Global privacy policy

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, national resident 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 potentially 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 organization). 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, details of policy coverage and cause of loss; and
• Prior accident or loss history, your status as director or partner or other ownership or management interest in an organization and other insurance policies you hold.

Cookies contain small amounts of information which are downloaded to your device when you visit our website. Cookies are sent back to our website to allow us to recognize your device.

We use the following cookies:

• CraftSessionId to maintain sessions across web requests. For GDPR purposes, please note that Craft’s default cookies do not collect any personal or sensitive information. Craft's default cookies do not collect IP addresses. The information they store is not sent to any 3rd parties.
  The default cookies are only used to communicate for the purposes of user authentication, form validation/security, and basic web application operations.
• Google Analytics _gat, _ga These two 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.

We use the personal data that we collect 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.
• Manage claim disputes, where applicable.
• 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 analyze and manage other commercial risks.
• Conduct satisfaction surveys.
• Use during the normal course of pre-employment contracting during the recruitment process.
• For our legitimate interests while conducting the recruitment process. 
• 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

We use data during the recruitment and employment process, including:

• to decide whether to employ (or engage) you;
• to decide how much to pay you, and the other terms of your contract with us;
• to check you have the legal right to work for us;
• to determine whether we need to make reasonable adjustments to your workplace or role because of your disability;
• to monitor diversity and equal opportunities;
• to comply with employment law, immigration law, health and safety law, tax law and other laws which affect us;
• the prevention and detection of fraud or other criminal offences; and
• for any other reason which we may notify you of from time to time.

We may process special or sensitive personal data when we are processing it for the following purposes, which we may do:

• where it is necessary for carrying out rights and obligations under law;
• where it is necessary to protect your vital interests or those of another person where you/they are physically or legally incapable of giving consent;
• where you have made the data public;
• where processing is necessary for the establishment, exercise or defense of legal claims; and
• where processing is necessary for the purposes of occupational medicine or for the assessment of your working capacity.

We will only process personal data for the specific purposes set out above or for any other purposes specifically permitted by the data protection legislation. We will notify you of those purposes when we first collect the data or as soon as possible thereafter.

We may, as a matter of law, and without requiring notice or consent, use your information for crime and fraud prevention, or systems administration within Sedgwick and to monitor and/or enforce Sedgwick’s compliance with any regulatory rules and codes.

You may let us know how you want to be contacted (e.g. by email, phone or post).

For personal data to be processed lawfully in most countries, they must be processed on the basis of one of basis as set forth by applicable law. These include, among other things, the data subject’s consent to the processing, or that the processing is necessary for the performance of a contract with the data subject, for the compliance with a legal obligation to which the data controller is subject, or for the legitimate interest of the data controller or the party to whom the data is disclosed. When sensitive Personal Data is being processed additional conditions must be met. When processing Personal Data as data controllers in the course of our business, we will ensure that those requirements are met.

Depending on your relationship with us, the legal basis for us processing your Personal Data is one of the following:

• You have given consent to us or the party for whom we are acting
• The processing is necessary for the performance of a contract or legal duty
• Processing is necessary for a legitimate interest pursued by us or a third party. Where processing is based on legitimate interest only, it will be in relation to one of the following:
  • Claim handling on behalf of another party
  • Establishing, exercise or defense of legal claims
  • Prevention, detection of crime

Where we use legitimate interest as our grounds for processing your data you have the right to object at any time.

Sedgwick may make personal data available to the following parties for the purposes of claim assessment or as required by law:

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; and
  • 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 organizations 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 reorganization, 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.

Due to the global nature of our business, for the purposes set forth 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 in order to perform our services.

We will rely on legally-provided mechanisms to lawfully transfer personal data across borders.  In many cases, we will use European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers from the EU.  You can find more information about Standard Contractual Clauses here on the European Commission website.  These clauses are contractual commitments between companies transferring Personal Data, binding them to protect the privacy and security of the 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 vendor, the vendor will be selected carefully and required to use appropriate measures to protect the confidentiality and security of your Personal Data.

