In visiting our Web site, we want you to know that you have control over your business and personal information. You can visit us on the Web without telling us who you are or revealing any business and personal information whatsoever, including your e-mail address.

This Privacy Policy outlines our information sharing practices to help you understand how we protect your privacy, when we collect and use information about you and your employees and operations, and the measures we take to protect the confidentiality of that information.

Your Confidential Information

Your Confidential Information includes, but is not limited to, Protected Health Information, Non-Public Personal Financial Information, and/or Trade Secrets. We do not sell your Confidential Information to others under any circumstances.  However, we may provide certain non-personally identifiable information to data clearinghouses in order to assist them in compiling broad based risk information for the benefit of the entire industry.

We collect only that amount of Confidential Information which you choose to provide to us and which we need to properly operate our business. If at any time this policy changes, those changes will be posted on this page of our Web site so that you are aware of our intent to better protect your privacy.

Confidentiality Practices

We support the concept of non-disclosure of your Confidential Information and protect it as we protect our own. We also hold our business associates and our affiliates to similar confidentiality standards. Your Confidential Information must be used and disclosed in a manner consistent with applicable laws and regulations, contractual obligations, and our company’s policies and procedures.

Protected Health Information is defined as individually identifiable health information that is held or transmitted by our company in performance of our contractual obligations with clients. This type of information includes information in electronic, paper and oral form. Protected Health Information may be used and disclosed solely for our company’s business activities related to health care operations.

Non-Public Personal Financial Information is defined as including confidential information of a financial nature that is shared by a current, prospective or prior client with us in the course of providing products and services to that client. This type of information is not otherwise available to the public and includes, but is not limited to, the following: credit history, financial benefits, business records, accounting information involving the client, contracts in which the client is a party, claims which the client is a party to, client’s policy information, and any other data of the client that is financial in nature.

Trade Secrets are defined to include any proprietary information of our current, prospective or prior client that is obtained through the course of our business activities with that client, through the provision of products and services provided by us to the client. This information is not otherwise available to the public and includes, but is not limited to, the following: business records, contracts, claims, products, business methods, data processing procedures, marketing strategies, pending projects or proposals, mailing lists, and any other information related to a client’s activities, products or services, which may or may not be protected by the United States Patent and Trademark Office.

Information We Collect

We know how important your privacy is to you and we appreciate you trusting us to handle your Confidential Information responsibly and with integrity. We collect Confidential Information about you and your employees and operations as required to operate our business, including, but not limited to, the following:

Information we receive related to risk control activities, such as your or your employee’s occupation, employer, social security and driver’s license numbers, Protected Health Information, Non-Public Personal Financial Information and Trade Secrets.

Information about you or your employee’s transactions with us, our affiliates, or previous insurers or employers, such as you or your employee’s policy coverage, claim information, premiums and payment and claim history.

In the course of conducting our business, we may share information you or your employees provide to us strictly on an as-needed basis or otherwise required by law.  In certain situations, and in no event contrary to applicable public policy, we would share information about you to: 1) our affiliated companies in order to provide a service to you; 2) a third party if reasonably necessary to enable them to perform services for us, such as claims inquiries, appraisals, or the detection of fraud or material misrepresentations; 3) governmental authorities only to the extent that we are required to disclose any such Confidential Information pursuant to the legal process we receive from such governmental authority.

Online Tracking

Non-personally identifiable information collected and displayed on an aggregate basis to persons or organizations conducting legitimate research.

Click Streams

We may capture click streams to help us learn what parts of our Web site are most popular and among which audiences. We may also use them to help us optimize our user interface, to analyze site usage statistically, to improve content, and to customize our Web site’s content and layout. In short, we use this information to allow us to tailor our Web site and to meet your needs better. We analyze click stream data to track trends and behaviors, not individuals. We are interested in our audience size, return visit rate, and similar data on an aggregate basis. We also capture date and time information of visits, pages visited, and the time you spend with us.

