Effective Date: 2024

Highcourt Partners Limited (doing business in Canada as “Brown & Brown Canada”, “Brown & Brown”, “we“, “our”) pride ourselves on our privacy practices. We are committed to being transparent about the personal information we collect, the manner in which such personal information is used by us and the limited circumstances in which some of your personal information may be disclosed. To help us meet this commitment to you, we have created this Privacy Policy (this “Privacy Policy”) and have appointed a Privacy Officer to ensure that any personal information you provide to us will only be collected, used and disclosed in accordance with this Privacy Policy. References to “user”, “you” and “your” throughout this Privacy Policy are to you as the individual to whom the personal information relates.

Your Consent

This Privacy Policy governs how Brown & Brown and its affiliates collect, use and disclose personal information in Canada. By obtaining an insurance product from us, or otherwise providing us personal information, you agree with the terms of this Privacy Policy as it may be modified from time to time and consent to the collection, use and disclosure of personal information in accordance with the terms of this Privacy Policy. As our business evolves, this Privacy Policy may change, so check back to this page periodically to make sure you understand how your personal information will be treated.

Meaning of Personal Information

For the purposes of this Privacy Policy, “personal information” means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization when collected, used or disclosed solely for the purpose of communicating or facilitating communication with the individual in relation to their employment, business or profession.

The Personal Information We Collect

Except as otherwise provided in this Privacy Policy, the personal information we collect from you is comprised of the information you provide to us. We may collect personal information as follows:

a.	Contact details: such as your name, email, postal address, and phone number. We may collect this information from you throughout the course of our relationship with you.
b.	Demographic details: such as your date of birth, age, gender, marital status, and insurance requirements. We collect this as part of your insurance application and/or administration of your insurance policy.
c.	Employment information: such as job title, employee number, employment status, salary, employment benefits, and employment history, qualifications and affiliations where relevant to your insurance policy. Where applicable, we collect this as part of your insurance application and/or administration of your insurance policy including underwriting.
d.	Health information: such as medical records, health status and medical assessment outcomes. We collect this as part of your insurance application and/or administration of your insurance policy.
e.	Benefits information: such as benefit elections, pension entitlement information, date of retirement and any relevant matters impacting your benefits e.g. voluntary contributions, pension sharing orders, tax protections or other adjustments
f.	Financial information: such as credit history and bankruptcy status, salary, bonus payments, benefits and entitlement data, national insurance contributions details. We collect this information only with your express consent solely on behalf of the applicable insurance company. As noted in the “How We Disclose Your Personal Information” section below, where we collect personal information on behalf of an insurance company, or otherwise share personal information with an insurer in connection with the administration of your insurance policy, such personal information will be subject to the privacy policy of the applicable insurer.
g.	Claims details: such as information about any claims concerning your or your employer’s insurance policy
h.	Marketing and communications preferences: such as interests and preferred language
i.	Events information: such as information about your interest in and attendance at our events, including provision of feedback forms
j.	Background checking information: such as inclusion on a sanctions list or a public list of disqualified directors, the existence of previous or alleged criminal offences, or confirmation of clean criminal records, information in relation to politically exposed persons (“PEPs”). We will only collect this information where (i) applicable in the context of the policy you have applied for; and (ii) we have obtained your appropriate consent.
k.	Comments, feedback or other information provided to us: such as social media interactions with our social media presence, comments provided on feedback forms or surveys and questions or information sent to our support services.
l.	Account login credentials: such as username and password, and security information related to your account with us
m.	Payment information: such as credit or debit card number and bank account details to facilitate payment on behalf of insurers.
n.	Driving history, certifications and insurance details: such as driving licence details, the period for which a licence has been held, existing and previous insurance policy details, previous accident and claims history and details of any motoring convictions. We collect this as part of your insurance application and/or administration of your insurance policy.

