PRIVACY POLICY

General Information

The GBG group of companies includes insurance companies, brokering and management companies, as well as assistance and operations companies (the “GBG Group”). GBG is the trade name for GBGI Limited and its subsidiary and affiliated companies. We are all committed to ensuring your privacy and personal information is protected.  The document that referred you to this notice (for example, a short form privacy notice in an application form or terms and conditions in your insurance policy) shall set out details of the GBG company that is processing your personal information; it is the data controller of your personal information and is responsible for complying with applicable data protection laws. For the purposes of this Privacy Policy, references to “Company,” “we,” or “us” shall refer to that GBG company.

Section 1 below provides users of our website with information about the cookies and web analytics we use on our websites.

Section 2 sets out our overall Privacy Policy and provides you with information on the types of personal information we collect, why we collect it and how we use it. This Privacy Policy should be brought to the attention of any individual who is included in your communications with us for the purposes of entering into or having entered into a contract with us and where they have given you consent to act on their behalf. 

By providing your personal information or the personal information of someone included in your policy, you acknowledge that we may use it only in the ways set out in this Privacy Policy. “Personal Information” is information that identifies and relates to you or other individuals (such as your dependents) and we detail this in Section 2 below.  Our aim is responsible handling of Personal Information.  We respect your privacy and are committed to protecting it through compliance with this Policy.

Last Updated: January 2022

This Privacy Policy applies to information we collect:

  • On this Website, the software applications made available by us for use on or through computers and mobile devices (“Apps”) (collectively, including the Website and the Apps, referred to as the “GBG Online Services”); and 

  • Other means (for example, from your application and claim forms, telephone calls, emails, and other communications with us, as well as from claim investigators, medical professionals, witnesses or other third parties involved in our business dealings with you).

A) General information on logfiles and cookies

How/ Where Do We Collect the information

Log files

We collect certain data that your browser transmits to our website server (i.e. log files). Our log files contain the following information: (i) date and time of retrieval of our GBG Online Services, (ii) type, version and settings of your web-browser, (iii) your operating system and internet service provider, (iv) requested pages and files, (v) website used prior to visiting our Website as well as (vi) your IP-address. The IP address is a specific number assigned to your computer which enables your device to communicate in a network using the Internet Protocol (IP). IP addresses may qualify as personal data as they technically allow the identification of the user in certain circumstances. 

The processing of these log files is necessary for us to maintain the functionality, stability and security of our GBG Online Services. We may also process them for the purpose of forensic investigations in the case of a security incident or in order to generate user statistics. For statistical purposes your IP-address is used in anonymized form only.

Log files are generally kept for a period of approximately three months. Beyond this time period log files will only be stored for the purpose of investigating irregularities or security incidents in our system.

Cookies and similar technologies

We also collect information through “Cookies” and other similar technologies to remember you when you visit the GBG Online Services. Cookies are text files placed on your computer or device when you visit a website or online service to recognize your browser or device. Cookies may store unique identifiers, visitor preferences and other information. This information is used to track and help us understand how you and others use the GBG Online Services, view our products and respond to advertising so we can enhance our overall product and service offering. When we refer to “cookies” we include other technologies with similar purposes, such as pixel tags.

We use the following types of cookies:

Necessary Cookies. These cookies are necessary for you to browse the Site and use its features, such as accessing secure areas of the Site. Without these cookies, certain aspects of the GBG Online Services may not be available to you. The use of necessary cookies on our GBG Online Services is possible without your consent. However, you can deactivate cookies at any time by modifying your browser settings. For a detailed description of the used necessary cookies and respective purposes kindly see the table below.

The following optional cookies will only be used upon your consent which you may provide by clicking "OK" on our Website's cookie banner. This consent can be withdrawn at any time with effect for the future. Optional cookies may also be placed by external advertising companies ("third party cookies"). Although visitors are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through our GBG Online Services. For a detailed description of the used optional cookies and respective purposes kindly see the table below.

Preferences Cookies. These cookies collect information about how you have used the Site in the past and allow the Site to remember the choices you have made. These cookies allow us to improve how the Site works for you and tailor the Site to your preferences. 

