When you use our Services, we may automatically collect information about your Internet service provider, your operating system, browser, type, domain name, Internet protocol (IP) address, your access times, geolocation of your device, the website that referred you to us, the pages and aspects of the Services you requested, and the date and time of those requests.
Additionally, we may collect the following information, which, in addition to the above, is considered personal information:
Contact information: may include name, email, physical address, general geographic location, social media handle or phone number.
Unique identifiers: may include passport number, driver’s license number, or any other identifying documentation issued by a federal, state, or local agency.
Demographic details: may include your date of birth, age, gender, race, image, marital status, background information, or insurance requirements.
Employment information: may include job title, employee number, employment status, salary, background information, or health and wellness benefits. If you apply for employment with us, we will collect personal information related to your potential employment, including your education and employment history, address and contact information, and any other information included in your application.
Health information: may include medical records, health status, medical outcomes, claim summaries, and other information which may or may not be regulated under the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
Benefits information: may include benefit elections, claims made under your applicable benefit programs or insurance policies, retirement information, employment information, contribution summaries, and other voluntary information relating to your health and wellness benefits.
Financial information: may include credit history, salary, tax information, deductions, benefits data, and insurance contribution or payout information.
Claims information: may include claim summaries, background information, driving/motor vehicle records (MVRs), credit reports, medical files, or other necessary documentation.
Communication information: may include personal information contained within your communications with us via email, social media, telephone, or otherwise, and in certain cases we may use third-party service providers to do so. Where permitted by applicable law, we may collect and maintain records of calls and chats with our agents, representatives, or employees.
Finally, we may also collect certain marketing information you provide in connection with any marketing campaigns, events, or seminars hosted by us. Such information may include information about the Services you’ve used, indication of your interest in our Services, comments, feedback, or other forms of interaction that may occur through said marketing campaigns, events, or seminars. We will also make note of your communication preferences.
Personal Information Provided by You or Third Parties to Us
We collect personal information that you provide to us directly, for example, if you choose to contact us, request information from us, or otherwise utilize our website or Services. Depending on the Services being provided, we may obtain your personal information from third parties such as our vendors and service providers (including to confirm and supplement information you provide to us directly), your employer, your health plan, applicable insurance carriers, and our motor vehicle record (MVR) providers.
Cookies and Other Tracking Technologies
We and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Services. The technologies we use for this automatic data collection may include cookies and web beacons that permit us to verify system and server integrity and generate statistics around the popularity of certain content. We process the information collected through such technologies, which may include or be combined with personal information, to help operate certain features of our Services, to enhance your experience through personalization, and to help us better understand the features of our Services that you and other users are most interested in.
We may use third-party providers to enable certain customer interaction opportunities, content delivery (like audio or video), or other service capabilities. For example, we partner with service providers to host our website and deliver specific content in support of our Services. For example, we use Adobe Typekit to serve fonts on our Site, which is governed by Adobe Typekit’s Privacy Policy. We also partner with companies like Vimeo to deliver specific content delivery like audio and video.
We also use analytics services including Google Analytics that uses cookies and other technologies that collect your personal information to assist us with analyzing our site traffic usage to optimize, maintain, and secure our Site and inform subsequent business decisions. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data from sites or apps that use our services.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.
Interest-Based Advertising – We may also allow or enable third parties to collect personal information to provide their interest-based advertising on behalf of our products and services, or their own. Interest-based advertising occurs when advertisements are shown to you based on information collected from your online interactions over time and across multiple websites, devices, or online services that you visit or use. Some companies may engage in cross-context behavioral advertising to predict your preferences and show you advertisements that are most likely to be of interest or relevant to you.
We do not control these third parties’ collection or use of your information for these purposes, or the opt-out options they may individually offer you via their terms, conditions, and privacy policies. If you have any questions about an advertisement or other targeted content, you should contact the applicable provider directly. Examples of the third-party service providers we engage to serve interest-based advertisements include Google Ads (including Google Signals and Google Marketing Platform). It is in this context that we may provide advertising networks, data analytics providers, social networks, and video sharing platforms with personal information as your IP address, device information, Internet and other electronic network activity information, and geolocation information in the last twelve months.
Selling Personal Information – While we do not sell personal information in exchange for monetary consideration, we do disclose personal information for other benefits that could be deemed a “sale” under various data protection laws because it is sometimes broadly defined to include activities such as the delivery of interest-based advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior.
Cookie Choices – To manage your preferences with respect to these technologies, you can:
- Change your cookie preferences by clicking the cookie icon in the bottom left-hand corner of our website or customizing your browser settings to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable certain cookies, please note that some parts of our Site may not function properly. These settings may be lost and require reconfiguration if you delete your cookies.
- Block the collection and use of your information by online platforms and ad tech companies for the purpose of serving interest-based advertising by visiting the opt out pages of the self-regulatory programs of which those companies are members: National Advertising Initiative and Digital Advertising Alliance. Please note that even if you opt out of interest-based advertising, you may still see “contextual” ads which are based on the context of what you are looking at on the websites and pages you visit.
- Review and execute any provider-specific instructions to customize your preferences or opt-out of certain processing, including interest-based advertising, by third-party service providers. For example, to opt-out of this type of advertising by Google, customize your ad preferences, or limit Google’s collection or use of your data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions.
How We Use Personal Information
To the extent permitted by applicable law, we use personal information as outlined in this Privacy Notice including:
- To contact you, such as responding to your requests (e.g. surety bond requests) or questions and comments, or notifying you of changes to our Services.
- To provide our Services, including risk management, property & casualty insurance, employee benefits, claims management, and other specialized programs.
- To improve our marketing and promotional efforts, to analyze site usage, and to improve our content, layout, and Services. Information collected automatically through cookies may be combined with your previously submitted personal information. We may also use Personal Information to conduct interest-based advertising as discussed in the Cookies and Other Tracking Technologies section above.
- To meet our legal and regulatory obligations, to protect our and our clients’ safety, property, or rights, enforce our terms, conditions, and policies, detect and prevent security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity.
- As part of a corporate transaction, such as in connection with the sale of part or all of our assets or business, the acquisition of part or all of another business or another business’ assets, or another corporate transaction, including bankruptcy.
- To fulfill any other purpose for which you provide it, including purposes described when provide information or give your consent.
If you are applying for employment with us, we also use personal information to process your job application, to verify the information you have provided in your application, conduct interviews, perform background and reference checks, to communicate with you and answer your questions, to confirm your eligibility for employment, and improve our recruiting processes. We may also save your personal information for future employment opportunities with us.
How We Disclose Personal Information
We may disclose aggregated information about our clients, and information that does not identify any individual, without restriction.
We may disclose your personal information with your consent, as required by law, to provide our Services, or as identified in this Privacy Notice. Your personal information may be shared with our affiliates, agents or service providers, in a business transfer, or in certain legal matters which require such disclosure.
We may disclose your personal information to insurance carriers, risk management agencies, legal advisers, accountants, auditors, insurance adjusters, claim investigators, third party administrators, medical professionals, law enforcement bodies, or regulators and government bodies.
We may share or make available limited personal information (such as mobile device identifiers) with ad tech companies and other online service providers. When we share your personal information in this context, we follow applicable legal requirements, which may require that we provide opt-out rights or other individual rights.
Additionally, we may disclose your personal information to third parties when explicitly requested by or consented to you, or for the purposes for which you disclosed the personal information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
Your Privacy Rights
Depending on where you are located, you may have certain rights with respect to your personal information, including the right to:
- Confirm whether we process your personal information and obtain a copy of any personal information we may have;
- Delete personal information that we have collected or obtained, subject to certain exceptions;
- Request that we correct any inaccuracies in your personal information, subject to certain exceptions; Opt out of personal information processing for targeted advertising and sales;
- Limit the use of your sensitive personal information (if applicable); and
- Know when you are subject to automated decision-making, the personal information used to render the decision, the principal factors and parameters involved in the decision, and human review or correction of the decision (or its underlying data, where appropriate). You may also have the right, depending on your location, to consent or opt out of (a) this automated decision-making or (b) any profiling in furtherance of decisions that produce legal or similarly significant effects (if applicable); and
- Lodge complaint with a regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to reach out to us first so we have an opportunity to address your concerns directly before you do so.
To exercise any of the privacy rights afforded to you under applicable data protection laws, please e-mail us at [email protected] or call (800) 247-7756. You may also exercise your opt out rights by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC). We honor Opt-Out Preference Signals, including GPC. If you choose to use an Opt-Out Preference Signal, you will need to turn it on for each supported browser or browser extension you use.
You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Notice. However, if you choose not to provide certain personal information, we may be unable to provide some, or all, of our Services to you.
Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your personal information. We may need to verify your identity before fulfilling certain requests, and if we cannot verify your identity, we may request additional information from you. If you are an authorized agent making certain requests on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or evidence of power of attorney. We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.
We do not charge a fee to process or respond to your requests unless they are excessive or repetitive. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you may submit an appeal by emailing [email protected] or calling (800) 247-7756.
California Residents
This section provides additional information regarding our practices pursuant to the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (“CCPA”), where “Personal Information” has the definition set forth in the CCPA.
