Insured Privacy Notice

I.  Overview

This Notice is meant to provide our valued customers with information about Howden US Specialty LLC (“Howden”, “we”, “us” and “our”) Privacy Practices, when it comes to the Nonpublic Personal Information that we need to collect from you when you apply for or obtain an insurance policy with us.

Title V of the Gramm‐Leach‐Bliley Act (GLBA) generally prohibits any financial institution, directly or through its affiliates, from sharing nonpublic personal information about you with a nonaffiliated third party unless the institution provides you with a notice of its privacy policies and practices, such as the type of information that it collects about you and the categories of persons or entities to whom it may be disclosed. In compliance with the GLBA, we are providing you with this document, which notifies you of the privacy policies and practices of Howden.

II. Definitions

“Customer” means a natural person who is utilizing our services in order to obtain insurance that is to be used for personal, family, or household purposes.

“Nonpublic Personal Information” means any personally identifiable financial information that Howden collects about its Customers in order to quote, bind and support the administering of claims in connection with an insurance policy. Nonpublic Personal Information does not include any information that is Publicly Available.

“Publicly Available” means information made available to the public via federal, state, or local government records (i.e., the filing of a mortgage on a property). Publicly Available also includes information that is contained in widely distributed media and made available to the general public on an unrestricted basis, even if there is a fee for access or a password protected access to the media (i.e., telephone books, newspapers, and websites),

III. Howden’s Information Collection Practices Overview

Howden offers a range of products and services including, and related to, the brokering, placement, administration and renewal of insurance policies (further information about what we do can be found on www.howdengroup.com/us-en). To provide these services, we may collect and process both personal and non-personal information from our Customers. It is our policy to only obtain the Personal Information that is absolutely necessary to provide our services to you and to limit the access to customer Personal Information to only those individuals who need it to serve our Customers’ insurance needs. We strive to provide the best service and thus, certain information may also be used to maintain and improve our customer service to you. In general, we only disclose a customer’s Personal Information to our Affiliates and other professionals we work with when necessary to conduct business such as processing an application for insurance, supporting the administering of Customer’s claims, or as required by law.

IV. Information We Collect from You

We collect certain Nonpublic Personal Information about you in order to provide our services to you. We describe what information we collect and how we obtain it below. Unless it is specifically stated otherwise in an amended Privacy Policy Notice, no additional nonpublic personal information will be collected about you.

a. Information Provided by You

If you fill out an application with us directly, or register for an account online via our Customer portal or download our insurance application, we will collect certain Nonpublic Personal Information about you such as your name, address, e-mail address, and telephone number. 

We may also need to collect your financial information, details about a claim that you are processing, or other information related to your insurance policy and/or a claim.

b. Information Provided by Your Insurer

There may be times when your insurance provider needs to share information with us directly in order to renew your existing, or place new, insurance coverage. In those situations we will collect your Nonpublic Personal Information from them in order to process your information to submit for that process.

c. Information Provided by Consumer Reporting Agencies or Other Insurance Support Organizations

In order to quote and ensure that your policy is bound, we may need to obtain additional information about you, to the extent permitted by law, such as your credit report, driving record, accident and motor vehicle conviction history,

d. Information Provided by Other Insurance Companies

In order to quote and ensure that your policy is bound, we may need to obtain additional information about you, to the extent permitted by law, such as your prior insurance coverage history and other current insurance coverage(s) provided by another insurance company. 

e. Information Provided by Government Agencies or the Court

In order to quote and bind your policy, we may need to obtain additional information about you, to the extent permitted by law, such as your driving record abstract, documents related to property ownership, criminal convictions, and civil judgments.

V. Who We Share Your Personal Information With

As noted above, we may need to share Your Nonpublic Personal Information for different reasons. Based on those reasons, we may Your Nonpublic Personal Information with the following Third-Parties, including:

a.  Authorized service providers and Affiliates: We may share Your Nonpublic Personal Information with our authorized service providers that perform certain services on our behalf. These services may include relationship management software; brokers and agents, claims management providers, claims investigators, evaluators, contractors and auditors; email marketing providers; customer service providers; providers that perform business and operations analysis for us.

b.  Insurance Companies and Reinsurers: We may share your Nonpublic Personal Information with insurance companies and reinsurers in order to verify coverage, or obtain our own insurance coverage.

c.  State insurance regulators and government entities: Upon request or in connection with a legal reason, we may provide your Nonpublic Personal Information to insurance regulators and other governmental entities for fraud investigations or other regulatory purposes.

d.  Business partners: When you request a quote or participate in our services and programs, we may share Your Nonpublic Personal Information, with the businesses with which we partner to administer the services and programs (e.g., evaluators, independent adjusters, contractors).

e.  Non-Affiliated Companies: We may share Your Nonpublic Personal Information with non-affiliated companies that perform marketing services on our behalf or with whom we have joint marketing agreements, such as financial service providers engaged in banking, consumer finance, securities and insurance, and non‐financial companies such as envelope stuffers and other fulfillment service providers.

VI. Categories of Your Nonpublic Personal Information that is shared with Non-Affiliated Joint Marketers

We may share the following categories of Nonpublic Personal Information with our Joint Marketing Partners:

a.  Identifiers (i.e., a legal name, nickname, physical home address, email address, phone number, an online identifier, driver’s license number, etc.).

b.  Professional or Employment Information (i.e. where a person currently works).

c.  Demographic Information (i.e., such as zip code).

VII. Sale of Your Nonpublic Personal Information

We do not sell your Nonpublic Personal Information. Additionally, we do not disclose any Nonpublic Personal Information about you with anyone for any purposes that is not specifically permitted by law.

VIII. How We Secure Your Nonpublic Personal Information

Howden maintains a comprehensive Information Security Program that employs commercially available physical and IT securitization tools, including but not limited to:

a.  Commercially available and sufficient firewalls;

b.  Segmented Data Storage;

c.  Multi-factor authentication; and

d.  Policies providing for least privileged access to data across our organization.

Unfortunately, however, there is no way to completely eliminate the risk of a data security incident. If we do suffer one that affects any of Your Nonpublic Personal Information, we will report the same to you as per applicable data breach notification laws. If you have any questions about our cybersecurity posture, you can send an email to [email protected].