Privacy Notice

1. Introduction

Davies Group Limited with its registered office at 5th Floor, 20 Gracechurch Street, London, EC3V 0BG, United Kingdom, and its entities and affiliates (hereinafter referred to as ‘Davies Group’) are committed to being transparent about how the Davies Group processes your personal data.

The Davies Group is committed to respecting an individual’s privacy rights and complying with all applicable data privacy laws including the California Consumer Privacy Act (CCPA) and other U.S. state privacy laws.  This Privacy Notice outlines how the Davies Group operating in United States will collect, hold, process, and share your personal data, to assist you in making informed decisions when using our website and/or accessing our products and services. This Privacy Notice does not apply to personal information collected about Davies personnel.

For California HR covered individuals please refer to this link here with the applicable privacy notice.

For residents of the United Kingdom or the European Economic Area (EEA), please refer to our UK & Europe Privacy Policy.

For information about the types of cookies we use and our reasons for using them, please refer to our Cookie Policy.

In this Privacy Notice, the terms ‘we’, ‘our’ or ‘us’ are used to refer to the Davies Group North America, who are at times either the data controller or processor responsible for processing your personal data.

2. The types of personal data we collect

Generally, we collect, use, and disclose your personal information in order to provide you services and as otherwise related to the operation of our business (and may have collected during the 12-month period prior to the Last Updated date of this Privacy Notice) the following categories of personal information about you:

• Identifiers and Contact Information:identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers, and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers.
• Personal Records:signature, physical characteristics or description, state identification card number, insurance policy number, bank account number, credit card number, debit card number, or other financial information, education information, medical information and health insurance information
• Commercial Information:commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
• Device/Network Data:Internet and other electronic network activity information, including, but not limited to, IP address, geolocation, device identifiers, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.
• Audio/Visual Data:audio, electronic, visual, and similar information

3. How we collect your personal data

The personal data we process may be collected from a variety of sources including, but not limited to:

• Directly from you, when you contact us.
• Our affiliates and clients we service, such as your insurer.
• Service providers, contractors and other vendors who provide services on our behalf.
• Law enforcement agencies.
• Your devices, such as when you use our services.
• Website cookies and similar technologies.
• Social media services.

4. How we use your personal data

Davies may use (and may have used during the 12-month period prior to the Last Updated date of this Privacy Notice) personal information for the purpose of performing contracted services for our clients and conducting our business operations, including the uses described below.

5. Who we share your personal data with

Within the Davies Group, your personal data will be shared with team members who need to access it for the processing purposes outlined in this Privacy Notice.

We will only share your personal data with other parties where it is reasonable and necessary to accomplish the processing purposes outlined in this Privacy Notice. This may include (but is not limited to) occurrences where we:

• Are required to share information with clients while performing contracted services
• Engage in business-related mergers and acquisitions. This would include conducting due diligence analysis, for the purposes of facilitating and completing transactions.
• Rely on the services of third-party service providers to carry out activities, provide services, or undertake business operations on our behalf.
• Are required to share information with law enforcement bodies and/or fraud prevention agencies for the purpose of preventing or detecting fraud or criminal activities.

In any such cases, the data we share will be limited to that which is strictly necessary and will be subject to appropriate contractual and confidentiality arrangements in place.

We may also share your personal information by allowing certain third parties (such as online advertising services) to collect personal information via automated technologies on our websites and apps for cross-context behavioral advertising purposes. For example, this kind of sharing may be considered a “sale” or “sharing” (as defined under CCPA). You have the right to opt out of these types of disclosures of your information.

We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the Last Updated date of this Privacy Notice) the following categories of personal information about you to online advertising services:

• Identifiers
• Device/Network Data
• Commercial Information

You have the right to opt-out of this use of your information, as detailed below. You can opt-out of the sale or sharing of your personal information by clicking “Do Not Sell or Share My Personal Information” or by using the Global Privacy Control signal.

We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.

6. How long we keep your personal data for

We will keep your personal data for as long as necessary to fulfill the purposes for which it was collected, taking into account the following:

• Adhering to retention periods established under applicable law or necessary to comply with legal obligations, or to establish or defend legal claims;
• In line with industry best practices;
• Whether the purpose of processing is reasonably likely to justify further processing;
• Identifying risks to individual privacy in continued processing;
• Applicable data protection impact assessments;
• Recognizing design considerations/limitations; and
• Analysing the costs associated with continued processing, retention, and deletion.

7. Your privacy rights

Davies Group is committed to processing your personal data in compliance with all applicable laws and regulations. The United States maintains various data protection laws which provide a range of rights for individuals and their personal information. These rights may be applicable to you depending upon the jurisdiction you currently reside in. These rights generally include:

Right to Know/Access

You have the right to know or obtain a copy of personal information we have collected, used, disclosed or shared about you.

Right to Confirm Data Processing

You have the right to confirm what personal data we will collect about you.

Right to Correct

You have the right to ask us to correct personal information you think is inaccurate, or to complete information you think is incomplete.

Right to Delete

You have the right to ask us to delete your personal information, in certain circumstances. Please note – there may be certain circumstances under which we may not delete some or all of your personal information as required by applicable law.

Right to Opt-Out of Sale and Sharing

You have the right to opt-out of the sale and sharing of your personal information, in certain circumstances.

Rights to Limit Sensitive Data

You have the right to request we limit the use and disclosure of sensitive personal information we have collected from you.

Right to Data Portability

You have the right to ask that we transfer the personal information you gave us to another organization, or to yourself, in certain circumstances.

8. How to Submit a Request

To exercise any of the rights applicable in your state outlined above: Right to Know/Access, Confirm Data Processing, Correct, Delete, Opt-out of Sale and Sharing, Limit Sensitive Data, or Data Portability please complete our webform through the link here or contact us at usprivacy.dpo@us.davies-group.com.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with Right to Know/Access, Confirm Data Processing, Correct, Deletion, Limit Sensitive Data, or Data Portability. We may require you to provide any of the following information:

• Name
• Address
• Phone Number
• Email

In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

9. How to Contact Us

We aim to meet the highest standards to safeguard your privacy. However, if you have any questions regarding this Davies Group North America Privacy Notice or our privacy practices, you can contact us or submit a complaint to our Director of Privacy by emailing usprivacy.dpo@us.davies-group.com, or by writing to:

Director of Privacy

Davies North America Headquarters:

PO Box 110259

Lakewood Ranch, FL 34211-000

10. Changes to this Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a copy of the updated Privacy Notice (displayed electronically) when we make any substantial changes. We may also notify you in other ways from time to time about changes to the processing of your personal information.

This Privacy Notice was last updated on July 16, 2024.

11. Affiliates

The Davies Group incorporates the following legal entities: