Privacy Policy USA

Our Privacy Pledge

Clements Worldwide, along with the insurance companies we represent, believe that information personal to our clients and prospects should be respected and protected. For this reason, we are committed to protecting your nonpublic personal information and using it only as appropriate or necessary to provide you with the best possible service and products. This Privacy Policy, which describes our information practices and policies in detail, applies to our relationship with you as an individual who enquires about or obtains products or services from us for personal, family or household purposes.

Our Commitments to Privacy

Our privacy commitments are fundamental to the way we run our business. Unless otherwise noted or governed by law, these commitments apply to everyone who has a relationship with us – including customers, partners, and website visitors. Clements Worldwide is committed to providing you with the best overall experience in all of our products and services. We strive to strike the right balance between using your data to ensure the quality of those experiences and protecting your privacy. We have assessed all aspects of our business and optimized the amount of data we collect to find the right balance between data sharing and service.

Scope

This policy applies to all information we collect about you, information we collect directly from you, information we automatically collect, information we collect through our mobile application(s), and information we collect from third parties. This policy covers many legislative statutes such as CCPA, CPRA, CPA, CDPA, VCDPA, UCPA.

Personal, Anonymous, and Aggregate Information

Personal Data, also referred to as PII or personally identifiable information, is Information that identifies or reasonably can be used to identify you. Examples include your: (i) Name, (ii) Mailing address, (iii) Email address, (iv) Phone number, (v) Date of birth or age, (vi) Credit/debit card number, (vii) Purchase information, (viii) Mobile device information, (ix) How you use our sites and mobile applications, (x) Social media information. Anonymous Information is information that doesn’t identify you and can’t reasonably be used to identify you specifically. Finally, Aggregate Information is information taken from many people’s data and combined into anonymous groups or categories.

Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. For example, cookies are used to remember users’ preferences and to help navigate between pages efficiently. Clements Worldwide sends cookies to your computer from our website. We use cookies in order to monitor customer traffic patterns and site usage so we can develop the design and layout of our website. This process is to ensure we better meet the needs of visitors to our website. It includes non-specific data such as mouse movements and pages visited.

Should you wish to refuse to accept cookies or restrict the data what we collect through our software, you can alter your cookies setting in your web browser. This may however mean you will be unable to access parts of our website. For more information on cookies you can visit http://www.allaboutcookies.org/.

Click here to manage your cookie preferences

Your Consent

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last 12 months:

Category	Examples	Collected?
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, internal protocol address, email address, account name, social security number, driver’s license number, passport number, other similar identifiers.	YES
B. Personal information categories listed in the California customer records statute (Cal.Civ Code 1798.80)	A name, signature, security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, debit card number, or any other financial information, some personal information included in these categories may overlap with other categories.	YES
C. Protected Classification characteristics under California or federal Law	Age (40 years or older) race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information	Genetic, physiological, behavioural, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints and voiceprints, iris or retina scans, key stroke, gait, or other physical patterns, and sleep, health, or exercise data.	YES
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data	Physical location or movements.	YES
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g,34 C.F.R Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information	Profiles reflecting a person’s preferences, characterises, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.	NO

Some of the personal information, such as information relating to health or criminal convictions, may be required by us for the specific purposes of underwriting or as part of the claims handling process. The provision of such information is necessary for us to be able to provide you with insurance or manage a claim. Such information will only be used for the specific purposes set out in our notice. Personal information does not include; Publicly available information from government records, de-identified or aggregated consumer information and information excluded from the scope.

How We Obtain Personal Information

We obtain the categories of personal information listed above from a number of sources such as; directly from our clients or their agents, indirectly from our clients or their agents, directly and indirectly from activity on our website (www.clements.com) and from third parties that interact with us in connection with the service we perform.

Use of Personal Information

We may use the personal information we hold about you for the purposes for which the information was collected i.e. providing insurance; including handling claims and any other related purposes, underwriting (which may include underwriting decisions made via automated means), offering renewal terms, pricing or statistical purposes. We may also use your data to safeguard against fraud and money laundering and to meet our general legal and regulatory obligations or to respond to law enforcement requests.

Sharing Personal Information

We may disclose your personal information for business purposes to third parties involved in providing products or services to us, or to service providers who perform services on our behalf. These include our group companies, affinity partners, brokers, agents, third party administrators, insurers, reinsurers, other insurance intermediaries, insurance reference bureaus, credit agencies, medical service providers, fraud detection agencies, loss adjusters, external law firms, external accountants and auditors, regulatory authorities, and as may be required by law. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose;

Identifiers
Customer records personal information categories
Protected classification
Commercial information
Biometric information
Internet or other similar network activity
Geolocation data
Professional or employment-related information

In the preceding twelve (12) months we have not sold any personal information.

Information We Disclose to Third Parties

We do not disclose personal information about you to third parties for their own marketing purposes or to contact you about their own products or services. We share personal information about you with third parties (that is, people and companies that are not affiliated with us) only as appropriate or necessary to provide you with our products and services and as otherwise permitted by law. For example, we may disclose your personal information as appropriate or necessary to service your policy and to administer and provide you with benefits in accordance with the terms and provisions thereof; to investigate, administer, and pay or deny or otherwise resolve claims; to comply with state and federal regulatory requests or demands; and to process other transactions that you request.

Persons and other third parties to whom we may make such disclosures may include persons who perform a business function for us, insurance regulators or law-enforcement authorities, insurance companies (The represented companies may share information with their affiliates so that they may offer you additional products and services. They do not disclose information to other companies or organizations not affiliated with them for the purpose of using information to sell their products or services to you.), preferred provider organizations, reinsurers, insurance and claim adjusters, insurance premium auditors, attorneys who are retained by us or by them, and persons requesting information pursuant to subpoena or court order.

International Transfer of Personal Data

Due to the global nature of our business, for the purposes set out above we may transfer Personal Information to parties located in other countries.  For example, we may transfer Personal Information 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. If your data originate in the European Economic Area (EEA), we may send your data outside the EEA for processing and storage. By submitting your personal data to us you are consenting to the storage and transfer of your data in this way. If we do this we will take reasonable steps to protect your data. Such transfer will comply with all applicable data protection regulations and with our obligation to adequately protect and secure your personal information.

Retention Of Personal Data

Clement Worldwide takes reasonable steps to ensure that the Personal Information we process is reliable for its intended use, and as accurate and complete as is necessary to carry out the purposes described in this Privacy Policy. We will retain Personal Information for as long as reasonably necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. In most cases this will be for (7) years following the end of our relationship with you, however in some instances we may retain your personal data for longer periods of time, for instance; where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.

Your Rights

You have specific rights regarding your personal information.

Right to access of your personal information
Right to rectification of your personal information
Right to deletion
Right of restriction
Right of Portability
Right to opt out of sales
Right against automated decision making
Private right of action

Once we receive and confirm your request, we can disclose to you:

The categories of personal information we collected about you
The categories of sources for the person information we collected
Our business or commercial purpose for collecting that personal information
The categories of third parties with whom we share that person information
The specific pieces of personal information we collected about you
Whether we sold or disclosed your personal information for a business purpose

Sensitive Personal Information (PI)

We will ask for your consent to process any sensitive personal information.

By providing your personal information to Clements Worldwide you consent to the processing, transfer and retention of your personal data. We do not knowingly collect, use, or disclose information of children under the age of sixteen (16) without the consent of their parents or legal guardians. In any instance where such information was collected, it would be purely accidental and unintentional. Some examples of Sensitive Personal Information;

social Security number
state Identity card
passport
driver license
account log-in
financial accounts
debit or credit card information
racial or ethnic origin
religious or philosophical beliefs
union memberships

You have the right to limit our use of your Sensitive Personal Information in certain circumstances. To do, please contact Clements at compliance@clements.com.

Deletion Request

Individuals have the right to request that we delete any of their personal information that we collected from them and retained, subject to certain exceptions.

Once we received and confirm the consumer request, we will delete their personal information from our records, unless an exception applies.

We may deny a deletion request if retaining the information is necessary:

To complete the transaction for which we collected the personal information, provide a good or service that was requested, take actions reasonably anticipated within the context of our ongoing business relationship, or otherwise perform our contract.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Exercise free speech ensure the right of another individual to exercise their free speech rights, or exercise another right provided for by law.
Comply with any relevant Electronic Communications Privacy Acts
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.
Make other internal and lawful uses of that information that are compatible with the context in which an individual provided it.

To exercise the access, data portability, and deletion rights described above please submit a request to us by contacting compliance@clements.com or completing our online SAR form Subject Access Request | Clements.

We will review your request to ensure that it is a verifiable consumer request and relates to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Subject Access and Data Deletion Request

A subject access request is a request from or on behalf of an individual which seeks to discover whether Clements is processing the personal data of that individual, if so, to have access to that information and, in addition, to be provided with additional information, which corresponds to the information provided in this privacy policy. We endeavour to respond to a verified consumer request within 30 days of its receipt. To exercise the access, data portability, and deletion rights described above please submit a consumer request to us by contacting compliance@clements.com or completing and submitting the online SAR form Subject Access Request | Clements.