Cookies

Cookies are pieces of information that a Web site transfers to your computer’s hard drive for record-keeping purposes. They can make the site more useful by storing information about your preferences at our Web site. It is almost standard for any interactive Web site to use cookies. Cookies do not identify a user, but they do identify a user’s computer. Most browsers are set up to accept cookies. If you prefer, you can set your browser to refuse cookies, but some online services on our Web site will not function without them.

We do not use cookies to track or report on activity when you are not on our Web site or to provide such information to other parties. We do not use cookies to collect personal information such as your e-mail address, and we do not combine information collected through cookies with your Confidential Information. We make no attempt to look at or examine other cookies or information that may be stored on your computer.

Information We Share

We do not use, disclose, sell or transfer any Confidential Information without consent unless required or permitted by law or regulation. In cases of permitted disclosure, we will disclose information in compliance with applicable laws and regulations and will require the recipient to protect the information and use it only for the purpose provided.

Information Security

We restrict access to your Confidential Information to our employees who need to know such information in order to provide you with the insurance products or services which you have engaged us. We maintain physical, electronic, and procedural safeguards that comply with U.S. federal and state regulations to guard your Confidential Information.

Be aware that e-mail messages sent in clear text over the public Internet can be observed by an unintended third party. Non-encrypted Internet e-mail communications may be accessed and viewed by other Internet users without your knowledge and permission while in transit to us. If you wish to keep your information private, please do not use electronic mail to communicate information to us or request information from us that you consider to be Confidential and/or proprietary. If you wish, you may contact us instead via telephone at the phone number provided elsewhere in this Web site.

Links to Other Sites

We may provide links to other Web sites not owned or controlled by us that we think might be useful or of interest to you. We are not, however, responsible for the privacy practices used by other Web site owners or the content or accuracy contained on those other Web sites. Links to other Web sites do not constitute or imply endorsement by us of those Web sites, any products or services described on those Web sites or any other material contained in them. Contact those Web sites directly for their individual privacy policies.

Changes to Our Privacy Policy

We reserve the right to make changes to our Privacy Policy at any time.  We encourage you to review the Web site and the Privacy Policy in particular periodically for any updates or changes.  Your continued access of use of this Web site shall be deemed your acceptance of all terms and conditions contained in this Privacy Policy.

Copyright and Disclaimer

Gallagher Bassett Services, Inc. (GB), a wholly owned subsidiary of Arthur J. Gallagher & Co., grants permission to view, copy, print and distribute the information found on this website [the “Website”] provided that the above copyright notice appears on all copies, use is for internal informational purposes only, and no modification is made to any materials.  Any other use, reproduction or distribution must be first approved by GB.

DISCLAIMER. The content of this Website is provided for informational purposes only with the understanding that GB is not rendering legal, accounting or other professional advice on specific matters.   Accordingly, GB assumes no liability whatsoever in connection with the use of such content. GB recommends that you consult your legal counsel or other professional advisor with respect to your individual situation.

NO WARRANTIES. GB makes no representation or warranty whatsoever and assumes no responsibility or liability whatsoever in connection with the accuracy, completeness, or currency of the materials or the suitability, functionality, or operation of the materials on this or any other site that may be hyperlinked to this site. GB is in no way responsible for the views, content or accuracy of any site, which is either hyperlinked to or from this site, nor does GB endorse any content or products that may be advertised or noted on those sites. Information on this Web site is subject to change at any time without prior notice.

LIMITATION OF LIABILITY. GB provides these materials and Website on an “AS IS” “WHEN AVAILABLE” basis without warranty of any kind, express or implied, including, but not limited to, any implied warranty of merchantability or fitness for a particular purpose or non-infringement. In no event will GB be liable for any damages, including, but not limited to, special, indirect, incidental or consequential damages, or for acts of negligence arising in connection with any information, result, error, omission, defect, delay or system malfunction relating to GB’s Website regardless of whether GB has been advised of the possibility of such damages. Access to this Website may be monitored and use of this site constitutes consent to monitoring.

WARNING: Unauthorized access to secured databases or circumvention of security measures on this Website may be a violation of state and federal laws.

Client Disclosure Statement

This disclosure discusses certain GB policies and procedures and the manner in which GB provides services that enable us to provide the added value upon which you have come to rely. If you have specific questions regarding any of GB’s policies, procedures, or any other information contained in this disclosure, please contact your account manager or visit www.gallagherbassett.com.

Data Security and Privacy

GB takes care to protect the data entrusted to us and has made a commitment to safeguard the privacy of the assets and information of our clients. This means that we collect, use and safeguard client information as we would our very own. We strive to never share client information with a third party or employee that does not have authorization and a business need to know such information. A copy of GB’s privacy policy can be found at https://www.gallagherbassett.com/privacy-policy/.

GB employs industry standard data protection practices to aid in the prevention of theft, misappropriation and unauthorized access to electronically stored data. These measures may include, without limitation, password protections, restrictions on access, physical and electronic barriers and/or other steps as we deem necessary. We limit access to authorized users who may only obtain access through the use of a unique identifier and password. At times, GB may be required to transfer personal data to selected external third parties or business partners engaged to perform certain services. Such selected third parties will have access to personal data solely for the purposes of performing the services specified in the applicable service contract. These third parties may process personal data at the direction of GB or in the course of delivering the services for which they were retained. In either instance, GB will engage only reliable vendors who undertake, to GB’s satisfaction, to: (1) take reasonable and appropriate security measures to ensure data protection; and (2) comply with GB’s standards or an even greater level of data protection.

Document Retention

GB has adopted a records and electronic information management policy to ensure that GB does not store outdated and nonessential records, support efficient operational functioning and assure compliance with applicable business, legal, regulatory, and operational requirements. It is our policy to maintain complete, accurate, and high-quality records. Records are retained for a defined period based on their category unless longer retention is required for historical reference, contractual, legal, or regulatory requirements, or for other purposes set forth in our policy. Records that are no longer required to be retained, or which have satisfied their required period of retention, are destroyed or returned at the client’s request as described in our policy. As a general matter, GB will retain claim files for a period of ten (10) years following the date of closure of a claim, unless your agreement indicates differently, or as otherwise required by law.

Business Arrangements

As part of our comprehensive and integrated claims administration services model, GB may partner or enter into other business arrangements with selected vendors and service providers. GB generally purchases these services wholesale or at a negotiated discounted rate. We similarly expect our vendors and service providers to adhere to our high standards, including, more specifically, our Global Standards of Business Conduct, which can be found at http://www.ajg.com/about-us/global-standards/. We carefully vet these providers and utilize only those that we believe are best in class. In certain situations, GB may receive compensation from these arrangements corresponding to the services provided by GB for procurement of discounted and/or wholesale rates and for integration and management of the relationships with service providers. The prices charged to clients by GB reflect fair value for the ultimate services received by each client.

Anti-Corruption

We take a firm stance against corruption. Corruption or bribery, in any form, runs counter to GB’s values. GB is subject to, and has policies, procedures and training in place to comply with, domestic and international anti-corruption laws, including the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, OFAC and the laws of other countries in which we conduct business. Among other things, these laws prohibit any GB employee from offering, giving or receiving anything of value to improperly influence such person’s judgment or otherwise assist GB in obtaining business. We expect our business partners – such as consultants, contractors, agents or other third parties working on our behalf – to abide by the same laws.

Fraud

As our reputation depends on the integrity of our actions and dealings, we are committed to the prevention and detection of fraud. GB has created controls intended to prevent, detect and mitigate the risk of fraud. Any concerns regarding fraud or financial irregularities that you notice should immediately be brought to our attention.

Questions or Suggestions

Should you have any questions regarding any of the policies listed in this Disclosure, or any other policy affecting your relationship with GB, please ask your account manager. We appreciate your continued business, and look forward to bringing increased value to your business for years to come.