 

How we Use the Personal Information We Collect

We use the personal information we collect from you as follows:

a.	offer, administer and manage the insurance products you are subject to, including providing initial and renewal quotations and client care information;
b.	carry out due diligence, identity, credit reference, bankruptcy, sanctions, data validation, anti-money laundering, “Know Your Customer” and other business acceptance, vetting and risk management agency checks;
c.	evaluate risks relating to your or your organization’s prospective or existing insurance policy;
d.	process payments, including your payments for the insurance premium and any mid-term adjustments;
e.	administer, investigate, and settle claims or complaints in relation to the insurance products you are subject to;
g.	enforce our agreements, trace debtors and recover any outstanding debt in connection with the insurance products you are subject to (such as for unpaid premiums);
h.	fulfil legal and regulatory obligations, resolve disputes and monitor compliance with the same;
k.	perform analytics for risk modelling purposes and to analyze trends in the insurance industry;
l.	Subject to our obligations under applicable anti-spam laws, canvass your views about our products, sending you offers regarding other products, services and events that may be of interest to you, including sending newsletters and promotional materials; and
n.	communicate with you and to respond to your requests, inquiries, comments and concerns.

 

If you are applying for employment with us we will collect certain personal information from you as part of the application process including your name, address, email address, and any information provided on your cover letter, resume or through the assessment and interview process.  In addition, if you are considered for employment with Brown & Brown, we may ask for your consent to run a background and references check which may be performed by us or through our 3rd party background check vendor.

If you are hired by Brown & Brown, any personal information collected as part of your employment will be subject to Brown & Brown’s Employee Privacy Policy.

In addition to the foregoing, we may use personal information we have collected from you to generate aggregated and anonymized data (“Aggregated Data”). Aggregated Data cannot and does not identify you and does not constitute personal information. We may use and disclose Aggregated Data for a number of purposes including improving our Platforms and market research. Our use and disclosure of Aggregated Data is not subject to the terms of this Privacy Policy.

Automated Collection of Information and Interest-Based Advertising

We use cookies, web beacons, third-party analytics and other tracking mechanisms to track your use of our website and mobile application (collectively, our “Platform”. As you use a Platform, these tracking mechanisms may automatically collect information such as: your IP address, browser type and operating system; web pages you view; links you click; how you move through the Platform including the length of time you use the Platform or particular features or pages of the Platform; and the referring URL, the webpage that led you to the Platform or your general location. We may combine this information with other personal information we collect about you for statistical purposes, for measuring effectiveness of advertising and for fraud detection.

We also use these tools to provide you with a more personalized user experience, to better understand your needs and preferences, to provide you with content (including advertising) that is most relevant to you and to monitor trends respecting the usage of our Platforms.

Do-Not-Track

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies or opting out of ad networks as described further in this section).

Cookies. Cookies are pieces of information that are transferred from websites to your computer’s hard drive and they may serve a variety of purposes. Web beacons, flash cookies and other similar technologies may also be used for these purposes. For example, cookies “remember” you when you return to a website and make your experience more user-friendly. Cookies identify which web pages are visited and how often. Cookies are also used to allow companies to better understand how their websites are used to improve their services.

How to disable or delete cookies

If you want to prevent your browser from accepting cookies, if you want to be informed whenever a cookie is stored on your computer or if you want to delete cookies from your computer, please make the necessary changes in your Internet browser settings, typically under the sections “Help” or “Internet Options”. See links below:

• Internet Explorer: //windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-9
• FireFox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
• Chrome: https://support.google.com/chrome/answer/95647
• Safari: https://www.apple.com/legal/privacy/en-ww/cookies/

If you disable or delete cookies in your Internet browser settings, you might not be able to access important functions or features, you will be required to re-enter your log-in details and your use of the Platform may be limited.

Please note that if you clear all cookies on your browser, or use a different browser or computer, you will need to complete the opt-out procedure again.

To opt out from flash cookies, please click here: //www.adobe.com/privacy/opt-out.html.