Response Times

We endeavour to respond to a verified consumer request within 30 days of its receipt. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or service, charge you different prices or rates for goods or services, provide you with a different level or quality of goods or services or suggest that you may receive a different price or rate for goods or services.

Changes to Privacy Policy

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements.  We will place updates on our website.

Information Security

We restrict access to personal information about you to those employees who need to know that information in order to provide products and administrative services to you. We maintain physical, electronic and procedural safeguards to guard your personal information. If you have any questions concerning our use of your personal information, please contact our Legal Affairs and Compliance Department at compliance@clements.com.

How To Contact Us

Email: compliance@clements.com

By post: at one of our office locations below

Online: https://www.clements.com

For information concerning our products and services, please visit our website at www.clements.com.

Washington, DC

1220 L Street NW, Suite 1200
Washington, DC 20005

+1.202.872.0060

+1.800.872.0067 info@clements.com

London, UK

The Walbrook Building
25 Walbrook
London, UK EC4N 8AW

+44(0) 33.0099.0100 europe@clements.com

Gibraltar

Unit 243.01
World Trade Center
6 Bayside Road
Gibraltar, GX11 1AA

+00350 57826000

+00350 54716000 europe@clements.com

Dublin, Ireland

Alexandra House
3 Ballsbridge Park
Ballsbridge, Dublin 4
Dublin, D04 C7H2, Ireland

International: +353 1 9645098

In Ireland: +1800 44 99 33 ireland@clements.com

Privacy Policy UK

Our Privacy Pledge

Our Commitments to Privacy

Scope

Personal, Anonymous, and Aggregate Information

Personal Data, also referred to as PII or personally identifiable information, is Information that identifies or reasonably can be used to identify you. Examples include you: (i) Name, (ii) Mailing address, (iii) Email address, (iv) Phone number, (v) Date of birth or age, (vi) Credit/debit card number, (vii) Purchase information, (viii) Mobile device information, (ix) How you use our sites and mobile applications, (x) Social media information, and (xi) . Anonymous Information is information that doesn’t identify you and can’t reasonably be used to identify you specifically. Finally, Aggregate Information is information taken from many people’s data and combined into anonymous groups or categories.

Information We Collect

We may collect personal information about you from a variety of sources. A great deal of the information we collect, such as your name, address, birth date, phone number, passport number, medical and health history, medical treatment, personal property descriptions and related matters comes from you during the application or claim submission process. We may collect information about you to properly underwrite and review your application or to properly investigate, administer, and resolve any claims for benefits, and we may contact you by telephone, fax, mail or e-mail for additional information. We also may collect personal information about you from third parties, such as governmental entities or regulators, medical providers and other health related sources, and possibly from consumer reporting agencies. The information we collect can include such things as information concerning your previous insurance coverage and policies, your employment status, credit card information, your claims and medical history, and on rare occasions, your credit history.

How We Use Your Information

We may use the information we collect to send you information about our products and services. We may use the information we collect for analytical purposes and to assist us in improving our processes, products and services. We will use your information collected to safe-guard against fraud and money laundering, comply with applicable laws and regulatory obligations (including laws outside your country of residence) and establish and defend legal rights. We will also use your information to handle requests for data access or correction as well as when we are resolving complaints.

Purpose for Use of Your Personal Data and Legal Basis

We are required to establish a legal basis to use your personal data. We use your information for the following lawful reasons:

To enter into or perform a contract; for example to provide you with an insurance quotation, to start, change or cancel an insurance policy, to administer the policy, to manage any claims which arise, to answer any queries you may have, action your requests or perform any debt recovery
To comply with a legal obligation: for example the rules set by our regulators, to fulfil your data rights under data privacy laws, handle complaints about data privacy or our financial products and services, and to comply with other legal requirements such as preventing money laundering and other financial crimes
For our legitimate business interests: for example to offer a renewal, detect and prevent fraud, for statistical analysis, to monitor and improve our business and our products and services, demonstrate compliance with applicable laws and regulations and some marketing activities. Where we rely on this lawful reason, we assess our business needs to ensure they are proportionate and do not affect your rights. In some instances, you also have the right to object to this kind of use. For more information on our legitimate interests, please refer to Appendix 2
With your consent: for example if you consent to us contacting you for marketing purposes. You can withdraw your consent at any time, for more information please visit the “Your rights” section of this Privacy Policy.
To protect vital interests: in extreme or unusual circumstances, we may need to use your information to protect your life or the lives of others.

Special Category Data

The processing of special category data, such as health data, requires an additional legal basis to the grounds set out above. Some examples of special category data:

personal data revealing racial or ethnic origin
personal data revealing political opinions
personal data revealing religious or philosophical beliefs
personal data revealing trade union memberships
genetic data
biometric data

This additional legal basis will typically be:

your explicit consent;
the establishment, exercise or defence by us or third parties of legal claims; or
a substantial public interest exemption provided under local laws of EU Member States and other countries implementing the General Data Protection Requirements (“GDPR”), such as where the processing is necessary for an insurance purpose, or to detect or prevent unlawful acts, or to prevent fraud

Your Rights

You have the right to know what information is held about you. GDPR in the UK provides a framework to ensure that personal information is handled properly. This information must be:

Processed fairly, lawfully and in a transparent manner
Processed for specific, legitimate and lawful purposes
Adequate, relevant and not excessive
Accurate and up to date
Not kept for longer than necessary
Processed in line with an individual’s rights
Secure
Not transferred other than in accordance with agreed terms and conditions

Data protection law gives you the following rights relating to your personal data:

Your right to access
Your right to rectification
Your right to erasure (the right to “be forgotten”)
Your right to restrict processing
Your right to object to direct marketing
Your right to automated decision-making
Your right to challenge our legitimate interest
Your right to object to the use of your information for statistical purposes
Your right to data portability

For more information on your rights in the UK, please visit; Individual rights | ICO.

To exercise your rights you may contact us by contacting compliance@clements.com or using the Subject Access Request | Clements.

You also have the right to submit a complaint to the Information Commissioner’s Office (ICO); for more information please visit; What to expect from the ICO when making a data protection complaint | ICO.

Deletion Request

Under GDPR this is called “The right to be forgotten”.

Individuals have the right to have their personal data erased if:

The personal data is no longer necessary for the purpose which we originally collected or processed it for.
We are relying on consent as our lawful basis for holding the data, and the individual withdraws their consent.
We are relying on legitimate interests as our basis for processing, the individual objects to the processing of their data, and there is no overriding legitimate interest to continue this processing.
We are processing the personal data for direct marketing purposes and the individual objects to that processing.
We have processed the personal data unlawfully (i.e. in breach of the lawfulness requirement of the 1st principle).
We have to do it to comply with a legal obligation; or
We have processed the personal data to offer information society services to a child.

The right to erasure does not apply if processing is necessary for one of the following reasons:

to exercise the right of freedom of expression and information.
to comply with a legal obligation.
for the performance of a task carried out in the public interest or in the exercise of official authority.
for archiving purposes in the public interest, scientific research historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing; or
for the establishment, exercise or defence of legal claims.

GDPR also specifies two circumstances where the right to erasure will not apply to special category data:

if the processing is necessary for public health purposes in the public interest (e.g. protecting against serious cross-border threats to health, or ensuring high standards of quality and safety of health care and of medicinal products or medical devices); or
if the processing is necessary for the purposes of preventative or occupational medicine; for the working capacity of an employee; for medical diagnosis; for the provision of health or social care; or for the management of health or social care systems or services. This only applies where the data is being processed by or under the responsibility of a professional subject to a legal obligation of professional secrecy (e.g. a health professional).

Information We Disclose to Third Parties

International Transfer of Personal Data

Retention of Personal Data

Your Consent

Subject Access and Data Deletion Request

Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. For example, cookies are used to remember users’ preferences and to help navigate between pages efficiently. Clements Worldwide sends cookies to your computer from our website. We use cookies in order to monitor customer traffic patterns and site usage so we can develop the design and layout of our website. This process is to ensure we better meet the needs of visitors to our website. It includes non-specific data such as mouse movements and pages visited.

Should you wish to refuse to accept cookies or restrict the data what we collect through our tracking software, you can alter your cookies setting in your web browser. This may however mean you will be unable to access parts of our website. For more information on cookies you can visit http://www.allaboutcookies.org/.

Response Times

We endeavour to respond to a verified consumer request within 30 days of its receipt.

Non-Discrimination

We will not discriminate against you for exercising any of your rights. Unless permitted by the Law, we will not deny you goods or service, charge you different prices or rates for goods or services, provide you with a different level or quality of goods or services or suggest that you may receive a different price or rate for goods or services.

Changes to Privacy Policy

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements.  We will place updates on our website.

Information Security