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

Your account can be used to view sensitive information for applications where a PIN is required. It is, therefore, important that you keep your PIN private, as you would your banking PIN. If your PIN is compromised, contact Sedgwick immediately.

From time to time we alter our Privacy Notice as we introduce new services or change existing ones. Changes to this notice are effective as soon as they are posted on the Site and a notice has been placed on the login screens of the self-service applications. We from time to time also communicate this change via e-mail. The effective date of this version of the Privacy Notice appears at the top of the notice.

You from time to time have the option to enter third party web site through the Site, or you from time to time have the option to enter our web site from another third-party web site. Since we cannot be assured that such third-party web site follow our privacy policies, we encourage you to ask questions and review the privacy policies of these third parties. We have no responsibility or liability for the actions or policies of these independent sites, do not endorse any product or service mentioned or offered in such sites, and are not responsible for the content or privacy practices of such sites.

Ours are general purpose and professional websites that do not knowingly collect any information from children under age 18 at any time. We also strive to be fully compliant with the Children’s Online Privacy Protection Act (COPPA). We strongly encourage parents and guardians to regularly monitor and supervise their children’s online activities. If a child under the age of 18 has provided Personally Identifiable Information on one of our web site without the consent of his or her parent or guardian, we ask that a parent or guardian send an e-mail to privacyissues@Sedgwick.com, and we will delete the child’s Personally Identifiable Information from our files.

Sedgwick takes steps to keep your Personal Data accurate and up to date. If you reside in Argentina, you may request further information about processing, access your Personal Data, and request that we stop processing or correct Personal Data related to you. To access your Personal Data, please contact us described above. Sometimes, however, we may need access to your Personal Data to complete then Services. We may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law. If you have any complaints regarding how we handle your Personal Data, please contact our privacyissues@sedgwick.com. Sedgwick responds to complaints as soon as practicable, and in any event, within the time limits prescribed by law.

Sedgwick takes steps to keep your Personal Data accurate and up to date. If you reside in Australia, you may request access to or correction of the Personal Data that we have collected about you. To access your Personal Data, please contact us described above. We may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law. If you have any complaints regarding how we handle your Personal Data, please contact us at the address above or email us: privacyissues@sedgwick.com. Sedgwick responds to complaints as soon as practicable, and in any event, within the time limits prescribed by law.

We will not process your data for direct marketing without making additional disclosures. Further, if you are located in Bahrain please contact us at the address provided above if you would like the correction of any Personal Data related to you, want to opt-out of automated decision making, and/or want to access any data related to you held by us. If you have any complaints regarding how we handle your Personal Data, please contact us at privacyissues@sedgwick.com. Sedgwick responds to complaints as soon as practicable, and in any event, within the time limits prescribed by law.

Sedgwick Canada Inc. (“Sedgwick Canada”) is a leader in innovative claims and productivity management solutions, providing cost effective claims administration and adjustment. We are committed to the protection and confidential treatment of Personal Information that comes into our possession as part of the services we render on behalf of our clients. Our employees and colleagues have been trained to treat Personal Information in accordance with applicable privacy laws. This Privacy Policy outlines our Personal Information handling practices.

Why Sedgwick Canada Collects, Uses and Discloses Personal Information

Sedgwick Canada collects Personal Information only in connection with claims related services and risk management activities. Sedgwick Canada collects and discloses Personal Information to enable our professional claims specialists to establish the entitlement to benefits of claimants, arising from contracts of insurance, or self-insured plans. We also collect and disclose Personal Information from third parties with respect to claims made against our clients.

The Kinds of Personal Information Sedgwick Canada Collects, Uses and Discloses

For the purposes of this Privacy Policy, Personal Information means information about an identifiable individual, other than information which is excluded under applicable legislation.

Sedgwick Canada collects Personal Information based upon the type and nature of the claim or risk circumstances. This may include previous claim history, financial, medical, health or employment information. We may seek claim validation information from retailers, wholesalers and suppliers of goods and services. In appropriate cases we may seek information from authorities such as the Ministry of the Environment, Ministry of Labour, Office of the Fire Marshal, Police and Fire Services, Municipalities, Towns and Cities.