Statistics Cookies. These cookies collect information about how you use the Site, such as which pages you most often visit on the Site, the time you spend on the Site, which links you click on, and any issues encountered. These cookies help us understand how visitors interact with the Site. All information collected is aggregated and do not identify you.

Marketing Cookies. These cookies track your online activity to help deliver advertisements that are relevant to you and your interests and measure the effectiveness of the advertising campaigns. They also limit how many times you see a certain advertisement. We may share the information collected through these cookies with others, such as advertisers

Necessary cookies used on our GBG Online Services:

Cookie name

Purpose

Storage period

GBGMemberPortalWebOid 

AuthenticationToken - A token is set at the time of user login. For every API requests from UI, this authentication token is passed in the header of request to validate the user access.

Until User Logs out/Closing browser

GBGProductPortalApplicationCookie

To store the Culture info and previous URL. Culture info is a language code being used to manage language selection. For example, if the selected culture is 'en-GB' portal language would be switching to English and load all texts in English language. Previous URL parameter is not being used.
Current Usage: Current implementation of language selection does not use this cookie to store user-selected language. This cookie could be removed if required.

Until User Logs out/Closing browser

currentsession

Sets at the time of user login. It Stores user information which Includes - Token, IP Address, GroupId, UserId, GroupName, Email, Username, Permissions
Usage - Token is used to validate all API requests, IP Address to identify user location, GroupId and  Group Name to identify the group of logged In user, Permissions is set to limit access to different sections of the portal. 

Until User Logs out/Closing browser

GBGProductPortalWebFulfilmentOid

To store authentication token for Fulfillment login. An encrypted string generated after user login and being used to pass along with each API call to ensure authentication

Until logout or browser closing

GBGProductPortalWebOid

To store authentication token for Product Portal login. An encrypted string generated after user login and being used to pass along with each API call to ensure authentication

Until logout or browser closing

GBGProductPortalAccessToken

Access token to get the Portal details, which is stored in an encrypted form

Until browser closing

GBGProductPortalWebAuthToken

It’s used to store User details like FirstName,LastName,Role etc, who got successfully authenticated in Product Portal

Until logout or browser closing

GBGProductPortalFulfilmentWebAuth

It’s used to store User details like FirstName,LastName,Role, email, applicationid etc, who got successfully authenticated in the fulfillment section

Until logout or browser closing

GBGApplicationCookie

To store the Culture info and previous URL. Culture info is a language code being used to manage language selection. For example, if the selected culture is 'en-GB' portal language would be switching to English and load all texts in English language. Previous URL parameter is not being used

Until logout or browser closing

X-Auth-Token

To store authentication token. An encrypted string generated after user login and being used to pass along with each API call to ensure authentication

Until logout or browser closing

user_info

To store user full name & roles. User role is used to check whether the particular role has access in the requested page/url. Example. 'Admin' role would only have the permission to access admin pages

Until logout or browser closing

username

To take the logged in username to be used across the templates.

Until logout or browser closing

IPAddress

Use to store web server IP address to log the same in student enrollment information: This is not in use

Will expire only during the browser cache clear

AgentId

Use to store agent code to log the same in student enrollment information

Will expire only during the browser cache clear

ErrorUrlType

To store type of return url whenever an error occurs during payment

Will expire only during the browser cache clear or once payment done

ErrorUrl

To store url of return url whenever an error occurs during payment

Will expire only during the browser cache clear or once payment done

CancelUrl

To store url of return url on cancel button event

Will expire only during the browser cache clear or once payment done

CancelUrlType

To store type of return url on cancel button event

Will expire only during the browser cache clear or once payment done

SessionKey

To store the session key of originated portal

Will expire only during the browser cache clear or once payment done

IsDatafromExternal

To identify whether payment is initiated from an external portal. True if it is initiated in integration flow

Will expire only during the browser cache clear or once payment done

_ga

To store google analytics code for identifying GBG domain.
Currently Not in Use

Will expire only during the browser cache clear

_gid

To store google analytics code for identifying GBG domain.
Currently Not in Use

Will expire only during the browser cache clear

IDE

It is a part of request from google analytics. Refer https://en.wikipedia.org/wiki/DoubleClick

Will expire only during the browser cache clear

Optional cookies used on our GBG Online Services

Cookie name

Purpose

Storage period

password

Only used when remember password option is selected

Until logout or browser closing

Web Analytics

Google Analytics

In case you have consented to the use of cookies by us, our GBG Online Services uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (Google). Google Analytics uses cookies to help the GBG Online Services analyze how users use the site. 

The information generated by the cookie about your use of our GBG Online Services (including your IP address and the URLs of the accessed pages) will be transmitted to and stored by Google on servers in the United States. We do not store any of your personal data collected in connection with Google Analytics.

Our GBG Online Services may use an IP anonymization feature provided by Google Analytics. Your IP address will therefore be truncated/anonymized by Google as soon as it receives it. On our behalf, Google will use this information for the purpose of evaluating your use of our GBG Online Services, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to us. Google will not associate your IP address with any other data held by Google.

We process your personal data for purposes of Google Analytics based on your consent which you may provide by clicking "OK" on our GBG Online Services' cookie banner. This consent can be withdrawn at any time with effect for the future. You may also refuse the use of cookies by selecting the appropriate settings on your browser (see the below section). However, please note that if you do this, you may not be able to use the full functionality of our GBG Online Services. Furthermore, you can prevent Google's collection and use of your data by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout.

Further information concerning Google's terms of use and privacy statement can be found at https://www.google.com/analytics/terms/gb.html.

How to control and manage the use of cookies

By clicking on the "OK"-button in the Website's cookie banner you agree to the use of the above listed optional cookies on our GBG Online Services. Your consent can be withdrawn (for all or individual cookies) at any time with effect for the future.

You may also refuse the use of cookies by selecting the appropriate settings on your browser or by deleting the cookies from the device and browser. Most browsers accept cookies automatically, but you can alter the settings of your browser to erase cookies or prevent automatic acceptance if you prefer. Generally, you have the option to see what cookies have been placed and delete them individually, block third-party cookies or cookies from particular sites, accept all cookies, to be notified when a cookie is issued or reject all cookies.

You should be aware that any preferences will be lost, if you delete all cookies and many websites will not work properly or you will lose some functionality. We do not recommend turning cookies off when using our GBG Online Services for these reasons.

Updates to this policy

We may update this Notice to reflect legal, technical or business changes. When we update this Notice, we will take reasonable steps to inform you about the changes made. You will find the date of the "last update" at the beginning of this Notice.

GBG is committed to maintaining the privacy of its insureds, customers and other individuals for which it may control data.  For more information on how we maintain your privacy, please refer to our Privacy Policy (See Section 2).

Disclaimer

The GBG Online Services contains links to third-party websites. We have no control over the content or privacy practices of these other websites. Please read the respective data protection provisions of other websites that you visit.

If you have any questions about this Privacy Policy or our use of your Personal Information, please write to us at dataprotection@gbg.com or by postal mail at:

Global Benefits Group, Inc.Attn: Legal Department
7600 Corporate Center Dr #500,
Miami, FL 33126
USA 

GBG Insurance LimitedAttn: Legal Department
Fourth Floor, Albert House
South Esplanade
St Peter Port, Guernsey, GY1 1AW

Global Benefits Europe B.V.Attn: Legal Department
Penningkruid 20, 3984 BK
Odijk
Netherlands 

Global Benefits Group (UK) LimitedAttn: Legal Department
2 Seething Lane
London, EC3N 4AT
United Kingdom

Depending on your relationship with us (for example, as a consumer policyholder; insured person benefiting under another policyholder’s policy, or claimant; witness; commercial broker or appointed representative; or other person relating to our business), we may receive Personal Information about you and your dependents for example when:

  • You request or obtain a quote

  • You purchase a GBG product from us or one of our partners, brokers, or other third parties

  • You use GBG online services

  • You telephone, text, or write by post or email to the GBG Group

  • You make a claim

    This information may include: 

General identification and contact information 
Your name; address; e-mail and telephone details; gender; marital status; family status; date of birth; passwords on our systems; educational background; physical attributes; activity records, such as driving records; photos; 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; or driver’s or other license number.

