Gallagher Securities Global Privacy Notice

This Privacy Notice applies to Gallagher Securities, Inc., and its affiliates and subsidiaries (collectively, "we," "our," "us," or "Gallagher Securities"). This Privacy Notice provides you information concerning how we collect, use, share and retain your data and your rights with respect to your data. You may have additional rights available to you based on your country's local laws and regulations. When you have such rights, we have provided you information concerning those rights in a country-specific addendum. Gallagher Securities is part of the Gallagher group of companies. A full list of the Gallagher group of companies is available here.

View the Global Privacy Notice by country and language

In this Privacy Notice, we identify the personal data that we collect about you and how we use that data. This Privacy Notice applies to any personal data you provide to Gallagher Securities and any personal data we collect from other sources, unless you are provided a more specific privacy statement at the time of data collection. This Privacy Notice does not apply to any third-party websites, applications or portals ("Sites") linked to Gallagher Securities' Sites, or to any Gallagher sites that have their own privacy notices. If you provide personal data to us about other people, you must provide them with a copy of this Privacy Notice and obtain any consent required for the processing of that person's data in accordance with this Privacy Notice.

If you have any questions about this Privacy Notice, please contact us using the details set out in the Contact Us section. When using our Sites, you should read this Privacy Notice alongside the Site's Terms of Use.

The following sections will guide you through our practices for the collection, usage, disclosure and retention of your personal data:

1. Who we are

We are a global company providing a range of professional services including, (re)insurance brokerage and financial services.

2. How we process your personal data

2.1 Individuals in scope of this Privacy Notice

This Privacy Notice provides information for those individuals whose personal data we process, including:

Business contacts, such as brokers, (re)insurers, managing agents (MGAs), service providers, lawyers, suppliers, professional advisors, Municipal Advisors, conference attendees, visitors to our offices, government officials and authorities.
Customers and claimants , such as those in respect of securities we place as part of our core insurance and securities business activities (e.g., parties covered under the policies, potential beneficiaries of the policies, and other parties involved in claims in respect of the policies), and any other customers in relation to our various service offerings (e.g., employers, pension trustees, premium financing services, current, former and retired plan members, spouses and other beneficiaries entitled to payment from pension and/or benefit plans for whom we provide administrative services, Qualified Institutional Buyers, Municipal Advisors ,and Asset Managers).
Users of our Sites.
Other individuals, such as those requesting or receiving our marketing information, making general inquiries, entering competitions or promotions, or whose images we use in marketing or are captured on CCTV.

2.2 How we collect your personal data

We collect your personal data in a number of ways, which vary based on how you interact with us and as allowed by applicable law. The following summarizes our various collection points:

Directly from you or your authorized representative, such as when you provide your personal data to us, including from any of our Sites, surveys, live events, market research, and other direct communications and/or solicitations.
From our clients and partners, such as commercial clients, (re)insurers, network partners, brokers, employers, benefit plan sponsors, benefit plan administrators, premium finance companies, health service providers, pension trustees, data/marketing list providers and third-party service providers.
Publicly available sources, such as social media platforms, property and assets registers, and claims and convictions records.
Gallagher Securities affiliate companies.
Government authorities, such as police and regulators.
Background checks and screening tools, such as insurance industry fraud prevention and detection databases, credit agencies and sanctions screening tools.
Other third parties.

2.3 Personal data we collect

We collect the following types of personal data depending on the purpose of your interaction with us (e.g., as business contact, customer, claimant, insured) and as allowed by applicable law:

Basic personal and demographic information, such as your name, date of birth, age, gender and marital status.
Contact information, such as your address, telephone number and email address.
Unique identifiers, such as identification numbers issued by government bodies or agencies (e.g., your national identifier number or social security number, passport number, ID number, tax identification number, driver's license number, birth, death and marriage certificates, military passbook, and copies of official documents).
Beneficiary information, such as details of relationships, family members and dependents.
Employment information, such as your job title, employer, employment status, salary information, employment benefits, pensionable service periods, employment history and professional certifications and training.
Financial information, such as your bank account numbers and statements, credit card numbers, brokerage account numbers, transaction information, tax information, details of your income, property, assets, investments and investment preferences, pension and benefits, debts, and creditworthiness.
Policy information, such as your policy number, policy start and end dates, premiums, individual terms, mid-term adjustments, reasons for cancellation, risk profile, details of policy coverage, enrolment, eligibility for insurance or benefits, benefit amounts and underwriting history.
Claim information, such as a claimant's relationship to a policyholder/insured, claims history and claims data, and the date and particulars of a claim, including causes of death, injury or disability and claim number.
Plan information, such as contributions levels and benefit options
Commercial information, such as records of your personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Events or meeting information, such as details about your visits to our offices (including CCTV), your interest in and attendance at events or meetings, audio recordings, photographs or videos captured during meetings, events or calls with you.
Lifestyle information, such as travel history and plans and general health data.
Special category data and sensitive personal data, such as data relating to your health (including protected health information), genetic or biometric data, sex life, sexual orientation, gender identity, racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership.
Criminal records information, such as criminal charges or convictions, including driving offences, or confirmation of clean criminal records.
Professional disciplinary information.
Personal information received from background checks and sanctions screenings, including status as a politically exposed person.
Marketing information, such as your consent to or opt out from receiving marketing communications from us and/or third parties, your marketing preferences, or your interactions with our marketing campaigns and surveys, including whether you open or click links in emails from us or complete our surveys.
Sites and communication usage information, such as your username, your password, other information collected by visiting our Sites or collected through cookies and other tracking technologies as described in our cookie policy, including your IP address, domain name, your browser version and operating system, traffic data, location data, browsing time, and social media information, such as interactions with our social media presence.

2.4 How we use your personal data

Depending on the purpose of your interaction with us (e.g., as business contact, customer, claimant, insured, pension member), we use your personal data to:

Perform services for you or our clients
- Provide services and fulfill our contractual obligations, including providing services that you may not have personally requested but were requested by our client(s) and require us to interact, directly or indirectly, with you.
- Facilitate and enable placement of securities and assist in the ongoing management of such policies, including premium management, renewals, adjustments, cancellations, Sidecars, Capital Raising, and Catastrophe Bonds.
- Provide various consulting, administration, financial, and actuarial services and claims administration.
- Advise on the management of our clients' business risks and opportunities, affairs and insurance arrangements and on the administration of claims.
Manage our business operations
- Enter into business relationships and perform due diligence and background checks, such as fraud, trade sanctions screening, and credit and anti-money laundering checks.
- Create, maintain, customize and secure your account with us.
- Maintain accounting records, analyze financial results, comply with internal audit requirements, receive professional advice and, apply for and make claims on our own insurance policies manage or dispute a claim and recover a debt.
- Conduct data analytics, surveys, benchmarking, and risk modelling to understand risk exposures and experience, for the purposes of creating de-identified and/or aggregate industry or sector-wide reports, to share within Gallagher’s group of companies and with third parties.
Communicate and market to you
- Communicate with you regarding your account or changes to our policies, terms and conditions, respond to any inquiries you may have, and send you invitations for events or meetings.
- Advertise, market and promote our services or the services of others, including by email, LinkedIn, SMS, post or telephone.
- Send you newsletters, offers or other information we think may interest you, as well as offer and administer promotions.
- Monitor usage of our Sites and personalize your experience with our Sites and the messages we send you to deliver content, product and service offerings relevant to your interests, including targeted offers and ads through our Sites, third-party Sites, and via email, SMS or text (with your consent, where required by law).
Comply with legal obligations
- Comply with national security or law enforcement requirements, discovery requests, or where otherwise required or permitted by applicable laws or regulations, court orders or regulatory authorities.
- Exercise and defend ours, yours or third parties' legal rights.
Monitor and prevent fraud or wrongdoing
- Maintain the safety, security, quality, integrity and availability of our products, services, systems and data, detect security incidents, protect against inadvertent data loss, malicious, deceptive, fraudulent, or illegal activity, and debug or identify and repair errors that impair existing intended functionality.
- Monitor and ensure the safety and security of our premises, property, employees and visitors.
Improve our services
- Develop, enhance, expand or modify our services through research and development.
- Monitor, review, assess and improve our technology systems, including any Sites, and our content on social media platforms.
- Improve and develop systems and algorithms involving machine learning and artificial intelligence.
- Improve quality, training and security (for example, with respect to recorded calls).
Mergers and acquisitions
- Facilitate commercial transactions, including a reorganization, merger, sale of all or a portion of our assets, a joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). Should such a sale or transfer occur, we will use reasonable efforts to ensure the entity to which we transfer your personal data agrees to use it in a manner consistent with this Privacy Notice.

If we intend to use your personal data for any other purpose not described in this Privacy Notice or which is not compatible with the purpose for which your personal data was collected, we will contact you and let you know of that purpose, which may include the need to satisfy our legal and regulatory obligations. Where we require your consent to the processing, we will request it in advance.