How Sedgwick Canada Obtains Personal Information

Most Personal Information is collected directly from the insured or self-insured party, or from a third party making a claim against an insured or self-insured party. Some Personal Information may be provided by an Instructing Principal, including our clients or carriers, or by an Instruction Principal’s agents, such as insurance brokers.

Personal Information may also be collected from involved parties such as public officials (Fire Department, Police, Office of the Fire Marshal), Witnesses, Private Investigators, Credit Bureaus and Title Searchers. Some of the organizations we obtain information from are subject to their own privacy codes and we respect those codes.

Consent will not be obtained with respect to the collection of certain publicly available information, as prescribed by law. If Personal Information is collected with respect to an investigation involving a suspected breach of an insurance policy (or other agreement) or a breach of Canadian law, then consent may not be obtained.

Sedgwick Canada’s Disclosure of Personal Information

Sedgwick Canada only shares Personal Information with our affiliated companies for the reasons listed above or if required by law. To the extent that Personal Information is shared with our affiliated companies in other jurisdictions, such as the United States, it will become subject to the laws of those jurisdictions, including laws regarding disclosure to the local authorities.

Most Personal Information is disclosed or transferred solely to our Instructing Principals. However, in order to collect the information required by our Instructing Principals to provide claim or risk services, we may disclose Personal Information to third party service providers. These include (but are not limited to) the insured’s insurance brokers, insurance adjusters, automobile repair companies, contractors, construction companies, investigators, engineers, accountants and lawyers. We may also disclose Personal Information to authorities with jurisdiction such as Fire Departments, Fire Marshals, Police and other Federal, Provincial or Municipal authorities (“Authorities”) for the purpose of verifying the circumstances surrounding a claim. We obtain consent to disclosure when required and, where applicable, we rely on the consent obtained by our Instructing Principals to the use and disclosure of Personal Information. Where such third party service providers or Authorities are in other jurisdictions, such as the United States, the treatment of Personal Information will become subject to the laws of those jurisdictions, including laws regarding disclosure to the local authorities.

Where Sedgwick Canada discloses Personal Information to a regulatory or investigative body (such as the Insurance Crime Prevention Bureau), where we believe that the information relates to the breach of an insurance policy or other agreement or Canadian law, or where we are otherwise required or permitted by law to disclose the information, consent may not be obtained. Similarly, if Personal Information is disclosed to a lawyer for claims purposes or to obtain legal advice, consent may not be obtained.

Sedgwick Canada may disclose Personal Information in the context of an actual or possible corporate reorganization, merger or amalgamation with another entity, or an actual or possible sale of all or of a substantial portion of the assets of Sedgwick Canada. Under such circumstances, disclosure would occur on the condition that the information only be used for the purpose of evaluating the transaction, or, on completion of the transaction, for the purposes outlined in this Privacy Policy.

We will not however, transfer information without first taking reasonable steps to ensure that the Personal Information will receive adequate protection and that it will not be used for purposes not relevant to the object of the file or communicated to third persons without your consent, except as set out in this Privacy Policy or otherwise permitted or required by law.

How Sedgwick Canada Ensures the Security of Personal Information

Personal Information recorded in documents is securely stored at Sedgwick Canada’s offices and at the U.S. offices of Sedgwick Canada’s affiliated U.S. companies, where it is subject to the laws of that jurisdiction, including laws regarding disclosure and may be accessible to that jurisdiction’s government, courts, law enforcement or regulatory agencies. Electronically recorded information is stored on computer systems at the U.S. offices of Sedgwick Canada’s affiliated U.S. companies and is made accessible for processing by Sedgwick  Canada. These computer systems and the information stored in them are protected by electronic security systems.

Sedgwick Canada and its affiliated companies restrict access to Personal Information. Sedgwick Canada and its affiliated company employees, contractors and representatives are under an obligation to access Personal Information only when they have a legitimate business need to do so. Sedgwick Canada and its affiliated company employees receive training with respect to proper Personal Information handling practices and they are obliged to comply with applicable privacy laws, this Privacy Policy and related codes of conduct. Sedgwick requires that its contractors protect personal information against loss or theft, as well as unauthorized access, disclosure, copying use or modification by implementing reasonable and appropriate security measures.

Sedgwick Canada retains Personal Information only as long as is necessary in order to fulfill the purposes outlined in this Privacy Policy or as required or permitted by law or for one year after using such information to make a decision that directly affects the individual. Personal Information that is no longer required is securely destroyed or made anonymous as appropriate.

Sedgwick Canada’s compliance with appropriate Personal Information practices and applicable privacy laws is overseen by and is the responsibility of Elke Paulsen at 6725 Airport Road, Ste. #300, Mississauga, ON L4V 1V2, telephone number 905-293-7737 or Brenda Corey, Privacy Officer at 901-415-7430.

Accuracy and Access to Personal Information

Sedgwick Canada is committed to maintaining the accuracy and completeness of the Personal Information it collects uses or discloses to its Instructing Principals.

Upon written request and subject to exceptions permitted or required by law, we will provide you with access to Personal Information about you that is in our possession. We will also update and/or correct your Personal Information as required. Sedgwick will not charge you a fee to access your employee personal information in our possession.

We may refuse to provide access to certain information as required or permitted by law, which may include :

• If doing so could reveal Personal Information about a third party unless the information about the third party is severable or the, the third party consents;
• If the information is subject to solicitor-client privilege;
• If revealing the information would disclose confidential commercial information;
• If revealing the information could reasonably threaten the life, safety or security of another person;
• The information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act (i) under a collective agreement, (ii)   under an enactment, or (iii)   by a court; or
• Where Sedgwick Canada is acting as agent for an insurer or other Instructing Principal and where that principal has the responsibility to respond to requests for access to Personal Information.

Where the Personal Information consists of medical or health information, we may provide access through a medical practitioner. If we are unable or not permitted to provide you with access to your Personal Information, we will provide reasons for our inability to do so.

Amendments

Sedgwick Canada Inc.  may amend this policy from time to time at its discretion. A current version of the privacy policy is always available on Sedgwick CMS Canada’s main web site: “Sedgwick Canada Privacy Policy” at http://www.Sedgwick.com/ca

Further Information

Requests for further information, Personal Information access or complaints about Sedgwick Canada’s handling of Personal Information should be referred to Maria Joshua at 21 Four Seasons Place, Suite 100, Toronto Ontario, M9B 6J8 or at 416-695-5100 or to Brenda Corey, Privacy Officer at 901-415-7430.

We process data according to our legitimate interest and the legitimate interest of our third parties. Please contact us as provided above if you would like to know more about how we process your data, or to access, correct, or delete any data related to you that we control. Further, in some cases, you may need us to anonymize your data or transfer it to another entity (the right to portability). We will use our best efforts to respond to your request. We will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law. Sedgwick responds to complaints as soon as practicable, and in any event, within the time limits prescribed by law.

Sedgwick takes steps to keep your Personal Data accurate and up to date. If you reside in Chile, you may have a right to access, correction, or deletion of the Personal Data that we have related to you. To access your Personal Data, please contact us described above. We may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law. If you have any complaints regarding how we handle your Personal Data, please contact our privacyissues@sedgwick.com. Sedgwick responds to complaints as soon as practicable, and in any event, within the time limits prescribed by law.

Principally, Personal Data collected in China will be stored within China. However, we provide Services through resources and servers located globally (including the United States), which means your Personal Data may be transferred to or accessed within another country/region outside of China. The data protection and privacy laws and principles in those countries/regions may not offer the same level of protection as those in China. Under those circumstances, Sedgwick will continue to protect your Personal Data in a manner consistent with what is expected under Chinese law (e.g., we will obtain your consent to transfer your Personal Data, or de-identify the Personal Data before transfer).

