Cunningham Lindsey is committed to protecting the privacy of Personal Data we collect and process in conducting our business. “Personal Data” is information that identifies to you or other individuals (such as your dependants). This Privacy Policy describes how we will handle Personal Data that we collect through:

• Our websites (the “Site”)
• Software applications made available through computers and mobile devices (the “Apps”)
• Claims management process:
  • Claim forms, telephone calls, e-mails and other communications with us, as well as from claim investigators, medical professionals, witnesses or other third parties involved in our business dealings with you

Collectively referred to as the “Services”.

We collect and process your Personal Data in accordance with this Privacy Policy which also includes details about our use of website cookies.

3.1 Who to contact about your Personal Data

If you have any questions about our use of your Personal Data you can e-mail: privacy@clglobal.com or write to:

           Michael D. Finch

Chief Privacy Officer Cunningham Lindsey Corporate

2711 LBJ Freeway, Suite 900 Dallas

Texas

75234 United States

4.1Personal Data We Collect And Process

Personal Data collected about you and your dependants may include: General identification and contact information

• Your name, address, e-mail and telephone details, gender, marital status, family status, date and place of birth, educational background, physical attributes, activity records, driving records, photos and video images, employment history, skills and experience, professional licenses and affiliations, relationship to the policyholder, insured or claimant, and date and cause of death, injury or disability
• Identification numbers issued by government bodies or agencies – Social Security or national insurance number, passport number, tax identification number, military identification number, or driver’s or other license number

Financial information and account details

• Bank account number and account details, credit history and credit score

Medical condition and health status

• In certain cases we may receive information about your current or former physical or mental or medical condition, health status, injury or disability information, medical procedures performed, personal habits (for example, smoking or consumption of alcohol), prescription information and medical history.

Other sensitive information

• In certain cases we may receive sensitive information about your trade union membership, religious beliefs, political opinions, family medical history or genetic information (for example, if you apply for insurance through a third-party marketing partner that is a trade, religious or political organisation). In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud.
• We may also obtain sensitive information if you voluntarily provide it to us (for example, if you express preferences regarding medical treatment based on your religious beliefs).

Telephone recordings

• Recordings of telephone calls to our staff and offices.
• Information to investigate crime, including fraud and money laundering: For example, insurers commonly share information about their previous dealings with policyholders and claimants for this purpose.

Information enabling us to provide our services

• Location and identification of property insured (for example, property address, vehicle license plate or identification number)
• Travel arrangements including reservation numbers, destination and hotel details
• Policy details and claim numbers, coverage/peril details and cause of loss
• Prior accident or loss history, your status as director or partner or other ownership or management interest in an organisation and other insurance you hold.

Marketing preferences and customer feedback

• You may let us know how you want to be contacted

4.1How we use your Personal Data

We use this Personal Data to:

• Communicate with you and other interested parties to manage your claim.
• Send you important information regarding your claim and other administrative information.
• Make decisions about claim assessment, processing and settlement.
• Where applicable manage claim disputes.
• Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers).
• Prevent, detect and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks.
• Carry out market research and analysis, including satisfaction surveys.
• Manage our business operations to comply with internal policies and procedures, including those relating to auditing finance, accounting and billing, IT systems, data and website hosting, business continuity, document and print management.
• Resolve complaints, and handle requests for data access or correction.
• Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and comply with legal process and respond to requests from public and government authorities (including those outside your country of residence).
• Establish and defend legal rights, protect our business operations (including our group companies), our rights, privacy, safety of employees and property, you or others related to the claim and pursue available remedies to limit our damages.

4.2International Transfer of Personal Data

Due to the global nature of our business, for the purposes set out above we may transfer Personal Data to parties located in other countries (including the United States and other countries that have a different data protection regime than is found in the country where you are based). For example, we may transfer Personal Data in order to process international travel insurance claims and provide emergency medical  assistance services when you are abroad. We may transfer information internationally to our group companies, service providers, business partners and governmental or public authorities.

4.3Sharing of Personal Data

Cunningham Lindsey may make Personal Data available to the following parties for the purposes of claim assessment or as required by law:

• Our group companies
• Other insurance and distribution parties
  • In the course of processing claims, we may make Personal Data available to third parties such as reinsurance brokers, appointed representatives, distributors, financial institutions, securities firms and other business partners
• Our service providers
  • External third-party service providers, such as medical professionals, accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; travel and medical assistance providers
• IT systems, support and hosting service providers, document and records management providers and outsourced service providers that assist us in carrying out business activities.
• Banks and financial institutions that service our accounts, third-party claim administrators, claim investigators, construction consultants, engineers, examiners, jury consultants, translators and similar third-party vendors
• Authorities and third parties involved in court action
  • We may share Personal Data with government or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third- party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate:
    • to comply with applicable law and regulations, including those outside your country of residence
• to comply with legal process
• to respond to requests from public and government authorities including public and government authorities outside your country of residence
• to protect our operations or those of any of our group companies
• to protect our rights, privacy, safety or property, and/or that of our group companies, you or others
• to allow us to pursue available remedies or limit our damages.
• Other Third Parties

• We may share Personal Data with emergency providers (fire, police and medical emergency services); retailers; medical organisations and providers; travel carriers; credit bureaus; credit reporting agencies; and other people involved in an incident that is the subject of a claim; as well as purchasers and prospective purchasers or other parties in any actual or proposed reorganisation, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business. To check information provided, and to detect and prevent fraudulent claims, Personal Data (including details of injuries) may be put on registers of claims and shared with other insurers. We may search these registers when dealing with claims to detect, prevent and investigate fraud.