2.5 Legal basis for processing personal data

Local law and regulation may require us to have a legal basis to process your personal data. In most cases, our legal basis for processing your personal data will be one of the following:

Legitimate Business Interest, such as seeking to and entering into or performing our contractual duties, maintaining our business records, keeping records of insurance policies or other products we place, and analyzing and improving our business model, services, systems and algorithms. When using your personal data for these purposes, we ensure our business need does not conflict with the rights afforded to you under applicable laws.
For the performance of a contract with you or in order to take steps at your request prior to entering into that contract.
Compliance with legal obligations, such as when you exercise your rights under data protection laws and make requests, for compliance with legal and regulatory requirements and related disclosures and for the establishment and defense of legal rights.
Fraud detection or prevention.
Consent, such as when we have to obtain your consent to process your personal data.

When we process sensitive personal data, sometimes referred to as special category data, in most cases our legal basis will be one of the following:

As required to establish, exercise or defend legal claims.
As necessary for insurance operations when it is in the substantial public interest, where applicable under local data protection laws.
As necessary for the prevention or detection of an unlawful act and/or fraud when it is in the substantial public interest, where applicable under local data protection laws.
You have given us your explicit consent-where we receive sensitive personal data or special category data indirectly, the third party is responsible for obtaining your explicit consent to enable us to collect and use your data for the purposes described in this Privacy Notice.

2.6 Who we share your personal data with

We share your personal data within Gallagher’s group of companies for the purpose of your interaction with us, such as for the provision of our services, general business operations and controls, marketing, data analytics, systems and algorithm improvements, surveys, benchmarking, and compliance with applicable laws.

We may also share your personal data with the following third parties for the purpose of your interaction with us:

Your employer, as part of our provision of the services to you or your employer.
Professional Advisors, such as underwriters, actuaries, claims handlers and investigators, surveyors, loss adjustors/assessors, accident investigators, specialist risk advisors, pension providers or trustees, banks and other lenders (including premium finance providers), health professionals, health service providers, lawyers (including third party legal process participants), accountants, auditors, tax advisors, Municipal Advisors ,financial institutions, investment advisors and other fiduciaries and consultants.
Business partners, such as customers, (re)insurance companies, MGAs, brokers, other insurance intermediaries, claims handlers, Pension Funds, Municipal Advisors, Asset Managers, or other companies who act as insurance distributors and premium financing companies.
Providers of insurance broking and other platforms we use.
Service providers, such as IT software, security and cloud suppliers, finance and payment providers, marketing agencies, external venue providers, address tracers, printers, document management providers, telephony providers, debt collection agencies, background check and credit reference agencies.
Fraud detection agencies and credit bureaus which operate and maintain fraud detection or credit registers.
Industry bodies.
Insurers who provide you with insurance and us with our own insurance.
Regulators, public authorities and law enforcement agencies, such as police, judicial bodies, governments, quasi-governmental authorities, financial and pension regulators and workers' compensation boards, where we are required or requested to do so by law.
Asset purchasers and Swaps, such as those who may purchase or to whom we may transfer our assets and business.
Other third parties, where we have your consent or are required by law.

When required by applicable law, we will obtain your explicit consent before sharing your data with any third parties. We will also require third parties (where applicable) to maintain a comparable level of protection of personal data as set out in this Privacy Notice by the use of contractual requirements or other means. On request and where required by law, we will confirm the name of each third party to which your personal data has, or will be, transferred. To the extent permitted by applicable law, we disclaim all liability for the use of your personal data by third parties.

2.7 Children

Our Sites are not intended for children and we do not knowingly collect, use, or disclose information about children. If you are a minor, please do not provide any personal data even if prompted to do so. If you believe that you have inadvertently provided personal data, please ask your parent(s) or legal guardian(s) to notify us. In the event that we learn that we have inadvertently collected personal data via our Sites from a child, we will delete that information as quickly as possible.

3. How we protect your personal data

We use a range of organizational and technical security measures to protect your personal data, including, but not limited to, the following:

Restricted access to those who need to know for the purposes set out in our underlying agreement or this Privacy Notice, and who are subject to confidentiality obligations.
Firewalls to block unauthorized traffic to servers.
Physical servers located in secure locations and accessible only by authorized personnel.
Internal procedures governing the storage, access and disclosure of your personal data.
Additional safeguards as may be required by applicable laws in the country where we process your personal data.

Please note that where we have given you (or you have chosen) a password, you are responsible for keeping the password confidential. Please do not share your password with anyone.

