PICS - IPGH Private Client Insurance Services LLC
IPGH Personal Information Collection Statement (PICS)
IPGH Private Client Insurance Services LLC (referred to hereinafter as the “Company” or “IPG Howden”) recognises its responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data. Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by the Company is accurate. The Company will take all practicable steps to ensure security of the personal data and to avoid unauthorised or accidental access, erasure or other use.
In order to provide you with our insurance brokerage services and other services set out in the "Purpose" section below, we may collect personal data directly from you or from other third parties. Please note that if you do not provide us with your personal data, we may not be able to provide the information, products or services you need or process your request.
Purpose: From time to time it is necessary for the Company to collect your personal data which may be used, stored, processed, transferred, disclosed or shared by us for purposes (“Purposes”), including:
1. providing insurance brokerage services to you, including assessing and evaluating your needs on insurance, wealth management, estate planning, business planning, or other financial matters;
2. advising or acting for you on matters relating to insurance, wealth management, estate planning, business or financing planning, or arranging insurance contracts on your behalf;
3. offering, providing, and marketing to you, insurance products/services of local or offshore insurance companies or other insurance service providers (see “Use and provision of personal data in direct marketing” below);
4. preparing for you any applications for insurance products/services. This will entail providing your personal data to insurance carriers for the purpose of obtaining life cover;
5. providing subsequent services to you, including but not limited to conducting face-to-face meetings or phone discussions for the purposes of reviewing and administering; any purposes in connection with any claims made by or against or otherwise involving you in respect of any products/services you have purchased, including investigation of claims;
6. any other purposes in connection with the provision of our brokerage services;
7. designing products/services for customers;
8. conducting market research for statistical or other purposes;
9. matching any data held which relates to you from time to time for any of the purpose listed herein;
10. making disclosures as required by any applicable law, rules, regulations, codes of practice or guidelines or to assist in law enforcement purposes, investigations by police or other government, regulatory or tax authorities worldwide;
11. conducting identity checks;
12. complying with the laws of any applicable jurisdiction;
13. carrying out other services in connection with the operation of the Company’s business; and
14. other purposes directly relating to any of the above.
Under applicable data protection laws, we process your personal data for the Purposes set out above on the basis of one of the following legal bases: (a) where the processing of your personal data is necessary for the performance of the contract with you or to take steps at your request prior to entering into a contract with you; (b) where the processing is necessary for us to comply with a legal obligation that we are subject to; (c) where the processing is necessary for the purposes of our legitimate interests, which includes without limitation providing you with direct marketing, market research, providing you with products/services and designing products/services for customers; (d) where required under applicable laws, your consent; or (e) where permitted under applicable laws, notification to you.
We do not normally ask you to specifically provide us with “Special Categories” of personal data but in some cases, special categories of personal data for purposes of identity verification. “Special Categories” of personal data are personal data revealing or concerning (directly or indirectly) racial or ethnic origin, communal origin, political affiliations or opinions, religious or philosophical beliefs, criminal record, trade-union membership and health or sex life and including genetic data and biometric data where it is used for the purpose of uniquely identifying a natural person.
Transfer of Personal Data: Personal data will be kept confidential and subject to the provisions of any applicable law. Your personal data may be provided to the following recipients for the Purposes listed above:
1. any of our affiliates, any person associated with the Company, insurance or any reinsurance company, claims investigation company, industry association or federation, or financial institution and in this regard you consent to the transfer of your data;
2. any agent, contractor or third party who provides administrative, technology or other services (including direct marketing services) to the Company and/or our affiliates and who has a duty of confidentiality to the same;
3. any actual or proposed assignee, transferee, participant or sub-participant of our rights or business; and
4. any government department or other appropriate governmental or regulatory authority worldwide.
For our policy on using your personal data for marketing purposes, please see the section below “Use and provision of personal data in direct marketing”.
Transfer of your personal data will only be made for one or more of the Purposes specified below.
Please note that if you are located in the European Economic Area (EEA) or UK, your personal data may be transferred to, and stored at, a jurisdiction outside the EEA, which may not provide the same level of data protection under applicable data protection laws in your jurisdiction. However, we will take steps that are reasonably necessary to ensure that your personal data is treated in accordance with applicable data protection laws, including, where relevant, entering into appropriate arrangements with the party outside the EEA receiving the personal data and you can request further information regarding the arrangements we have in place for this purpose by contacting us as set out below (under the section on "Your Rights").
Retention of Personal Data: We only store and process your personal data for the time necessary to achieve the Purposes for which the personal data is collected, in accordance with applicable data protection laws.
Use and provision of personal data in direct marketing: The Company and/or its affiliates intends to:
1. use your name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data held by the Company from time to time for direct marketing and the purpose of providing additional insurance advisory activities.
2. provide your personal data to insurance carriers and/or re-insurers for the purpose of obtaining life cover.
3. provide information regarding your insurance policy and/or application to a financial institution for the purpose of obtaining financing.
4. provide your personal data to insurance carriers and/or reinsurers for the purpose of obtaining additional life cover as well as health, wellness, annuity and other insurance products.
5. provide information regarding your insurance policy to the policy’s owner which may be you or an affiliated entity as instructed by you.
6. use your data to provide “after-sales” services including face-to-face meetings and phone discussions for the purpose of advising, reviewing and administering your policy(ies).
You may in the future withdraw your consent to the use and provision of your personal data for providing the insurance advisory activities.
You may in the future withdraw your consent at any time to the use and provision of your personal data for direct marketing purposes. If you wish to withdraw your consent, please inform us in writing to the address in the section on “Your Rights”. The Company shall, without charge to you, ensure that you are not included in future direct marketing activities.
Your Rights: You have the right to ascertain whether the Company holds your personal data, to obtain a copy of the data, and to correct any data that is inaccurate. You may also request the Company to inform you of the type of personal data held by it.
In addition, [if you are located in the European Economic Area or the UK,] under applicable data protection laws you may also have the following rights:
• You may have the right to ask us to erase your personal data in certain circumstances;
• In limited circumstances, you may have the right to request that we restrict processing of your personal data.
• Under certain circumstances you may have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another entity;
• Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us and we can be required to no longer process your personal data. If applicable, this may include requesting human intervention in relation to an automated decision so that you can express your view and to contest the decision;
• Where we rely on your consent, you have the right to withdraw your consent at any time;
• You have the right to lodge a complaint with your local data protection authority.
Requests for access and correction or for information regarding policies and practices and kinds of data held by the Company should be addressed in writing to:
Data Privacy Officer
IPGH Private Client Insurance Services LLC
121 West Trade Street, Suite 1100
Charlotte, NC 28202
If you prefer to call, please contact us at 855-378-8203.
Where permitted under applicable data protection laws, a reasonable fee may be charged to offset the Company’s administrative and actual costs incurred in complying with your data access requests.