We take steps to keep your Personal Data accurate and up to date. If you are residing in Colombia, please contact us if as provided above you would like to correct, receive proof that we process your data, or to object to processing, where applicable. If you have any complaints regarding how we handle your Personal Data, please contact us at privacyissues@sedgwick.com. Further, we remind you that you can lodge a complaint with the applicable Superintendent if you believe that an entity which processes your data has violated your related rights. 

Click here to view our policy.

Sedgwick takes steps to keep your Personal Data accurate and up to date. If you reside in Hong Kong, you may request access to or correction of the Personal Data that we have collected about you. To access your Personal Data, please contact us as described above. We may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

You may choose not to provide Sedgwick with your Personal Data where applicable. However, if you choose not to provide your Personal Data, you may not be able to use the Services. 

Sedgwick takes steps to keep your Personal Data accurate and up to date. If you reside in Indonesia, Malaysia, Philippines or Singapore, you may request access to, and modification, opposition, and deletion of the Personal Data that we have collected about you. To access your Personal Data, please contact us as listed above. Subject to applicable law, we may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

Sedgwick may use your Personal Data for the following purposes:

1. Communicating with you on activities related to Services
2. Requesting opinions and feedback on Services.
3. Providing you with updates on new uses of your Personal Data.
4. Providing registration support and details for Services.
5. Creating statistical and analytic information.
6. Other inevitably necessary communications to you.
7. Complying with legal requirements or obligations, law enforcement, and for public safety purposes.

Sedgwick may also share Personal Data with our affiliates business partners, vendors and suppliers. The sharing of Personal Data to these organizations may mean your Personal Data is transferred to third parties located outside of Japan.

Consent for use and/or sharing of Personal Data

If you reside in Japan, by using the Services you consent to the collection, use and transfer of your Personal Data as outlined in this Privacy Notice.

If you have any complaints regarding how we handle your Personal Data, please contact our privacyissues@sedgwick.com.

Sedgwick takes steps to keep your Personal Data accurate and up to date. If you reside in Israel, please contact us if you want more information on how we process your data, including accessing, correcting, deleting, or objecting to further processing, where applicable. If you have any complaints regarding how we handle your Personal Data, please contact our privacyissues@sedgwick.com. Sedgwick responds to complaints as soon as practicable, and in any event, within the time limits prescribed by law.

By using the Services you consent to the collection, use and transfer of your Personal Data (including sensitive Personal Data pursuant to Mexican law) for processing in the United States as described in this policy.

Sedgwick takes steps to keep your Personal Data accurate and up to date. If you reside in Mexico, you may request access to, modification, cancellation or opposition of the Personal Data that we have collected about you. To access your Personal Data, please contact us through as described above. We may charge for this access service pursuant to applicable law and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

Sedgwick takes steps to keep your Personal Data accurate and up to date. If you reside in New Zealand, you may request access to or correction of the Personal Data that we have collected about you. To access your Personal Data, please contact us as described above. We may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law. If you have any complaints regarding how we handle your Personal Data, please contact our privacyissues@sedgwick.com. Sedgwick responds to complaints as soon as practicable, and in any event, within the time limits prescribed by law.

Sometimes it is necessary that we process your data in order to provide the Services. Sedgwick takes steps to keep your Personal Data accurate and up to date. If you reside in Peru, please contact us above if you would like any information about the data we hold that relates to you, or if you would like to access, correct, delete, or opt-out of providing data, where applicable. If you have any complaints regarding how we handle your Personal Data, please contact our privacyissues@sedgwick.com. Sedgwick responds to complaints as soon as practicable, and in any event, within the time limits prescribed by law.

We take steps to keep your Personal Data accurate and up to date. If you reside in Russia, please contact us above if you would like any additional information or if you would like to access the Personal Data that relates to you. If you believe that any data is incorrect, you may request that we either correct or delete the data.

We take steps to keep your Personal Data accurate and up to date. If you reside in Qatar, please contact us above if you would like any information about the data we hold that relates to you, or if you would like to access, correct, delete, or opt-out of providing data, where applicable. 

