Privacy Policy Notice

MARSH INC.

and its Subsidiaries

Including

Marsh USA Inc.

mARSH PLACEMENT INC.

MARSH USA AGENCY INC.

MARSH USA RISK SERVICES INC.

MARSH USA RISK & INSURANCE SERVICES

seabury & smith, inc.

guy carpenter & company, inc.

PURPOSE OF THIS NOTICE

The privacy of personal information is important to Marsh Inc., its subsidiaries, and Marsh Inc.’s other affiliated companies.

The Gramm-Leach-Bliley Act (“GLBA”) limits how financial institutions can share nonpublic personal financial information (“NPI”) with third parties, which are not affiliated with us. GLBA also requires financial institutions to provide notices about their privacy policies and practices.

We are providing you with this document to comply with the GLBA and state laws relating to privacy in the insurance industry and to notify you of our privacy practices.

OUR PRIVACY POLICIES AND PRACTICES

Marsh Inc., through its subsidiaries, provides insurance brokerage, risk management and related services to its corporate, association and individual clients (all “Clients”).

1.Information we collect:

In order to serve our Clients, we collect NPI about:

  • The employees and members of our corporate and association Clients, and, in certain cases, their family members (all “Participants”), and
  • Our individual Clients.

We may collect NPI from the followingsources:

  • Clients and Participants orally, or on applications or other forms;
  • Affiliates, insurers, other intermediaries, third party providers and others;
  • Consumer reporting agencies; and
  • External sources. These include publicly available records.

We also collect NPI when we process and verify the information we get about Clients and Participants.

2.Information we may disclose to third parties:

We do not disclose any NPI about our current and former Clients or Participants to any third parties except as stated here.

We may share this information outside Marsh as allowed by our Clients and Participants. We may also share it in other ways permitted by law.

This includes to:

  • Determine eligibility for insurance benefits or payments;
  • Process or complete a transaction, or otherwise in connection with the transaction for which the information was provided;
  • Detect or prevent criminal activity, fraud, and material misrepresentation or nondisclosure in connection with insurance transactions;
  • Conduct audits; and
  • Comply with the law; and to respond to administrative or judicial orders.

We may also disclose NPI about our current and former Clients or Participants to:

  • Insurance regulatory authorities;
  • Law enforcement;
  • Other government authorities pursuant to law;
  • Parties to a proposed or actual sale, transfer, merger or consolidation of all or part of our business;
  • Group policyholders to report claims experience or to conduct audits of operations or services; or
  • Certificate holders or policyholders to provide information regarding the status of insurance transactions.

The law permits us to share NPI with our affiliates. Our affiliates may use it to market products and services to you. You cannot prevent those disclosures.

We may obtain your consumer credit reports. You may request that we do not share these with our affiliates. Please contact your local Marsh Representative to ask us not to share these.

The GLBA and this notice do not affect any rights any individuals may have under the Fair Credit Reporting Act.

3.Our practices regarding information confidentiality and security:

We restrict access to NPI about Clients and Participants. We only provide access to our employees and employees of our affiliates who need it to serve our Clients and Participants.

We have physical, electronic, and procedural safeguards in place to protect all NPI that we maintain.

4.Your right to access, correct, amend or delete certain information:

You may submit a written request for access to:

  • The information we maintain about you, and
  • The names of the carriers, agents, or insurance support organizations to which we have disclosed or normally disclose the information in the two (2) years prior to your written request.

We are allowed to charge a reasonable fee to cover our costs for providing this information.

You also have the right to request that we correct, amend, or delete your information that is not accurate or not current. You must detail the information at issue and provide supporting documents.

We will generally agree to your request.

However, if we believe the information we have is right, we may refuse. We will provide you the reasons for our refusal.

If you disagree with our reasons you can file a written statement with:

  • The information you think is correct, relevant or fair, and
  • The reasons why you disagree with our refusal.

If you file such a statement, we will keep it in our files. We will also provide your statement to any third party viewing the disputed information.

You do not need to call or do anything as a result of this notice.

It is meant to inform you of how we treat your NPI.

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 Our affiliates include Mercer Inc., Mercer Human Resource Consulting LLC, Mercer Management Consulting, Inc., National Economic Research Associates, Inc., MMC Capital Inc., Putnam Investments Trust.