MARSH & McLENNAN COMPANIES

MMC Website California Resident Privacy Notice

Effective: June 30, 2020

 

 

Scope

This California Resident Privacy Notice supplements the MMC Website Privacy Statement and applies to California residents’ personal information collected in relation to the Site.

What is Personal Information?

In this California Resident Privacy Notice, "personal information" has the same meaning as under the California Consumer Privacy Act (“CCPA”): information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  Personal information does not include information that is de-identified or aggregated.

Personal Information MMC Collects

We collect the following types of information in connection with this Site:

·       Unique identifiers (such as your name or an ID number)

·       Contact information (such as telephone number, email address, or mailing address)

·       Professional information (such as company and title)

·       Commercial information (such as your communication preferences, survey data, or other information you provide in order for us to respond to your inquiry)

·       Audio, video, or visual information (such as a recording of your voice or image if you participate in a corporate event- you will always be notified of any recording in advance)

·       Individual profile information (such as your dietary preferences if you register for an event with a meal)

·       Internet and technical information (such as your IP address, device identifiers, browser type, ISP, and data from cookies and web beacons)

Sources of the Personal Information We Collect

We collect personal information used in relation to this Site from the following sources:

·       Directly from you (e.g., through a submission you make on our “Contact Us” page or when registering for an event)

·       From Third Parties acting on your behalf (e.g., your employer when it provides information about you in connection with a corporate event)

·       From first and third party cookies that help us operate and assess the Site (see our “Cookies” section below for more information)

Our Business or Commercial Purposes for Collecting, Using and Disclosing Personal Information

We collect, use, and disclose your Personal Information for the following purposes:

·       To provide you with a requested service

·       To verify your identity and registration

·       To communicate with you in response to your inquiry or a requested service

·       To gather your feedback or survey responses

·       To host corporate events on behalf of MMC and our affiliates

·       For MMC’s and our affiliates marketing and analytics purposes

·       To administer, assess, personalize, and improve our Site and services

·       To conduct research, statistical analysis, survey/demographical interpretation, and other data studies based on the data collected

·       To maintain network security and performance and protect against cyber-attacks

·       To comply with and enforce applicable laws, industry standards, and our own policies and terms

·       For auditing, reporting, corporate governance, and internal operations

·       For due diligence and implementation of commercial transactions, including reorganizations, mergers or other disposition of all or any portion of our business, assets or stock

·       To exercise and defend legal rights

·       As otherwise described to you at the point of collection or pursuant to your consent

Categories of Third Parties With Whom We Share Personal Information

We may share your personal information with:

·       Affiliates to enable them to provide services to you and to enable them to contact you regarding additional products and services that you have expressed an interest in.

·       Agents and services providers who perform services for on our behalf, such as hosting this Site, sending communications, operating a call center, or hosting/managing corporate events.

·       Third parties involved in events you register for, including physical and virtual sites that host the event.

·       With your employer, to the extent you are 

·       Any entity that acquires all or a portion of our business, assets, or stock, including in connection with a merger, reorganization, or other commercial transaction.  In such transactions, user information generally is one of the transferred business assets. Also, if either MMC or any of MMC’s assets are acquired (including through bankruptcy proceedings), your personal information may be one of the transferred assets.

·       Authorities, subject to applicable laws, including to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence.

Our third-party affiliates, service providers and successors to whom we disclose information are required by law and/or contractual requirements to keep your personal information confidential and secure. These parties may not use or disclose it except as reasonably necessary to provide services to you or as otherwise permitted by law. 

We may also use or share de-identified information that is not reasonably likely to identify you for commercially legitimate business purposes with our affiliates, service providers, and business partners. 

We do not sell personal information to any third parties, and have not done so in the preceding 12 months. As we explain in our Privacy Policy, we and our third-party partners use cookies and other tracking technologies to analyze website traffic and facilitate marketing or advertising.  You can learn more about the cookies utilized on this Site and opt-out of our and our third-party partners’ use of certain cookies using our Cookie Management tool

Children’s Personal Information

We do not knowingly collect personal information from children under 13.  If we learn that we have collected any personal information from a child under the age of 13 without verifiable parental consent, we will delete that information from our files as quickly as possible.  If you believe that we may have collected information from a child under 13, please contact us at the email address provided below.

We never sell the personal information of minors under 16 years of age, and would not do so in the future without affirmative authorization of the consumer if between 13 to 16 years of age, or the parent or guardian of a consumer less than 13 years of age.

Your Rights as a California Resident

Under California law, some California residents have specific rights regarding their personal information.  These rights are subject to certain exceptions as described below.  Further, if you are a current, former, or prospective employee or if we have collected or processed your personal information in connection with our business with a company, partnership, sole proprietorship, nonprofit or government agency, and you are an employee, owner, director, officer, or contractor of that entity, rights 1-3 below are not available to you until at least January 1, 2021.

When required, we will respond to most requests within 45 days, unless it is reasonably necessary for us to extend our response time.

1.Right to Disclosure of Information

You have the right to request that we disclose certain information regarding our practices with respect to personal information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:

  • The categories of personal information we have collected about you in the last 12 months.
  • The categories of sources for the personal information we have collected about you in the last 12 months.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
  • If we sold your personal information for a business purpose, a list of the personal information types that each category of recipient purchased.
  • If we disclosed your personal information to a third party for a business purpose, a list of the personal information types that each category of recipient received.

 

2. Right to Delete Personal Information

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will determine if retaining the information is necessary for us or our service providers to:

  • Complete a transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • Comply with a legal obligation; and/or
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If none of the above retention conditions apply, we will delete your personal information from our records and direct our service providers to do the same.

How to exercise the above rights

To exercise your rights to disclosure or deletion described above, please submit a verifiable consumer request to us as follows:

·       Email: Privacy@mmc.com

·       Phone: 1-855-246-3837 (toll free)

·       “Contact Us” webform: click here

Only you or a person legally authorized to act on your behalf may make a verifiable consumer request related to your personal information. 

You may make a verifiable consumer request for access or deletion no more than twice within a 12-month period. In connection with your request, we will require you to:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.  Depending on the nature of your request and the sensitivity of the information we hold about you, we may ask you to confirm various data elements we already have on file such as your mailing address and phone number, or, in case of sensitive personal information, we may require you to submit a copy of a government issued identification.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You will not be required to create an account with us in order to submit a verifiable request, though we may communicate with you about your request via a pre-established account if applicable.  However, in order to safeguard the personal information in our possession, if we cannot verify your identity or authority to act on another’s behalf, we will be unable to comply with your request.  We will only use personal information you provide when submitting a verifiable request to confirm your identity or authority, or to fulfill your request.

3. Right to Opt out of Sales of Your Personal Information

As a California resident, you have the right to direct a business that sells your personal information to third parties not to sell your personal information.  This right is referred to as “the right to opt-out.”  Because we do not sell your personal information, we do not provide any mechanism for you to exercise the right to opt out.

4. Right to Non-Discrimination

You may exercise your rights under the CCPA without discrimination.  For example, unless the CCPA provides an exception, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We may offer you financial incentives to provide us with personal information that is reasonably related to the information’s value.  This could result in different prices, rates, or quality levels for our products or services.  Any financial incentive we offer will be described in written terms that explain the material aspects of the financial incentive program.  You must opt-in to any financial incentive program and may revoke your consent at any time by contacting us as indicated below.

5. Direct Marketing and Do Not Track Signals

Under California’s “Shine the Light” law, California residents may request and obtain a notice once a year about the personal information we shared with other businesses for their own direct marketing purposes.  Such a notice will include a list of the categories of personal information that were shared (if any) and the names and addresses of all third parties with which the personal information was shared (if any).  The notice will cover the preceding calendar year. To obtain such a notice, please contact at privacy@mmc.com. In addition, under this law you are entitled to be advised how we handle “Do Not Track” browser signals.  Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not honor Do Not Track requests at this time.