Financial information and account details 
Payment card number; bank account or other financial account number and account details; credit history and credit score; assets; income (including salary); and other financial information.

Sensitive Personal Information

  • Medical condition and health status 
    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 sensitive information 
    In certain cases, we may receive sensitive information about you, but it will not necessarily be processed. This may include information about your race or ethnic origin, politics, religious beliefs, trade union membership, genetics, biometrics, sex or sexual orientation, or criminal convictions and offenses (including information about suspect criminal activities).

Where we collect any of this type of information (known as “sensitive” or “special category” information) we will always be clear to explain when and why we need it, and the purposes for which we will use it, and, where required by law, we will obtain your explicit consent before we use it.

Telephone recordings 
Recordings of telephone calls to our representatives and call centers.  

Photographs and video recordings
Photographs or video recordings created in connection with our insurance or other business activities, including for claims assessment, processing, settlement, and disputes, or for other relevant purposes as permitted by law. 

Information to investigate or prevent 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 products and services 
Location and identification of property insured; travel plans; age categories of individuals you wish to insure; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organization; and other insurance you hold.

Personal Information about others

We may collect information about other members of your household or family, for example, family members who may be included on a travel or health insurance policy or on whose life you take out a life insurance policy.

If you give us information about another person, it is your responsibility to ensure and confirm that:

-       you have told the individual who the GBG Group is and how we use personal information, as set out in this Privacy Policy; and

-       you have permission from the individual to provide that personal information (including any sensitive personal information) to us and for us to process it, as set out in this Privacy Policy.

We collect information from the GBG website (through Cookies and similar technologies)

We collect information through “Cookies” and other similar technologies to remember you when you visit our website [and Mobile Apps]. Cookies are text files placed on your computer or device to collect standard internet log information and visitor behavior information. This information is used to track and help us understand how you and others use our website and Mobile Apps, view our products, and respond to advertising so we can enhance our overall product and service offering.

To find out more about Cookies and related technologies that we use, please read our separate Cookies Policy.

For further information about Cookies in general, visit www.aboutcookies.org or www.allaboutcookies.org

You can set your browser not to accept cookies or to alert you to when websites set or access cookies. The above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may become inaccessible or not function as a result.

We collect information from GBG Mobile Apps

We collect information via other online channels

Services that our website may use from time to time include analytics providers such as Google. These services transmit website traffic data to search engine servers in the United States.  We use reports provided by web analytics providers to help us understand website traffic and webpage usage.

We collect information from search information providers

We collect information from Third-Parties

We may collect information about you from third parties such as:

-       your insurance intermediary or other organizations providing services to them;

-       your employer;

-       your health professional;

-       other insurers (directly or using shared databases such as a register of claims); 
-    other third-party databases which have been established to help detect and prevent fraudulent activity; and

-    other publicly available sources such as social media, commercially available sources, and information from our affiliates or business partners.

Your Personal Information is collected in order for us to provide our services, administer your plan and, in general, conduct insurance business in line with the services you are entitled to.

We use the Personal Information collected:

a) In relation to any quotes requested, or your insurance products and services taken out to enable us to perform the contract we are about to enter into or have entered into with you:

  • Communicate with you and others as part of our business; 

  • Send you important information regarding changes to our policies, other terms and conditions, our GBG Online Services, and other administrative information;  

  • Provide quotes and make decisions about whether to provide insurance and assistance services, and other products and services which we offer, and provide such products and services, including claim assessment, processing, and settlement; and, where applicable, manage claim disputes; 

  • Process your premium and other payments;  

  • Identify you to anyone to whom you send messages through any of the GBG Online Services;

Without the Personal Information collected we may be unable to offer, accurately underwrite or administer your policy, product, or service. 

b) To ensure we are able to adhere to legislation and regulatory obligations such as to: 