Web Beacons/Pixels. Web beacons or “pixels” are tiny graphics that are deployed on websites and email, similar in function to cookies. In contrast to cookies, though, web beacons are embedded invisibly on web pages.  These “images” are automatically loaded to your browser/device when you visit our platform or open an html format email message from us, thereby letting us know if a certain page was visited or an email message was opened. Pixels allow us to record user actions related to our platform and to email communications received from us, to help us determine the usage and effectiveness of our platform and communications.  We might use pixels to track the behaviour of our visitors and app users, identify the site or app which you were directed from, help us manage content, and compile statistics about usage across our digital properties. We and our third-party service providers also might use pixels in HTML e-mails to our customers, to help us track e-mail response rates and identify when our e-mails are viewed or clicked on.

Web beacons may be able to be blocked either by using a third-party application such as Ghostery (https://www.ghostery.com), or, in the case of emails, by changing your settings to prevent images from being downloaded (where your email client supports this functionality).

Third-Party Analytics. We also use automated devices and applications, such as Google Analytics (https://support.google.com/analytics/answer/6004245) (to opt out, go here (https://tools.google.com/dlpage/gaoptout) to evaluate usage of our Platforms.  We use these tools to obtain aggregated statistical information about the use of our Platforms to help us improve our services, performance and user experiences.  These analytics providers may use cookies and other technologies to perform their services, and may combine the information that they collect about you on our Platforms with other information that they have collected about you from your use of other sites.

Third-Party Ad Networks. We may use third parties such as network advertisers to serve advertisements on our Platforms and on third-party websites or other media, and to evaluate the success of our advertising campaigns. This enables us and these third parties to target your browser with advertisements for products and services in which you might be interested, based on inferences made from browser activity. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons, and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. In some situations, we may provide these third-party advertisers with limited information about users (e.g., IP address and basic demographic information solely for the purpose of reconciling payments for third party advertising), but we do not disclose details such as your name or contact information. You may be able to avoid targeted ads by certain ad networks by blocking cookies (see your browser’s “Help” menu for information on how to do this); however, our Platform may not work if you block or disable cookies. For participating ad networks and providers of interest-based advertising, you may opt-out of receiving online behavioural advertising by clicking on the AdChoices icon located in the top righthand corner of any of our websites or in the ads placed on our sites.

Location Data: Most devices provide users with the ability to change device permissions (e.g., disable/access location services) and these controls are located in the device’s settings menu. If you have questions about how to change your device permissions on devices manufactured by third parties, we recommend you contact your mobile service carrier or your device manufacturer.

How We Disclose Your Personal Information

We will not disclose any personal information we collect from you to any third parties except as follows:

• Our Affiliates. We may disclose your personal information to any of our affiliates within the Brown & Brown corporate group to the extent that these affiliates require such personal information and only employees or service providers of these affiliates which require such personal information to perform their duties will have access to it.
• Insurance Market Participants. Where necessary to offer, administer and manage the insurance products provided to you, we may collect your personal information on behalf of, or otherwise disclose your personal information to, insurers and insurance underwriters, reinsurers, brokers, intermediaries and loss adjusters. The insurance underwriter is the insurer that is underwriting your insurance statement and is named in your policy documentation. When we collect your personal information on behalf of, or otherwise disclose your personal information to, an insurer, the insurer’s use and disclosure of your information is subject to its privacy policy. You should refer to the insurer’s privacy notice on their website for further information about their privacy practices;
• Risk management agencies: such as credit reference, criminal record, fraud prevention, data validation and other professional advisory agencies, where necessary to prevent and detect fraud in the insurance industry and take steps to assess the risk in relation to prospective or existing insurance policies and/or the Services;
• Service Providers. We may disclose your personal information to our service providers who perform certain services necessary to run our business (for example, data hosting and payment processors) to the extent that they require such personal information to perform their duties.
• When Reasonably Required. We may disclose your personal information when we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud or respond to a government, judicial or other legal request, or to comply with the law. This includes sharing your personal information with legal advisers, loss adjusters, and claims investigators where necessary to investigate, exercise or defend legal claims, insurance claims or other claims of a similar nature.
• Corporate Circumstances. We may disclose your personal information in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business.

 

Protecting Your Personal Information

At Brown & Brown we take the protection of your personal information seriously. We make every reasonable effort to prevent unauthorized use, disclosure, loss or theft of your personal information. Employees who have access to your personal information are made aware of the importance of keeping it confidential.

