As of June 2016
OUR PRIVACY POLICIES AND PRACTICES
Aon Affinity is committed to integrity in all our dealings with our clients. This commitment extends to any personal information about you that we might possess or acquire. We are dedicated to providing you with high quality service, support and products while taking appropriate actions to safeguard your personal information.
PURPOSE OF THIS NOTICE
Title V of the Gramm-Leach-Bliley Act (GLBA) and applicable state laws generally prohibit any financial institution, directly or through its affiliates, from sharing non-public personal information about you with a non-affiliated third party unless the institution provides you with a notice of its privacy policies and practices, including the type of information that it collects about you and the categories of persons or entities to whom it may be disclosed. In compliance with GLBA and state privacy laws, we are providing you with this notice, which informs you of the privacy policies and practices of Aon Affinity
GLBA further requires that we inform you of your right to restrict sharing of your non-public personal information with a non-affiliated third party for any purpose that is not specifically authorized by law. Your right to restrict sharing of non-public personal information with a non-affiliated third party for a purpose that is not specifically authorized by law is called your right to “opt-out” of such information sharing.
1. Information we collect:
We collect non-public personal information about you from the following sources:
2. Information we may disclose to affiliates and non-affiliated third parties:
We also may disclose non-public personal information that we collect (as described in section 1) about customers and former customers to affiliates and non-affiliated third parties as permitted by law.
3. Non-affiliated third parties to whom we are permitted to disclose non-public personal information:
We are permitted to disclose non-public personal information that we collect, such as we have described above, to the following types of third parties that perform services on our behalf. We will only disclose the portion of your personal information that is necessary to process or service your claim. These third parties are not allowed to use personal information except for the purpose of providing these services. These companies are not allowed to use your Personal Information for their own purposes and are contractually obligated to maintain strict confidentiality.
4. Notification of your right to opt-out of certain disclosures:
In the future, if we decide to disclose the information we collect about you, as described above, for purposes other than those described in this notice, which are expressly permitted by GLBA and applicable federal and state regulations designed to protect the privacy of your non-public personal information, we will give you an opportunity to opt-out of such disclosures; that is, we will give you the opportunity to direct us not to make those disclosures.
SAFEGUARDING AND MAINTAINING PERSONAL INFORMATION
We restrict access to non-public personal information about you, which we hold, to those employees and others who need to know that information to provide products or services to you. Their right to further use the non-public personal information about you is limited by our employee code of conduct, applicable law and non-disclosure agreements where appropriate. We maintain physical, electronic and procedural safeguards that comply with applicable regulatory standards to guard your non-public personal information.
For Minnesota Residents
The disclosure of personal information among Aon Affinity and affiliates is authorized under the Minnesota Insurance Fair Information Report Act, § 72A.502, subdivision 8, which allows for disclosure without written authorization where i) the personal information is used for a limited purpose and ii) the affiliate agrees not to disclose the information for any other purpose or to unaffiliated persons.
For Montana Residents
The disclosure of personal information among Aon Affinity and affiliates is authorized under Montana’s Insurance Information and Privacy Protection Act, MCA 33-19-306 (12)(a) and (b), which allows for disclosure without written authorization where i) the personal information is used in connection with an audit or to enable Aon Affinity to perform an insurance function and ii) an appropriate agreement is executed with the affiliate to limit the affiliate’s use and disclosure of the personal information.
For New Mexico Residents
We may disclose personal information among Aon Affinity and affiliates without written authorization pursuant to New Mexico’s Privacy Rule, 220.127.116.11 through 18.104.22.168 NMAC. However, any such disclosure will be only to the extent necessary to effect, administer or enforce a transaction that you have requested or authorized.
For North Dakota Residents
NDCC 26.1-02-27 permits Aon Affinity to disclose personal information pursuant to NDCC 45-14-01-11, which sets forth North Dakota’s rules promulgated in accordance with NAIC’s Privacy of Consumer Financial and Health Information and allows for disclosure where appropriate opt-out notice and opportunity has been given.
For Vermont Residents
Aon Affinity is authorized to disclose personal information under Vermont’s Privacy of Consumer Financial and Health Information Regulation Article IV, Sections 14(A), (B) and (C), which provide an exception to the general “opt-in” rule (which requires consumers to affirmatively agree to disclosure) where Aon Affinity executes an appropriate agreement with the third party that limits the third party’s use and disclosure of the personal information. Aon Affinity is further authorized to disclose personal information under Sections 15(A) and (B) which provide an exception to the “opt-in” requirement where the disclosure of personal information is necessary to affect, administer or enforce a transaction that the customer authorizes. Our release of personal information is also authorized where permitted by law under Section 16(A).
Feel free to contact us if you have any questions about this Privacy Notice. The address and phone number you can contact should you have any questions is listed below.
900 Stewart Avenue
Garden City, NY 11530