This privacy notice describes how National ethics Association ('we', 'us') may collect, handle and process personal information in relation to your access to or use of the services.
This privacy notice applies to all of the services, websites and apps offered by National Ethics Association (collectively, the "Services"), but excludes Services which have separate privacy notices that do not incorporate this privacy notice.
National Ethics Association, which provides each Service is primarily responsible for the personal information collected and held in relation to that Service. A description of National Ethics Association’s Services available and contact details for us is available here www.ethics.net
1. Personal information we use
We may collect personal information about you from a variety of sources, including information we collect from you directly (e.g., when you contact us) and from other sources, described below.
Note that we may be required by law to collect certain personal information about you, or as a consequence of any contractual relationship we may have with you. Failure to provide this information may prevent or delay the fulfillment of these obligations. We will inform you at the time your information is collected if the provision of certain personal information is compulsory and the consequences of the failure to provide such personal information.
1.1 Information we collect directly from you
Depending on the service, website or app that you are using, the categories of information that we may collect directly from you include:
We do collect personal information about your online activities over time and across third party websites or online services. When we see a browser set to "do not track", signals transmitted from web browsers do not apply to our sites, and we do not alter any of our data collection and use practices upon receipt of such a signal.
1.2 Information we collect from other sources:
The categories of information that we may collect about you from other sources are:
We may receive such information via other insurers, consumer-reporting agencies, our affiliated companies, or other third parties in the course of conducting our business.
1.3 Sensitive personal information
We may also collect certain information about you which is considered more sensitive under local applicable laws, such as:
We do not knowingly collect online information from children under the age of 13. Our services are marketed towards adults. If we are notified that we have collected personal information, as defined by the Children’s Online Privacy Protection Act ("COPPA"), of a child under the age of 13, we will delete the information as expeditiously as possible.
2. How we use your personal information and the basis on which we use it
We may use your personal information to:
Some jurisdictions require a legal basis to use or process your personal information. In most cases the legal basis will be one of the following:
3. Your rights over your personal information
You may have certain rights regarding your personal information, subject to local law. These include rights in certain circumstances to:
If you would like to discuss or exercise such rights, as applicable under local law, please contact us at the details below.
We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.
We will contact you if we need additional information from you in order to honor your requests.
4. Automated decisions about you
We may automatically process your personal information to make decisions or conduct 'profiling' about you. This may involve using software that is able to evaluate your personal aspects and predict risks or outcomes. We may carry out this automatic processing for general business purposes including, for example, advertising, risk assessment or fraud prevention. The processing may involve decisions about you that relate to products that we sponsor or your eligibility to use the Services. The significance of our actions in this connection is that is that it may have legal or similar effects for you, namely, availability of access to services. The logic involved may be related to our cookies policy, or it may be related to specific underwriting software, for example.
We will only make these kinds of automated decisions about you where:
Subject to local legal requirements and limitations, you can contact us to request further information about automated decision-making, object to our use of automated decision-making, or request an automated decision to be reviewed by a human being.
We also may make automated decisions about you based on your personal information in the circumstances such as: to select personalized offers, discounts or recommendations to send you based on your shopping history or browsing history, subject to any applicable laws or regulations.
These types of decisions will not have legal or similar effects for you, but you can still contact us for further information.
5. Information sharing
We may share your personal information with third parties for the purposes described in this privacy notice under the following circumstances:
Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the Services). See the section on "International Data Transfer" below for more information.
When required by applicable law, when we share personal information with corporate third parties we will ensure that such third parties maintain a comparable level of protection of the personal information as set out in this privacy notice by using contractual or other means. To the fullest extent permitted by applicable law, we exclude all liability arising from the use of your personal information by third parties. When required by applicable law, data transfers will be logged and documented, identifying the recipient of the data, the purpose of the transmission, and the type of data that was transmitted. Where required by law to do so, we can on request confirm the name of each third party that personal information is, or will be, transferred to.
6. Information security and storage
We implement technical, organizational, administrative and physical measures to help ensure a level of security appropriate to the risk to the personal information we collect, use, disclose and process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to help ensure the security of the processing. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.
We restrict access to your personal information to those who require access to such information for legitimate, relevant business purposes.
We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:
We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the personal information.
6.1 Secure communications
Live chat sessions on our site are encrypted to encode information that you share with our operators. By contrast, be aware that e-mail messages sent in clear text over the public internet can be observed by an unintended third party. Non-encrypted Internet e-mail communications may be accessed and viewed by other internet users without your knowledge and permission while in transit to us. If you wish to keep your information private, please do not use electronic mail to communicate information to us or request information from us that you consider to be confidential and/or proprietary. If you wish, you may contact us instead via telephone at the phone number provided: https://www.ethics.net/contact/
6.2 Third-party vendors
For certain services on our website, such as live chat or webcasts, we will ask for information about you such as your name, business, and e-mail address. In cases where we use a third-party vendor to provide online services, the vendor has agreed to keep your information confidential. For example, transcripts of live chat sessions may be archived in a database by our vendor for review by our operators.
7. Links to other sites
We may provide links to other websites not owned or controlled by us that we think might be useful or of interest to you. We are not, however, responsible for the privacy practices used by other website owners or the content or accuracy contained on those other websites. Links to other websites do not constitute or imply endorsement by us of those web sites, any products or services described on those websites or any other material contained in them. We advise that you contact any third party websites directly for their individual privacy policies.
8. International data transfer
We may transfer certain personal information across geographical borders to our subsidiaries or service providers (working in conjunction with us or on our behalf) worldwide. Such transfers are made in accordance with applicable law.
Where you are based in the European Union you should be aware that your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under European Union law.
Where you are based outside of the European Union, you should be aware that your personal information may be transferred to, stored, and processed in a jurisdiction that is not your home jurisdiction. You consent to the transfer, disclosure, storage and/or processing of your personal information outside the jurisdiction in which the information was originally collected.
We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your personal information is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.
9. Contact us
National Ethics Association company which provides each Service is primarily responsible for the personal information collected in relation to that Service. A general description of National Ethics Association capabilities and their contact information is available here https://www.ethics.net/contact/
Our Chief Privacy Officer can be contacted at: GallagherEthicsandCompliance@AJG.com
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority in your country of residence.
10. Changes to the privacy notice
You may request a copy of this privacy notice from us using the contact details set out above.
Where changes to this privacy notice will have a fundamental impact on the nature of our processing of your personal information or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you may have under applicable law (e.g. to object to the processing).