  • Prevent, detect, and investigate crime, including fraud and money laundering; 

  • 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, sanctions, and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence);  

c) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This will enable us to effectively manage our business, such as to: 

  • Provide improved quality, training, and security (for example, with respect to recorded or monitored phone calls to our contact numbers);  

  • Assess your eligibility for payment plans; 

  • Carry out research and analysis, and manage other commercial risks, including analysis of our customer base and other individuals whose Personal Information we collect as explained in this Privacy Policy;

  • Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; data analytics; business continuity; and records, document, and print management;  

  • Establish and defend legal rights; protect our operations or those of any of our group companies or business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.

 

As we are an international business, we may share and aggregate information about you from across the GBG Group, including personal information held within the GBG Group relating to other policies held with us, quotes or claims details and, depending on your preferences, we may use this information to:

  • help us identify products and services that may be of interest to you, to tailor and package our products and services;

  • to determine pricing and/or offer available discounts; and

  • Conduct customer research and develop marketing campaigns. 

If you request a quote, or purchase a product or service from us, your personal information will be used and shared within the GBG Group for the purposes of administration (including underwriting, determining premiums, managing claims and offering renewals). We will use your information to communicate with you about your quote, product or service, including improvements we make to the ways you can access your information.

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

GBG may make your information available to:

Insurance and Distribution Parties

In the course of marketing, providing insurance (for instance if you request a quote, or purchase a product or service) and processing claims, your personal information may be shared with and processed by our associated companies, introducers, intermediaries, insurers, reinsurers, insurance and reinsurance brokers, and their agents or appointed representatives, other distributors, affinity marketing partners, financial institutions and securities firms as well as the policyholder (for a corporate policy) and your broker or agent for the purposes of administration (i.e. progressing a claim made by you), including third parties providing services to them, (as detailed above). 

Our service providers

External third-party suppliers or service providers, such as medical professionals, accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; travel and medical assistance providers; call center service providers; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; banks, financial institutions and other parties that administer payments and receipts on behalf of our accounts; third-party claim administrators; document and records management providers; claim investigators and adjusters; examiners; jury consultants; translators; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities, for example, to help administer your policy, to help us manage and store data, provide data analytics, conduct market research and to communicate with you effectively. This may include any online or digital partners we work with, so we, or our online or digital partners on our behalf, can communicate with you through their platforms. Regulatory bodies

We may share your information with regulatory bodies [in the UK and overseas] as well as with other insurance companies (directly and via shared databases) to prevent and detect fraud. 

Governmental authorities and third parties involved in court action

GBG may also share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies) in response to lawful requests by such public authorities; 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: (a) to comply with national security or other law enforcement requirements; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to comply with applicable law, including laws outside your country of residence; (e) to enforce our terms and conditions; (f) to protect our operations or those of any of our family of companies; (g) to protect our rights, privacy, safety or property, and/or that of our family of companies, you or others; and (h) to allow us to pursue available remedies or limit our damages. Other Third Parties

We may share Personal Information with payees; emergency service providers (fire, police and medical emergency services); retailers; medical networks, telemedicine organizations, other 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, assets or stock. 
GBG may disclose your Personal Information as described above, but only in good faith and for the limited and specified purposes described in this notice.  

GBG will only share your information for marketing purposes outside the GBG Group where you have consented to marketing. See the Marketing section below for more information. 

In the event we share your Personal Information, we will take appropriate measures to protect your privacy and the Personal Information we transfer. 

We require all third parties to respect the security of your Personal Information and treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and we only permit them to process your Personal Information for specified purposes and in accordance with our instructions. 

In addition, if we learn that third-party is using or disclosing your Personal Information in a manner that is contrary to this Policy, we will take reasonable steps to prevent or stop such use or disclosure. GBG may be liable for onward transfers of Personal Information to third parties in violation of this Policy and the U.S. Privacy Shield.

We operate internationally, and some of the processes involved in our use of your Personal Information will require your Personal Information to be stored or processed in countries outside the country where you are located, including countries that may not have laws that provide the same degree of protection for Personal Information as your home country. In particular, your Information may be transferred to, and processed in the United States, where many of our systems are located.