4. How we protect your personal data when sending it internationally

We operate as a global business and may transmit your personal data across borders, including within Gallagher Securities' group of companies and to certain third parties, including our partners and service providers. This sharing of data allows us to provide you services as set out in our underlying agreement or as otherwise indicated in this Privacy Notice. When required by applicable law, we will obtain your explicit consent before transferring your data.

The laws that apply to the country where the data is transferred may not be equivalent to that in your local country (or in the country in which we provide the services). Transfers of personal data will comply with applicable law and be subject to suitable safeguards to ensure an adequate level of protection, including, where required, the use of standard contractual clauses approved by the local data protection regulator, that require each party to ensure that the personal data receives an adequate and consistent level of protection. Please contact us using the details provided under the Contact Us section if you would like further information regarding our international transfers and the steps we take to protect your personal data when sending it internationally.

5. Marketing activities

From time to time, we may provide you with information about our products or services or those of our partners that we think will be of interest to you. We may send you this information by email, LinkedIn, SMS, text, post or we may contact you by telephone. We may also share your personal data with other Gallagher group companies so that they can provide you with information about their products and services we believe will be of interest to you. We ensure that our marketing activities comply with all applicable legal requirements. In some cases, this may mean that we ask for your consent in advance of sending you marketing materials.

You can opt out of receiving marketing communications from us at any time. Please use the "unsubscribe" link in our marketing emails to opt out of receiving those emails. Alternatively, please contact us using the details provided under the Contact Us section. In such circumstances, we will continue to send you service-related communications where necessary.

6. Profiling and automated decision-making

Insurance market participants benchmark insured, beneficiary and claimant attributes and risk factors, and insured event likelihoods in order to determine insurance limits, insurance premiums and fraud patterns. This means that we compile and analyze data in respect of insureds beneficiaries and claimants to model such likelihoods. In doing so, we use personal and commercial data in order to create the models and/or match that data against the models (profiling) to determine both the risk and the premium price based on similar exposures and risks. We also use this information to help us advise insurance companies about the typical levels of insurance coverage that our clients may have in place.

We will only make automated decisions about you where:

Such decisions are necessary for entering into a contract (e.g., we may decide not to offer services to you, the types or amount of services that are suitable for you, or how much to charge you for services based on your credit history or financial or related information we have collected about you);
Such decisions are required or authorized by law (e.g., fraud prevention purposes); or
You give your consent for us to carry out automated decision-making. You may withdraw your consent at any time by contacting us.

These automated decisions may have a legal or similar effect on you, namely, your eligibility for or access to products or services.

We may also make automated decisions based on your personal data or browsing history to send you personalized offers, discounts or recommendations, subject to any applicable local laws and regulations. These automated decisions will not have legal or similar effects for you.

Subject to local laws and regulations, you can contact us to request further information about our automated decision-making, object to our use of automated decision-making, or request that an automated decision be reviewed by a human being.

7. How long we keep your personal data

We keep your personal data for as long as reasonably necessary to fulfil the purposes set out in this Privacy Notice based on our business needs and legal requirements.

When we no longer need your personal data, we de-identify or aggregate the data or securely destroy it based on our retention policy. Please note that de-identified or aggregated data is not treated as personal data under this Privacy Notice and may be used for analytics purposes.

We have a detailed retention policy that governs how long we hold different types of information. Please contact us using the details provided under the Contact Us section for further information regarding how long we keep your personal data.

8. Your personal data rights

Based on the country in which you reside, and subject to permitted exemptions, you may have certain rights in relation to your personal data. We are committed to respecting your personal data rights. Please refer to your country-specific addendum for information on the rights that apply to individuals in your country.

You can exercise your rights by contacting us using the details provided in the Contact Us section. We will usually not charge you for processing these requests. There may be cases where we are unable to comply with your request (e.g., via a permitted exemption or where the request would conflict with our obligation to comply with other legal requirements). We will tell you the reason if we cannot comply with your request and we will always respond to any request you make.

9. Contact us

Please contact us if you have any questions about how we collect and process your personal data. You may contact us by writing to GlobalPrivacyOffice@ajg.com. To assist in providing you with an accurate response, please let us know the Gallagher Securities business you interact with and your applicable

10. Updates to this Privacy Notice

We may update this Privacy Notice from time to time. When we make updates, we will post the current version on our Sites and will revise the version date located at the bottom of the Privacy Notice. We encourage you to review this Privacy Notice periodically so that you will be aware of our current privacy practices.

11. Disclaimer

Gallagher Securities, Inc. is a licensed broker dealer authorized and regulated by FINRA and a member of SIPC.