Sometimes we must process your Personal Data in order to provide the Services. Such processing may include transfer to a third country, such as the United States. Sedgwick takes steps to keep your Personal Data accurate and up to date.

If you reside in South Africa, you have the right to:

- know whether Personal Data is being collected and/or access data we have collected;

- request correction or destruction of that data;

- object on reasonable grounds to the data's use for direct marketing; and

- not to be subject to automated decision making.

You also have the right to contact the Information Regulator if you believe that any of your rights this title are violated. For more information, please visit http://www.justice.gov.za/inforeg/. 

Some data that we collect is mandatory for us to provide the Services. On other occasions, you may have a choice regarding whether to provide data, and we may inform you of such choice at the point of our collection. 

1. Access Requests

Sedgwick takes steps to keep your Personal Data accurate and up to date. If you reside in South Korea, you may request access to, and modification, opposition and deletion of the Personal Data that we have collected about you. To access your Personal Data, please contact us as described in this Privacy Notice. Subject to applicable law, we may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

2. Method and procedure for the destruction of Personal Data

Sedgwick retains your Personal Data for long as needed to provide you the Services and/or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Personal Data is destroyed when it is no longer necessary for these purposes.

3. How to Contact Us

If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us a privacyissues@sedgwick.com.

If we process your data while you are located in Taiwan, you may have the right to:

1. request for a review of the Personal Data;

2. request to make duplications of the Personal Data;

3. request to supplement or correct the Personal Data;

4. request to discontinue collection, processing or use of Personal Data; and

5. request to delete the Personal Data.

We will only retain applicable data as long as necessary for completing the Services or for legal compliance, and in some cases, we may be required to process your information to complete the Services. We process data based on the right to process data that does not injure your rights and interests. 

We take steps to keep your Personal Data accurate and up to date. If you reside in Trinidad, you may request access to, deletion, or correction of the Personal Data that we have collected about you. To access your Personal Data, please contact us at the address listed above or email us at privacyissues@sedgwick.com. We respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law. If you have further complaints, you can contact government agencies. 

By using the Services you consent to the collection, use and transfer of your Personal Data as outlined in this Privacy Notice. Further, Personal Data collected will be shared as outlined in this Privacy Notice.

1. Information Security

The Personal Data shared with Sedgwick will be protected using technical and organizational measures designed to protect your information against unauthorized access, theft, and loss as required by article 12 of the Law on Protection of Personal Data no. 6698.

2. Personal Data accuracy

Sedgwick takes steps to keep your Personal Data accurate and up to date. You are responsible for the accuracy of the information you have provided to Sedgwick, and you understand that doing so is important in terms of exercising your personal data rights under the Law on Protection of Personal Data no. 6698 and other applicable legislation.

3. Access requests

If you reside in Turkey, you may request access to, and modification, opposition and deletion of the Personal Data that we have collected about you. To access your Personal Data, please contact us through our through email or in writing. Subject to applicable law, we may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

4. Data retention and destruction

When you delete your account and/or when Personal Data is no longer needed to provide the Services or to comply with our legal obligations, resolve disputes, and enforce our agreements and/or the retention period under applicable law has expired, your Personal Data may be anonymized and continued to be used in that form.

We take steps to keep your Personal Data accurate and up to date. If you reside in Ukraine, you may have various rights connected with the processing of your Personal Data. To access your Personal Data, please contact us at the address listed above. We respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law. Rights related to the processing of your Personal Data may include the right to:

• know about the location the data base of Personal Data which contains your Personal Data;
• receive the information concerning the conditions of your Personal Data;
• know whether his/her Personal Data is stored in a respective database base;
• reject processing;
• change or destroy of Personal Data, if such data is processed illegally or are inaccurate;
• stop illegal processing and accidental loss, destruction, damage due to misleading uses or uses that may cause reputational harm;
• lodge complaints regarding the processing to applicable government authorities or courts;
• If data is processed according to consent, make reservations to restrict the right to process his/her Personal Data;
• withdraw consent to Personal Data processing;
• be informed of the procedure for automated processing of Personal Data; and
• be safeguarded against an automated decision having legal implications for the person.

