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 subsidiaries (hereinafter referred to as ‘Davies Group’) is committed to being transparent about how it processes your personal data.

The Davies Group is committed to respecting an individual’s privacy rights and complying with all applicable data privacy protection laws. This Privacy Policy outlines how Davies Group operating in North America 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.

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

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

2. The types of personal data we collect

We collect and process the following types of personal data:

• When you browse our website, we use cookies to collect usage data, which may include, but is not limited to, your IP address, browser type/version, browsing behaviour on our site (including the pages that you visit, the time spent on those pages and the date and time of your visit) and your geolocation data. More information about the types of cookies we use and our reasons for using them can be in our Cookie Policy.
• Personal identifiers, contact details, and characteristics, such as your name, state of residence, address, driver’s license number, social security number, phone number and email address.
• Special category data including financial information, health and/or medical diagnosis information, which may be held, used, and processed for the purpose of providing the services offered by Davies Group.

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.
• Fraud prevention agencies and organizations.
• Law enforcement agencies.
• Loss adjusters and claims investigators.
• Your devices, such as when you use our services.
• Our website cookies.
• Social media.
• Data brokers, such as public databases, credit bureaus, credit reporting service providers and background check services.

During the course of providing our services, we may also collect personal data from you directly, for example when the information is needed to progress your claim. We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers.

4. How we use your personal data

The personal data we collect is used to perform contracted third-party administration services for our clients including, but not limited to, third party claim handling, actuarial services, audit services, risk inspection services, consulting, as well as conducting our business operations such as fraud prevention, complaint handling and where legally required.

5. Change of purpose

We will only process your personal data in line with the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose, and that purpose is compatible with the original purpose.

Please note – we may process your personal data without your knowledge or consent, where this is required or permitted by law. For example, where the processing relates to the detection and prevention of crime.

6. Automated decision-making and profiling

In some circumstances, Davies Group may use automated processing and decision-making, where a decision is made by automated means without any human involvement. Our current use of automation technologies includes:

• Robotic Process Automation (RPA) – Where virtual workers automate the copying and pasting of information from one system into another.
• Self-Service Platforms – Allows humans to directly interact with an RPA process, enabling human-in-the-loop processing of information.
• Artificial Intelligence (AI) and Machine Learning – To enable virtual workers to learn and understand the data presented and improve effectiveness.
• Intelligent Automation Digital Assistant – An AI supervisor that automatically manages, tracks, and orchestrates virtual worker schedules and activities.
• Computer Vision/Optical Character Recognition – Offers pattern matching within images and can be used to interpret complicated language-based text recognition.
• Natural Language Processing – Translates/extracts human language into computer readable information (think “Hey Siri”) for the purpose of classifying information.
• Conversational AI – Uses AI and Natural Language Processing to enable real-time conversations with customers via the use of chatbots.
• API End-points – Uses virtual workers to bridge the gap between old systems and new ones by copying and pasting information across.

We do not anticipate that any of the automation technologies described above will produce legal or similarly significant effects on you, however if this was to change in the future, we would only do so where it is:

• Necessary for the entry into or performance of a contract; and
• Authorized under domestic laws applicable to the data controller; or
• Based on your explicit consent.

7. Who we share your personal data with

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

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 Policy. This may include (but is not limited to) where we:

• 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 being in place.

Additionally, all of our third-party service providers are required to take appropriate security measures to protect your personal data, in line with Davies Group policies, and we do not allow them to use your personal data for their own purposes under any circumstances.

8. How long we keep your personal data for

We will keep your personal data for as long as necessary to fulfill the purposes that we describe in this Privacy Policy or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.

9. Your privacy rights

Davies Group is committed to processing your personal data in compliance with all applicable laws and regulations.  Canada and the United States maintain 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 of 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 be Informed

You have the right to know how we will collect and use your personal data.

Right to Rectification

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

Right to Deletion

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 Object

You have the right to object to the processing of your personal information, in certain circumstances.

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.

Rights Related to Automated Decision-Making and Profiling

You have the right to request human intervention where a decision has been taken about you using fully automated decision-making or profiling, and which produces legal or similarly significant effects on you, such as the automatic refusal of a claim.

To exercise any of the rights outlined above, please contact us at. usprivacy.dpo@us.davies-group.com.

10. How to submit a complaint

We aim to meet the highest standards to safeguard your privacy. However, if you have any concerns about Davies Group’s use of your personal data, you can submit a complaint to our Director of Privacy by emailing usprivacy.dpo@us.davies-group.com, or by writing to:

Director of Privacy

Davies Group North America

6 Century Blvd., Suite NT350,

Nashville, TN 37214

11. Changes to this Privacy Policy

We reserve the right to update this Privacy Policy at any time, and we will provide you with a copy of the updated Privacy Policy (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 Policy was last updated on September 20, 2023.

12. Subsidiaries

The Davies Group incorporates the following legal entities, all registered in England and Wales unless otherwise stated: