Private Client Select Insurance Services (“Private Client Select”) and its subsidiaries and affiliates (each a “Private Client Select Company”, “Private Client Select Companies”, “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 the benefits of activities like research and data analytics with our other commitments, including transparency and non-discrimination.
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(ies)’s privacy notices to understand how your information will be used.
In addition, we may receive information about you from your insurance brokers 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(ies)’s privacy notices to understand how this information will be used.
This notice only applies to information that we collect about you that is not shared with or processed on behalf of these insurance companies or received 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 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.
For our California Consumer Privacy Act Notice, please click here.
- Whom to Contact About Your Personal Information
- Personal Information That We Collect
- How We Use Personal Information
- International Transfer of Personal Information
- Sharing of Personal Information
- Personal Information of Other Individuals
- Marketing Preferences
- Social Security Numbers
- Questions and Concerns
- Other Information We Collect Through our Private Client Select On-line Services
- How We Collect Other Information
- Use of Services by Minors
- Changes to This Privacy Notice
1. Whom to Contact About Your Personal Information
If you have any questions about our use of your Personal Information you can e-mail Pcs.firstname.lastname@example.org.
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), Personal Information collected about you and your dependents 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).
- 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 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, or 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 you 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 process 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, manage 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.
- Carry out 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.
- Personalize your experience when using our Private Client Select On-line Services or visiting third-party websites by presenting information and advertisements tailored to you.
- Identify you to anyone to whom you send messages through any of the Private Client Select On-line Services.
- Allow you to participate in contests, prize draws and similar promotions, and to administer these activities. Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these carefully.
- Facilitate social sharing functionality.
- 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 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. 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 an "privateclientservices.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. Further, please note that any communication you send to an "privateclientservices.com" e-mail address will be routed through the United States.
5. Sharing of Personal Information
Private Client Select may make Personal Information available to:
- Our group companies
Other Private Client Select group companies may have access to and use of Personal Information in connection with the conduct of our business where appropriate.
- 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; 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
- Governmental authorities and third parties involved in court action
Private Client Select may also share Personal Information with governmental or other public authorities (including, but not limited to, 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: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and (g) to 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 Pcs.email@example.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.
Private Client Select will take appropriate technical, physical, legal and organizational measures, which are consistent with applicable privacy and data security laws. 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. (See the "Whom to Contact About Your Personal Information" section above.)
When Private Client Select provides Personal Information to a service provider, the service provider will be selected carefully and required 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 would 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. 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 Notice.
8. 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 Pcs.firstname.lastname@example.org 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 addresses. We will endeavor to comply with your opt-out request(s) within a reasonable time period. 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., to those 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.
9. Social Security Numbers
It is Private Client Select’s policy to protect customer Social Security Numbers that we collect in the course of our business as confidential. This includes maintaining physical and electronic security procedures to guard against unauthorized access to Social Security Numbers. In addition, we do not disclose Social Security Numbers to third parties, except where required or permitted by law.
10. 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.
11. 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
12. 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.
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.
- 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: Some information (for example, your location or preferred means of communication) is collected 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 may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable 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.
13. Use of Services by Minors
The Private Client Select On-line Services are not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Information through the Private Client Select On-line Services.
14. Changes to This Privacy Notice
We review this Privacy Notice regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our website.
Please take a look at the “LAST UPDATED” date below to see when it was last revised.
Last Updated June 2023