Please see the chart for detailed information about the categories of Personal Information we have collected from California residents during the twelve months preceding the date on which this Notice was last updated and the categories of third parties to whom we Sell or Share Personal Information (as those terms are defined in the CCPA). For each category of Personal Information set forth in the chart below, the categories of third parties to whom we disclose it for a business or commercial purpose are set forth in the How We Disclose Personal Information section above.
| Personal Information Category set forth in Cal. Civ. Code § 1798.140 |
Categories of Third Parties to Whom We Sell or Share Personal Information |
| Personal identifiers, including real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. |
Third-party marketers and other third parties that set cookies and other online tracking technologies on our website.
|
| California Customer Records Personal Information (Cal. Civ. Code § 1798.80(e)), including name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, etc. |
We do not Sell or Share this category of Personal Information.
|
| Characteristics of protected classifications under California or federal law. This may include age, veteran status, accommodations information, gender identity and expression, sexual orientation, and religion.
|
We do not Sell or Share this category of Personal Information. |
| Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|
Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our website. |
| Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information about individual interactions with an Internet website, application, or advertisement. |
Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site. |
| Geolocation data, such as your IP address. |
Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our website.
|
| Sensory data including audio, electronic, visual, thermal, olfactory, or similar information. |
We do not Sell or Share this category of Personal Information. |
| Professional or employment-related information. |
Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our website. |
| Non-public education information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 C.F.R. Part 99) |
We do not Sell or Share this category of Personal Information. |
| Inferences drawn from any of the information categories to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
|
We do not Sell or Share this category of Personal Information. |
| Sensitive Personal Information as set forth in Cal. Civ. Code § 1798.140, including social security number, driver’s license number, state identification card, or passport number; citizenship or immigration Information; racial or ethnic origin; account access credentials (like usernames or account numbers combined with password or other security/access code to access an account). |
We do not Sell or Share this category of Personal Information. |
California Shine the Light – Under California Civil Code Section 1798.83, individuals who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of Personal Information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please contact us at [email protected]. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.
Links to Other Websites
Our Services may have links to other websites that are not operated by us. If you visit one of these linked websites, you are then subject to the policies of the owner of the linked website. We are not responsible for the contents of those websites and have no control over what information they may or may not collect from you. We encourage you to investigate and ask questions before disclosing personal information to third parties, since any personal information disclosed will be handled in accordance with the applicable third party’s privacy policy.
In some cases, we offer links to social media platforms (Facebook, Instagram, X, LinkedIn, and Handshake) that enable you to easily connect with us or share information on social media. Any content you post via these social media pages is subject to the terms of use and privacy policies of those platforms.
Data Security and Retention
We take reasonable steps to maintain physical, technical, and administrative security of any information you provide to use in order to protect the confidentiality, integrity, and availability of the information and ensure that such information is processed in accordance with applicable privacy laws. Unfortunately, the transmission of information via the internet is not completely secure. Despite these efforts to store personal information in a secure environment, we cannot guarantee the security of personal information during its transmission or its storage on our systems.
We retain your personal information for as long as needed: (i) to provide our Services to you; (ii) fulfill the purposes outlined in this Privacy Notice; and (iii) to comply with our legal obligations, resolve disputes, and enforce any agreements. Criteria we will use to determine how long to retain your personal information include the nature and length of our relationship with you; our legal rights, obligations, and retention requirements; and if we have an ongoing business purpose for retaining your personal information, such as communicating with you about ongoing or prospective Services.
Use by Children
We will not knowingly allow anyone under the age of thirteen (13) to provide us any personal information online. Holmes Murphy cares about protecting the privacy of children and believes children should always have the permission of their parents before transmitting any personal information over the internet. If we learn that we have collected personal information from a child, we will promptly take steps to delete that information. If you believe we might have any information from or about a child, please contact [email protected].
Compensation Disclosure
Holmes Murphy and its affiliates receive compensation from insurance carriers and other third-party vendors for services provided through the receipt of commissions and profit-sharing arrangements. Profit-sharing payments from insurance carriers are based on the profitability and/or premium growth of all the business Holmes Murphy or its affiliates has with an insurance carrier and is not determined solely by the profitability of your account.
International Users
If you are visiting our website or otherwise using our Services from outside of the United States, please be aware that we are based in the United States and that our website is hosted in the United States. Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Privacy Notice.
Changes to this Privacy Notice
Please note that we may modify or update this Privacy Notice from time to time, so please review it periodically. If we make material changes to how we treat personal information, we will notify you according to applicable law. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to our website. You are responsible for periodically visiting our website and this Privacy Notice to check for any changes.
Questions or Concerns
If you have any questions, concerns, or complaints about this Privacy Notice, they should be directed to Holmes Murphy at [email protected] or call (800) 247-7756.