We will use our best efforts to respond to any request made here under within 30 days. 

If you reside in the United Arab Emirates, your use of the Services signifies your consent to the following:

• You affirmatively waive your material privacy rights under applicable laws;
• Sedgwick may disclose any information you provide us, including information you may consider private; and
• Sedgwick is not liable for any publication of information you provide us, including information you may consider private.

Please do not use the Services if you disagree with any part of this Privacy Notice.

The list below summarizes our collection, use, and disclosure of personal data. To the extent that there is any conflict between this list and other sections of this Privacy Notice, this list shall prevail.

For these types of personal information collected:

• Identifiers (e.g., name, e-mail, postal address, and phone number)
• Demographic information
• Employment information
• Education history
• Sensitive information such as government identifiers
• Financial information and account details
• Geolocation information
• Commercial information (e.g., travel history)
• Photos and videos
• Criminal history
• Telephone recordings

Whose source is: You provide directly to us, such as during the claims process or through a customer satisfaction survey, and from business partners such as insurers.

Collected and used with the purpose of: Manage your claim and related disputes; Make decisions about claim assessment, processing and settlement;  Train employees; Prevent fraud; Conduct surveys; Manage our business operations including legal compliance; Resolve complaints; Establish and defend legal rights.

This Information is Disclosed for a Business or Commercial Purpose

Personal information is shared with these categories of Third Parties (which does not include service providers): Partners in our industry such as reinsurance brokers, appointed representatives, distributors, financial institutions, securities firms, and retailers.

Personal information collected via Website Browsing Activity, including web tracking technology such as browser cookies, flash cookies, and web beacons is used for business and commercial purposes of website functionality, customization and security, advertising and marketing. It is provided to Third Party web tracking providers.

CALIFORNIA PRIVACY RIGHTS (effective January 1, 2020)

Data Subject Rights – California Residents

This portion of our Privacy Policy advises California residents of rights provided in the California Consumer Privacy Act (“CCPA”) and how to effectuate those rights by communicating with us. Please note, we will seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your personal data.

Please customize your data preferences or direct any rights requests or additional questions you may have regarding this Privacy Policy here or privacyissues@sedgwick.com or by regular mail to ATTN: Privacy Office 8125 Sedgwick Way, Memphis, TN 38125 or by phone at 800-625-6588.

If you do, we will need to collect personal data and other information such as your name, email or transaction history in order to verify your identity. You may also authorize an agent to make a request on your behalf, who will need to provide similar information for verification. 

Right to Deletion of Personal Data

California residents have the right to request the deletion of personal data as prescribed in Section 1798.105(a) of the CCPA. Sedgwick may not delete some or all requested personal data as allowed or required by applicable law. 

Right of Access: Right to Request Disclosure of Data Collection and Sharing Practices

You may request to receive details about how we collect, use, and share your personal data.  Specifically, you may request to receive the specific pieces of personal data that we have collected about you. 

You may also request to receive:

• the categories of personal data that we have collected about you, 
• the categories of personal data that we have disclosed for a business purpose, 
• the categories of sources from which we collected the personal data,
• our purposes for collecting that personal data, and
• the categories of parties with whom we share your personal data.

Right to Opt-Out of Sale

We do not, and do not intend to, sell your personal data. 

Right to not be Discriminated Against for Exercising CCPA Rights

We do not discriminate against you for exercising any CCPA rights, such as the access and deletion rights described above. 

Do Not Track

We treat the data of everyone who comes to our site in accordance with this Privacy Notice, regardless their “Do Not Track” setting.

We take steps to keep your Personal Data accurate and up to date. If you reside in Vietnam, Please let us now if you would like to access, correct, update, or delete Personal Data that we hold about you. To access your Personal Data, please contact us at the address listed above or email us at privacyissues@sedgwick.com. We respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.