Please see GBG Group Company Details for examples of the countries where your Personal Information may be transferred. 

Whenever we transfer your Personal Information outside of a country or region, such as the European Economic Area, we will make sure that we take the steps necessary to comply with applicable legal requirements. Therefore, where required, we will ensure that appropriate safeguards are in place by using appropriate contractual mechanisms, such as the EU Standard Contractual Clauses, or by relying upon the service providers participating in an approved international data transfer mechanism. For further information about the documents we use to protect your Personal Information when it is transferred outside of your country or region, please submit a request to dataprotection@gbg.com.
The GBG Group’s U.S. entities also adhere to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and its Member States, the European Economic Area, the United Kingdom and/or Switzerland to the United States.  We recognize that the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield are no longer valid transfer mechanisms for personal information from the European Union and its Member States, the European Economic Area, or Switzerland. The U.S. Department of Commerce, which oversees compliance with Privacy Shield, has stated that it will nonetheless continue to administer the Privacy Shield program and that participants are not relieved of their obligations under Privacy Shield. Accordingly, our companies in the U.S., as participants in the Privacy Shield program, will continue to comply with its commitments under the Privacy Shield and its robust internal data protection policies. 

The GBG Group’s U.S. entities have certified to the Department of Commerce that they adhere to the Privacy Shield Principles with respect to such information.  If there is any conflict between the terms in our Privacy Shield statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

You will receive marketing communications from us if you have requested information from us or obtained insurance products and services from us and in each case you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your Personal Information with any company outside the GBG group of companies for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt-out of receiving these marketing messages this will not apply to Personal Information provided to us as a result of a product or service you have purchased from us, product/service experience or other transactions.

If you no longer wish to be contacted for marketing purposes, please contact marketing@gbg.com.

GBG will only process Personal Information in ways that are compatible with the purpose that GBG collected it for, or for purposes which you might later authorize. We will only keep your information for as long as is necessary and in accordance with any relevant legislation, accounting or reporting requirements. 

To determine the appropriate retention period for Personal Information we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use of disclosure, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

Before we use your Personal Information for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt-out. 

GBG maintains procedures to help ensure that Personal Information is reliable for its intended use, accurate, complete, and current.

GBG will take appropriate technical, physical, legal, and organizational measures, which are consistent with applicable privacy and data security laws. 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 Information you might have with us has been compromised), please immediately notify us. See contact information above.

When GBG provides Personal Information to a service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the Personal Information. 

We will put in place procedures to deal with any suspected Personal Information breaches. We will notify you and any applicable regulator of a breach when we are legally required to do so.

Persons covered by the European Union General Data Protection Regulation (“GDPR”), or other data privacy regulation, may have the following rights in accordance with the applicable data protection provisions:  

Right to access, rectification, and erasure

You may have the right to access the Personal Information that we hold about you and to request that we correct, amend, or delete it if for example, it is inaccurate or processed unlawfully. These rights may be restricted in some cases, including where requests are manifestly unfounded or excessive under the circumstances or where it would violate the rights of someone else. If you would like to request access to, correction, amendment, or deletion of your Personal Information, you can submit a written request to the contact information provided above. We may request specific information from you to confirm your identity.        Right to restriction of processing

You may have the right to “block” or suppress processing of your Personal Information in certain circumstances, for example where you think that the Personal Information we hold about you may be inaccurate or where the processing is unlawful and you oppose the erasure of the Personal Information and request the restriction of their use instead. 

Right to data portability

You may have the right to data portability in certain circumstances, which allows you to obtain and reuse your Personal Information for your own purposes across different services or request transfer to another controller, where technically feasible. 

Right to object

You may have the right to object to the processing of your Personal Information in certain circumstances including where your information is used for direct marketing or for purposes of scientific/historical research and statistics. 