Gallagher Securities Limited, a company registered in England and Wales (company number 2908053 and ARBN number 604 264 557) with a registered address at 51 Lime Street, London, EC3M, is authorized and regulated by the Financial Conduct Authority and exempt from the requirement to hold an Australian Financial Services License under ASIC Class Order [03/1099].

Gallagher Securities Europe is authorized and regulated by the French Prudential Supervision and Resolution Authority (Autorité de contrôle prudentiel et de résolution), 4, Place de Budapest — CS 92459 — 75436 Paris Cedex 09 (https://acpr.banque-france.fr), and also regulated by the French Financial Markets Authority ("AMF" — Autorité des marchés financiers), 17, Place de la Bourse — 75002 Paris, France).

The indicative terms contained herein shall not constitute an offer or solicitation for the purchase or sale of the investment, which may only be made by, and are subject to the terms of the investment subscription and related documentation; nor shall there be any offer, solicitation, or sale of the investment in any U.S. state or jurisdiction in which such offer, solicitation, or sale would be unlawful prior to registration or qualification under the securities laws or insurance laws in any such U.S. state or jurisdiction. All material contained herein, including proposed terms and conditions, is for discussion purposes only and do not contain any legally binding obligations on the part of any of Gallagher Securities or our and their respective affiliates or their affiliates' respective directors, officers or employees. Final terms and conditions may change without notice and are subject to further discussions and negotiations.
We make no representations, and neither give you any advice concerning the appropriate legal treatment, regulatory treatment, accounting treatment or possible tax consequences of any indicative transactions, nor make any recommendation or advice as to the suitability of the investment. An investment is speculative, involves a high degree of risk and should be considered only by institutional investors who can bear the economic risks of their investments and who can afford to sustain the loss of their investments.
The information contained herein does not purport to be complete and is subject to certain qualifications and assumptions and should be considered by investors only in light of the same warnings, lack of assurances and representations and other precautionary matters, as disclosed herein. The information contained herein should not be relied upon for the purposes of making an investment or entering into any transaction. Recipients should request any additional information they deem necessary or desirable on making an informed investment decision. Information from third parties regarding the investment has not been independently verified by us.
United Kingdom: In the United Kingdom, this presentation, and any other material in relation to the investment described herein is only being distributed to, and is only directed at, persons that are (i) investment professionals falling within Article 19(5) of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (as amended) (the "Order") and / or high net worth entities or other persons falling within Article 49(2)(a) to (d) of the Order and (ii) meet the definition of a "qualified investor" within the meaning of Article 2(1)(e) of EU Directive 2003/71/EC, or (iii) any other person to whom an invitation or inducement to engage in investment activity in connection with the issue or sale of the investment may otherwise lawfully be communicated or caused to be communicated by virtue of Section 21(1) of the Financial Service and Markets Act 2000 (all such persons together being referred to as "Relevant Persons"). In the United Kingdom, any investment or investment activity to which this presentation and any other material in relation to the investment described herein relates will be engaged in only with, Relevant Persons. This presentation, should not be distributed, published or reproduced (in whole or in part) or disclosed by recipients to any other person in the United Kingdom. Any person in the United Kingdom that is not a Relevant Person should not act or rely on this presentation, and any other material in relation to the investment described herein or any of their respective contents. United States: For the purpose of distribution in the United States, this presentation is only intended for "Major US Institutional Investors" as defined in Rule 15a-6 under the US Securities Exchange Act of 1934, as amended. Any U.S. person receiving this presentation and wishing to effect a transaction in the investment (to the extent ultimately offered and sold) must do so through a U.S. registered broker-dealer. European Union: this presentation is reserved for professional clients as defined by the European Directive 2014/65/EC dated 15 May 2014 (MiFID II), acting in their own name and on their own behalf. This presentation is solely for discussion purposes with such professional clients and is not for general public distribution and this presentation should not be distributed, published, reproduced or disclosed by recipients to any other person in the European Union.
Gallagher Securities and its affiliates provide services to multiple clients, including insurance companies and other services to competitors whose interests might conflict in the future.
Gallagher securities can have in its possession non-public information regarding other companies that could potentially be of relevancy. This information is material and can not be shared.
Gallagher Securities may place advertisements in financial and other publications and media at its own expense describing its services to the company hereunder
Companies engaging in business will not public refer to Gallagher securities or its engagements with Gallagher securities without prior written consent from Gallagher securities

12. View Gallagher Securities Regional Privacy Notices by Country and Language

Select your country to see the Global Privacy Notice and country addendum (if applicable) in your local language.

Australia — English
Canada — English
United Kingdom — English
United States — English