This Enlightenment Text is provided by Gallagher Sigorta ve Reasürans Brokerliği A.Ş. ("Gallagher", "Our Company", "we", "us" or "our") as a controller within the scope of Article 10 of the Personal Data Protection Law and the Communiqué on the Procedures and Principles to be Complied with in Fulfilling the Obligation to Inform. Our Company is part of the Arthur J. Gallagher global group of companies.

Please kindly note that as a registered insurance and reinsurance broker in Türkiye, Our Company has legal secrecy obligation as stated in Article 31/A of Insurance Law No. 5684 dated 3/6/2007.

The execution of insurance or reinsurance contracts in Turkey and intermediation thereof as an insurance and reinsurance broker are subject to the Insurance Law No. 5684 dated 3/6/2007 and its related legislation, the Turkish Commercial Code No. 6102 dated 13/1/2011 and the provisions of private law.

This enlightenment text describes how Gallagher collects and processes personal data about prospective, present and past clients ("you", "your"), our lawful basis for processing, to whom and what purposes that data may be transferred and any rights you may have in relation to your personal data.

Purposes and legal grounds of personal data processing

Gallagher processes your personal data for below purposes within the scope of carrying out our insurance and reinsurance brokerage and risk consultancy activities as per the Regulation on Insurance and Reinsurance Brokers based on the following legal grounds:

Purposes of Processing

Legal Grounds for Processing

To perform services for you or our clients.

For the performance of contracts to which you will be a party and in order to take steps at your request prior to you entering into those contracts; or

As prescribed by laws; or

For the purposes of legitimate interests pursued by us (to perform and enter into services for our clients).

To manage our business operations.

To comply with a legal or regulatory obligation to which we are subject; or

For the performance of contracts to which you will be a party and in order to take steps at your request prior to you entering into those contracts; or

For the establishment, exercise or protection of a right; or

For the purposes of legitimate interests pursued by us (to manage our business operations).

To communicate and market to you.

Your consent to this processing; or

For the purposes of legitimate interests pursued by us (to communicate and market to you where we do not require your consent).

To comply with legal obligations.

To comply with a legal or regulatory obligation to which we are subject; or

For the purposes of legitimate interests pursued by us (to defend or protect our legal rights).

To monitor and prevent fraud or wrongdoing.

To comply with a legal or regulatory obligation to which we are subject; or

For the performance of contracts to which you will be a party and in order to take steps at your request prior to you entering into those contracts; or

For the purposes of legitimate interests pursued by us (to monitor and prevent fraud or wrongdoing).

To improve our services.

For the purposes of legitimate interests pursued by us (to improve our services).

To manage mergers, acquisitions, sales, re-organizations, disposals and integrations.

For the purposes of legitimate interests pursued by us (to manage mergers, acquisitions, sales, re-organizations, disposals and integrations).

We process sensitive personal data, including your health data in order to provide our services and for other purposes described above. Our legal basis for processing sensitive personal data will be one of the following:

  • As prescribed by law, in cases where the establishment and performance of your insurance contract or the settlement of the claim process as prescribed by the Turkish Commercial Code No. 6102 and the Insurance Law No. 5684 require the processing of sensitive personal data.
  • As necessary for the establishment, exercise and protection of a right; in cases of the establishment, exercise and protection of your or our legal rights.
  • You have given us your explicit consent, where we receive sensitive personal data indirectly that is not covered above, the third party (for instance your employer) is responsible for obtaining your explicit consent to enable us to collect and use your data for the purposes described within this enlightenment text.

You can find the details of your processed personal data and the purposes of processing here.

Methods for the collection of your personal data

Gallagher collects your personal data on the website or by means of written, verbal, video, electronic, online communication and sometimes partially or completely using automatic tools and methods, from you or someone else acting on your behalf; your employer, another broker and insurers, third parties involved in the insurance process, the policyholder, third parties in claims processes, third parties that can introduce Our Company to clients, other companies within the Arthur J. Gallagher group, credit reference organisations, insurance industry fraud prevention and detection databases and sanctions screening service providers, government agencies and professional regulatory agencies.

To whom and for what purpose personal data can be transferred

In order to provide you services and for the other above-mentioned purposes Gallagher will transfer your personal data, including sensitive personal data within and outside Turkey to other companies within the Arthur J. Gallagher group, other insurance intermediaries, insurers, reinsurers or other companies operating in the insurance distribution channel, other brokers or parties acting directly on your behalf and contacting Our Company to arrange for an insurance policy for you, to third parties (accountants, auditors, lawyers and other experts) who assist Our Company regarding the management of insurance policies, insurance brokerage platform providers, fraud detection agencies and other third parties that operate and maintain fraud detection registries, regulators, law enforcement agencies, government agencies and institutions, other insurers of our own insurance, authorized institutions of the insurance industry, credit reference organizations, contracted third party service providers (information technology suppliers, finance and payment providers, actuaries, auditors, lawyers, marketing agencies, document management providers, tax consultants, debt collection agencies and insurance software providers) and selected third parties in connection with the sale, transfer or liquidation of our business, and to domestic and international servers due to information technologies that these parties can use, or to the cloud in cases where cloud computing is used.

Transfers will be made in accordance with applicable law. Where required by law we will obtain your explicit consent for such transfers, but in cases where we receive data indirectly from third parties, such as your employer, we rely on their confirmation of obtaining your explicit consent, if required, before transferring the data to us. In relation to your insurance transactions, since the situations in which we need to transfer to insurers, reinsurers, brokers, actuaries and loss adjusters located in Turkey and abroad, which may differ according to the placement structure of your policy, are prescribed by the Turkish Commercial Code No. 6102 and the Insurance Law No. 5684, your explicit consent will not be sought except for situations outside this scope and where we would not rely on any other legal ground.

Rights of the data subjects

In accordance with the provisions of Article 11 of the Law, you have the following rights regarding your personal data:

  • Learning whether your personal data is processed,
  • If your personal data is being processed, obtaining information about them,
  • To learn what is the purpose of processing your personal data and whether your personal data is used in accordance with its purpose,
  • Learning who the third parties are, if any, to whom the personal data is transferred at home or abroad, and which personal data is transferred,
  • Requesting correction of the processed personal data if it is incomplete or incorrect,
  • Requesting the deletion or destruction of your processed personal data, in case the reasons for the processing of your personal data disappear or your personal data loses its accuracy,
  • In case of correction, deletion or destruction of your personal data, requesting the notification of these processes to the third parties to whom your personal data has been transferred,
  • Objecting to the emergence of a result against you by analysing your processed personal data exclusively through automated systems,
  • You have the right to demand the compensation of the damage if you suffer damage due to unlawful processing of your personal data.

You can submit your requests to Our Company by contacting us :

Address: Emaar Square, Ünalan Mh. Libadiye Cad. No: 82-F Kat: 30, Emaar, 34700, Üsküdar / İstanbul
Telephone: +90 216 401 29 29
Fax: +90 216 401 29 30
E-mail: info-turkey@ajg.com

Your requests will be answered as soon as possible and within thirty days at the latest, depending on the nature of the request, and free of charge if the transaction does not require any additional cost.