Right to withdraw consent at any time

Where our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent, we will stop processing your personal information for that purpose, unless it is necessary for us to continue processing your information based on another lawful basis. Your withdrawal of your consent won’t impact any of our processing of information about you prior to withdrawing your consent.  The withdrawal of your consent may prevent us from processing any request made by you or offering insurance coverage or services or impede our ability to pay a claim. 

If you wish to withdraw this consent, please email us at dataprotection@gbg.com. 

Right not to be subject to automated decision making

As we use systems which make decisions based on automated processing of your Personal Information, you may have the right to obtain human intervention, express your point of view and to obtain an explanation of the decision and challenge it. 

Right to lodge a complaint

You may file a complaint about how we have handled your Personal Information. Please do not hesitate to contact us using the contact details provided above to ensure that it is resolved without delay. Please note that in some cases we may not be able to comply with a request you have made for reasons such as our own obligations to comply with other legal or regulatory requirements. However, we will always respond to any request or complaint you make and if we cannot comply with your request, we will tell you why. 

In addition, for European data subjects, pursuant to GDPR you have the right to lodge a complaint with the competent Supervisory Authority if you believe that your Personal Information has not been processed in accordance with the relevant legislation and regulatory requirements. More information on the national supervisory authority can be found under: https://edpb.europa.eu/about-edpb/board/members_en

For those in other jurisdictions, applicable laws may also give you the right to lodge a complaint with the data protection authority in your country. 

In compliance with the Privacy Shield Principles, we commit to resolve complaints about the collection or use of your Personal Information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us using the contact details provided above.  

We have further committed to cooperate with the panel established by the EU Data Protection Authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship. 

Under certain limited conditions, by providing notice to us, you may invoke binding arbitration regarding certain residual claims about EU Personal Information before a Privacy Shield panel.  Such procedure is in accordance with the rules established under the Privacy Shield.  

Please note, we are subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”).

 

The GBG Online Services are not directed to individuals under the age of sixteen (16), and we request that these individuals do not provide Personal Information through the GBG Online Services.

GBG Group

Wherever the name “GBG” is used on the Website, this implies one or more of the following companies within the GBG Group of companies: 

Guernsey:
GBGI Limited

A company incorporated in the Bailiwick of Guernsey with company number 48728 and whose registered office is at Fourth Floor, Albert House, South Esplanade, St Peter Port, Guernsey GY1 1AW. 

GBG Insurance Limited

An insurance company incorporated in the Bailiwick of Guernsey with company number 42729 and whose registered office is at Fourth Floor, Albert House, South Esplanade, St Peter Port, Guernsey GY1 1AW. 

United Kingdom:Global Benefits Group (UK) Limited

A company registered in England and Wales with registered number 9988615 having is registered office at Suite 102 7th Floor, 8 Devonshire Square, London, EC2M 4PL United Kingdom. GBG UK is an Appointed Representative of SP Financial Management Ltd which is authorised and regulated by the Financial Conduct Authority.

Netherlands:Global Benefits Europe B.V.

A European Union admitted broker and company authorized and regulated by the Dutch Authority for the Financial Markets (AFM) under License number 12016341, having its registered office at Penningkruid 20, 3984 BK, Odijk, Netherlands. 

Serbia:     
Predstavnistvo Global Benefits Group

A company registered in Serbia with registered number 29017816 and whose registered office is at Bulevar Zorana Djindjica 81/VI/17, 11070, Novi Beograd, Serbia. 

United States:
GBG Assist, Inc.

A company incorporated in Delaware, USA with company number 5835702 and with offices located at 7600 Corporate Center Dr #500, Miami, FL 33126 USA. 

Global Benefits Group, Inc.

A company incorporated in Delaware, USA with company number 4064823 and whose registered office is at 902 Carnegie Center, Suite 100, Princeton, NJ 08540 USA. 

GBG Holding Incorporated

A company incorporated in Delaware, USA with company number 3326953 and with offices located at 902 Carnegie Center, Suite 100, Princeton, NJ 08540 USA. 

International Claims Services, Inc.

A company incorporated in Delaware, USA with company number 2096081 and with offices located at 7600 Corporate Center Dr #500, Miami, FL 33126 USA. 

Global Benefits Group, US Inc.

A company incorporated in California, USA with company number C2758472 and with offices located at 902 Carnegie Center, Suite 100, Princeton, NJ 08540 USA. 

GBG Administrative Services, Inc.

A company incorporated in California, USA with company number C3182845 and with offices located at 7600 Corporate Center Dr #500, Miami, FL 33126 USA. 

Quality Health Management, LLC

A limited liability company incorporated in Florida, USA with company number L00000004878 and whose registered office is at 7600 Corporate Center Drive, Suite 502, Miami, FL 33126. GBG U.S. Group Holding Company

A company registered in Delaware, USA with company number 3405570 having its registered office at 902 Carnegie Center, Suite 100, Princeton, NJ USA. 

Clifford Allen Associates, Ltd.

A company registered in South Carolina, USA having its registered office at 55 Hospital Center Commons, Hilton Head Island, SC 29926-1695, USA. 

Cayman Islands:
SHIP, Ltd.

A company registered in Cayman Islands with company number 315448 having its registered office at Governors Square, Building 4, 2 Floor, 23 Lime Tree Bay Avenue, P.O. Box 1051, Grand Cayman KY1 - 1102, Cayman Islands. 

STP, SPC, Ltd.

A company registered in Cayman Islands with company number 315477 having its registered office at Governors Square, Building 4, 2 Floor, 23 Lime Tree Bay Avenue, P.O. Box 1051, Grand Cayman KY1 - 1102, Cayman Islands. 

GBG CayCo Holdings Limited

A company registered in Cayman Islands with company number 363521 having its registered office at Cayman Corporate Centre, 27 Hospital Road, George Town, Grand Cayman, KY1-9008, Cayman Islands. 

Global Wellness Administration Company

A company registered in Cayman Islands with company number 359246 having its registered office at Cricket Square, Hutchins Drive, PO Box 2681, Grand Cayman, KY1-1111, Cayman Islands. 

India:GBG Services (India) Private Limited

A company registered in the Republic of India with registration number U72200AP2010PTC071725 having its registered office at Ascent Towers, 3rd Floor, Road No. 10, Banjara Hills, Hyderabad, 500034 IND. 

Philippines:
GBG Processing and Consulting Services, Inc.

A company registered in the Republic of the Philippines having its registered office at 88 Corporate Center, Suite 1804 Sedeno cor. Valero Streets Salcedo Village, Makati City, Philippines. 

China:
Shanghai (GBG) Enterprise Management Consulting LLC

A company registered in Shanghai, China with registered number 41000002201511100000 having its registered office at Suite 2104. SCG Datang International Plaza, 868 Yinghua Road Shanghai 201204, PRC. 

Canada:
Global Benefits Group Canada Ltd.

A company registered in British Columbia, Canada with registered number BC0881084 having its registered office at 15 Allstate Parkway Suite 612, Markham, Ontario Canada L3R 5B4. 

Mexico: 
GBG Premier S.A. de C.V.

A company registered in Mexico with registered number 23180 and whose registered office is at Bosque de Ciruelos 180 PP 101, Bosques de las Lomas, Miguel Hidalgo, Mexico City 11700 Mexico. 

GBG Elite Medical Services S.A. de C.V.

A company registered in Mexico with registered number 23179 and whose registered office is at Bosque de Ciruelos 180 PP 101, Bosques de las Lomas, Miguel Hidalgo, Mexico City 11700 Mexico. 

Thailand: 
Global Benefits Group (Thailand) Co., Ltd.

A company registered in Thailand with registered number 105561034579 having its registered office at 246 Times Square Building Unit 405, Sukhmuvit Road 12-14, Khlongtoey, Khlongtoey, Bangkok 10110, Thailand. 

Paraguay: 
GBG Paraguay S.A.

A company registered in Paraguay with registered number 33Y407 having its registered office at Pascual Toledo 4461, Asuncion, Paraguay.

We keep our Policy under regular review, and we may amend it at any time and will post any updates on our website.

Please take a look at the “LAST UPDATED” date at the top of this Privacy Policy to see when it was last revised.