We may also anonymise, aggregate or combine any of the information we collect to analyse trends and provide statistical data to assist with forward planning of business operations

5.0 Security of Personal Data

We will take all appropriate reasonable technical, legal and organizational measures, which are consistent with applicable privacy and data security laws to safeguard your Personal Data. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Data you might have with us has been compromised), please immediately notify us.

Where we provide Personal Data to a service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of your Personal Data.

5.1Accuracy of Data

We take all reasonable steps to ensure that Personal Data we process remains  accurate and complete as is necessary for the performance of our services to you and in line with the controls detailed in this Privacy Policy.

5.2Retention of Personal Data

We will retain Personal Data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

5.3Personal Data of other Individuals

If you provide Personal Data to us regarding other individuals, you agree:

• to inform the individual about the content of this Privacy Policy
• to obtain any legally-required consent for the collection, use, disclosure, and transfer (including cross-border transfer) of Personal Data about the individual in accordance with this Privacy Policy.

We do not seek or knowingly collect any Personal Data from children under the age of 13 and we request that children do not provide us with any personal information through the Site or the Apps.

5.4Access and Correction Requests, Questions or Concerns

In certain countries, an individual may have the right to access, correct or object to the use of, or request deletion or suppression of Personal Data on certain grounds. Please contact us as set out in the “Who to Contact About Your Personal Data” section above with any such requests or if you have any questions or concerns about how we process Personal Data. Please note that some Personal Data may be exempt from access, correction, objection, deletion or suppression rights in accordance with local privacy and data protection laws.

5.5Other Information We Collect

“Other Information” is information that does not reveal your specific identity, such as:

• App usage data
• Information collected through cookies, tags and other technologies

We and our third party service providers may collect “Other Information” in a variety of ways, including:

• Through your use of the App: When you download and use the App, we and our service providers may collect App usage data, such as the date and time the App on your electronic device accesses our servers and what information and files have been downloaded to the App based on your device number.
• Using cookies: Cookies are pieces of information stored directly on the computer you are using. We use the following cookies:
  • Cookie Name
• Google Analytics _gat, _ga

These 2 cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

5.6Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our group companies. Before providing any Personal Data to any such linked website, please make sure to review that website’s privacy policy carefully to understand how it deals with your Personal Data.

Legal notice
 

None of the information on our site is a substitute for professional advice concerning particular circumstances. Inadvertent errors can occur on the website and applicable laws, rules and regulations often change. This site is provided “as is” and without any warranties, express or implied. Cunningham Lindsey, including its directors, affiliates, officers, employees, agents, contractors, successors and assigns, will not accept any liability for any loss, damage or other injury resulting from its use.

Nothing in this website constitutes or is intended to constitute an offer of, or an invitation to purchase or subscribe for, securities. Cunningham Lindsey grants you a limited licence to download this website for personal use only. You are not permitted to reproduce or alter this website, or any copy of it, for any other purpose without the prior express written consent of Cunningham Lindsey. All copyright in the website belongs to us.

Cunningham Lindsey reserves the right to make changes, modifications, additions, deletions and corrections to the website at any time and without notice. In the event of dispute all matters will be subject to the laws within that jurisdiction. The Cunningham Lindsey name and logo is a registered trademark and it cannot be used or reproduced without our consent.

Cunningham Lindsey only collects identifiable information that is specifically and voluntarily provided by a visitor to this site. A visitor may choose to provide information to register for certain areas of the site, apply for a job, or order or download a publication. This type of identifiable information is used solely for the purposes for which it was provided. Cunningham Lindsey regards your privacy as important and will take all reasonable steps to ensure that if you have subscribed to receive notification of website updates, your details will remain confidential. We do not share personally identifiable information with third parties, unless required by law, or unless explicitly requested by a visitor. We take all reasonable measures to protect your information while it is in our care.

Any external links to other websites have been provided for your convenience. Websites which you are transferred to are not controlled by Cunningham Lindsey and Cunningham Lindsey will not be responsible and does not accept any liability for the information contained on those websites. The provision of a link does not constitute an endorsement or approval of that website or any products or services offered on that website.

Security and Storage

Cunningham Lindsey places great emphasis on the security of all information   associated with our customers, clients, intermediaries and contractors. Our security measures in place attempt to protect against the loss, misuse and alteration of personal information under our control. Personal information is de-identified or destroyed securely when no longer required by us. Cunningham Lindsey retains the information you provide to us, including possibly your contact and payment details, to enable us to verify transactions and customer details and to retain adequate records for legal and accounting purposes. No data transmission over the Internet can be guaranteed to be 100 per cent secure. As a result, while we strive to protect user’s personal information, Cunningham Lindsey cannot ensure or warrant the security of any information transmitted to it or from its online products or services, and users do so at their own   risk. Ultimately, you are solely responsible for keeping your passwords and/or account information secret. You should be careful and responsible whenever you are online.

Data Protection

Cunningham Lindsey handles a large amount of information including details about individuals as part of its claims handling activities. Cunningham Lindsey adheres to all relevant Data Protection Laws in the jurisdiction in which they apply, together with adhering to a general principle of privacy worldwide.

We are part of a global business and the information we hold may be transferred overseas or shared with other organisations worldwide in order to perform our work. However, we only share information with organisations that have comparable levels of protection, security and confidentiality.

To combat financial crime and money laundering, we are obliged to make enquires  when dealing with claims. As part of the validation process we may check with other parties including credit reference agencies and data providers. We also share claim data within the insurance market but only through recognised schemes designed to combat financial crime. Details may also be passed to parties assisting with a claim but any personal data will be treated as confidential and will not be used for other purposes.