Where we use service providers who might have access to your personal information, we select them carefully and require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to ensure that they maintain the confidentiality and security of your personal information and to prevent such information from being used for any other purpose.

Please be aware that no data security measures can guarantee complete security. You should also take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. If you do not want Brown & Brown to know any particular information about you, you should not include that information in anything you submit or post to the Platforms.

Transfers outside Canada

Some of Brown & Brown’s service providers are located outside of Canada, including in the United States.  As a result, your personal information will be used, stored and/or accessed in countries outside of Canada, including the United States. However, all such information will be protected in accordance with this Privacy Policy. Please note that when your personal information is located outside of Canada it will be subject to the laws of the country in which it is situated.

Retaining Your Personal Information

We will only retain your personal information as long as is necessary for the fulfillment of the purposes for which it was collected or as required by law. Your personal information is securely stored until such time as it is no longer required, after which it is destroyed or rendered such that it is unable to identify you.

Your Choices And Rights

• Access And Modify: You may be able to access or modify certain inaccurate information in your user account on a Platform by logging in to the “My Account” or similar area of the applicable Platform. Where a Platform does not have the “My Account” feature, you may access or amend the personal information we hold about you by contacting us using the contact information in the “How to Contact Us” section below.

Please note that your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you such as when such information also includes the personal information of a third party.  In addition, the personal information may have been destroyed, erased, or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

• Withdrawal Of Consent. You also may also withdraw your consent to certain of our uses and disclosures of your personal information. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.
• Right To Lodge A Complaint. Although we ask that you first contact our Privacy Officer at the contact details below if you believe that any of your rights regarding our collection, use, and disclosure of your personal information may have been violated, you have, at all times, the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy thought the courts.

We will not retaliate against an individual who, in good faith and on the basis of reasonable belief, raises questions or concerns regarding their personal information.

When requesting access to or seeking to enforce any of your rights regarding your personal information, we may request specific information from you to enable us to confirm your identity.

Links To Third-Party Websites and Services

For your convenience and information, our Platforms may contain links, banners, widgets or advertisements that lead to other websites not owned or operated by us. For example, a Platform may include tools that allow you to share and/or publicly post content or information from the Platform to your profile on a third-party social network.  We are not responsible for these other sites or applications, and their posted privacy policies (not this Notice) will govern the collection and use of your information on them. We encourage you to read the privacy statements of each website or application visited after leaving our Platform to learn about how your information is treated by others.

In addition, we use several social networking platforms to communicate with our customers, some of which are operated by third parties, such as Facebook. This Privacy Policy applies to our use of information you submit to us on such platforms, but it does not apply to what those third party platforms do with your information.

Roles And Responsibilities

Brown & Brown is responsible for communicating this Privacy Policy and ensuring that our employees understand and respect it as well as any accompanying guidelines.

Our managers are responsible for ensuring that both they, and all of their employees, comply with the requirements of this Privacy Policy.

Our employees are responsible for complying with this Privacy Policy and for informing their manager or their manager’s manger whenever they become aware of processes or practices that appear to contravene this Privacy Policy or applicable laws.

Our Privacy Officer is responsible for: i) developing our personal information protection strategy; ii) developing and maintaining this Privacy Policy, accompanying guidelines and any other policy or procedure related to personal information and ensuring they comply with applicable law; and iii) serving as the official liaison with the federal and provincial commissioners.

Updates to this Privacy Policy

This Privacy Policy or our other privacy related documents will be updated from time to time or replaced with a new policy. You are responsible for reviewing this Privacy Policy periodically and informing yourself of any changes to this Privacy Policy. This Privacy Policy may be obtained by contacting our Privacy Officer (please see the “How to Contact Us” section below)

How to Contact Us

If you have any questions related to our practices with respect to the collection, use or disclosure of personal information, including our policies and practices with respect to our use of service providers outside Canada, or if you wish to complain to us in writing about how we have handled your personal information, please feel free to contact our Privacy Officer us at:

John Carlton, Customer Privacy Department

jcarlton@bbrown.com