The AI Systems work by analyzing your usage patterns, preferences, and other interactions within our services to predict your interests and preferences. The insights gathered allow us to improve our service offerings, improve efficiency and accuracy, provide personalized content and advertising, and enhance user satisfaction and service quality.

This notice explains how we use AI Systems, which training data we may use, and how you may request additional information or human review. By using the Private Client Select Site, you consent to the use of AI as described in this Privacy Policy. We encourage you to review your privacy settings regularly to ensure they continue to reflect your preferences.

For more information on your rights and how we use AI, or if you have any concerns about automated decision-making processes, please contact us at privacy@privateclientselect.com.

15.1      Data Collection by AI Systems

Our AI Systems collect data that you provide directly or indirectly through your interactions with the Private Client Select Site. The data collected may include, but is not limited to:

•             Usage data, such as the pages you visit, the links you click on, and the searches you conduct on our platform.

•             Device and connection information, including your IP address, browser type, language, and cookies that uniquely identify your browser or account.

•             Location information, determined through data such as your IP address or device’s GPS signal.

15.2      Automated Decisions

Our AI Systems may make automated decisions including:

•             Content curation and recommendations based on user preferences and historical activity.

•             Fraud detection and prevention through behavior analysis to identify and flag unusual activity that deviates from typical usage patterns.

15.3      User Rights and Control 

You have the right to:

•             Obtain an explanation of any automated decision and challenge its basis.

•             Opt-out of certain uses of your data, including profiling activities for personalized content or advertising.

•             Access the personal data that the AI Systems use or contribute to, and request rectification or erasure of such data.

•             Receive information about the logic involved in any automated decisions, as well as the significance and the envisaged consequences of such processing for you.

15.4      Safeguards and Oversight

We are committed to using AI responsibly. To this end, we implement the following safeguards:

•             Regular auditing of our AI Systems for accuracy, fairness, and effectiveness.

•             Human oversight to monitor AI decision-making and intervene as necessary to address anomalies or biases.

•             Compliance with privacy regulations, ensuring that data used by AI is processed lawfully, transparently, and securely.

16.         Changes to This Privacy Notice

We review this Privacy Notice regularly and reserve the right to make changes at any time to account for changes in our business and legal requirements.  We will place updates on our website.

Please refer to the “LAST UPDATED” date above to see when we last revised this Privacy Notice.

IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE PRIVATE CLIENT SELECT SITE AFTER THE EFFECTIVE DATE OF SUCH CHANGES.

17. Contact Us

The data controller for the purposes of GDPR, UK GDPR, PIPEDA or other data protection laws is Private Client Select Site. If you have any questions about this Privacy Policy, please contact us at privacy@privateclientselect.com or at:

Private Client Select Insurance Services LLC

150 Second Avenue N, Suite 1070

St. Petersburg, FL 33701

Attn: Chief Legal Officer