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CA Notice at Collection

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Authorized Agent

If an authorized agent submits a request to know, correct, or delete on your behalf, the authorized agent must submit with the request a document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you to follow the applicable process described above for verifying your and the authorized agent’s identity. You can obtain an “Authorized Agent Designation” form by contacting us at [email protected].

Additional Information for California Residents

The California Consumer Privacy Act as amended by the California Privacy Rights Act (the “CCPA”) requires the following additional information for California residents.  The  information  below concerning the collection and disclosure of California residents’ personal information as well as the information in Sections 2 through 5, above, apply to Brown & Brown’s collection, use, and disclosure of California residents’ personal information during the twelve months preceding the last updated date of this Privacy Statement and prospectively.

Notice at Collection

The Company collects the categories of personal information identified in Section 2 (Personal Information We Collect), above, for the purposes identified in Section 4 (How We Use Personal Information), above, and retains personal information for the period described in Section 8 (Retention of Personal Information), above. We do not, and will not, sell your personal information or disclose it to third parties for cross-context behavioral advertising (“sharing”). In addition, we have no actual knowledge that we sell or share the personal information of individuals of any age, including the personal information of children under 16. We also do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

Additional Information About the Categories of Personal Information We Collect

The personal information we collect falls within the following “categories of personal information” listed in the CCPA:

  • Identifiers, such as your name, telephone number, and email address.
  • Professional or Employment-Related Information, such as your employer, job title, and other information necessary for the administration of the relationship between Brown & Brown and your employer.
  • Commercial Information, such as records of services purchased, and purchasing or consuming histories.
  • Internet or other electronic network activity information, including your interactions with the Site.
  • Sensory or Surveillance Data, for example: voice-mails, recordings of telephone calls with our service center representatives, recordings captured by equipment at our offices and other physical locations.
  • Characteristics of Protected Classifications Under California or Federal Law, such as your age, gender, or marital status, where relevant to the Service provided.
  • Personal information listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)), to the extent not already included in other categories here, such as benefit elections, pension entitlement information, and certain medical records.
  • Preferences you provide to us or generated through your use of the Services, including inferences we may make based on our experience with you.
  • Inferences we may make about you based on other data that we collect and our experience with you.

Additional Information About Disclosures of Personal Information

We may disclose your personal information to third parties for the following “business purposes” as that term is defined in the CCPA and as a supplement to the disclosure described in Section 5 (How We Disclose Personal Information), above:

  • Service providers and Contractors: We may disclose any of the categories of personal information listed above to service providers and contractors for the business purpose of performing services on the Company’s behalf.
  • Professional Advisers and Related Third Parties: We may disclose the categories of personal information listed above to the professional services providers listed in Section 5 (How We Disclose Personal Information), above, for the business purpose of auditing compliance with policies and applicable laws.
  • Affiliated companies: We may disclose any of the categories of personal information listed above to other companies within the Brown & Brown family of companies for the business purposes of: (a) auditing compliance with policies and applicable laws, (b) helping to ensure security and integrity, (c) debugging, (d) short-term transient use, (e) internal research, and (f) activities to maintain or improve the quality or safety of a service or device.

Note on Deidentified Information

At times, Brown & Brown converts California residents’ personal information into deidentified information using reasonable measures to ensure that the deidentified information cannot be associated with the individual (“Deidentified Information”). We maintain Deidentified Information in a deidentified form and do not attempt to reidentify it, except that we may attempt to reidentify the information solely for the purpose of determining whether its deidentification processes ensure that the information cannot be associated with the individual. Brown & Brown prohibits vendors, by contract, from attempting to reidentify the Company’s Deidentified Information.

Additional Information Specific to Individuals Who Reside Outside the United States

If you reside in Bermuda, Canada, the Cayman Islands, the Dubai International Financial Center (DIFC), European Union (“EU”), Hong Kong, Malaysia, Singapore, or the United Kingdom (“UK”) (collectively, “Non-U.S. Residents”), the following also applies to you:

Your Rights With Respect to Your Personal Information

Subject to any limitations and exceptions provided by the law applicable to your country of residence, you have the right to:

  • request access to your personal information, i.e., to ask the Company to provide you with copies of your personal information;
  • request that the Company update, correct or delete (the “right to be forgotten”) your personal information, i.e., to rectify personal information that is incomplete or inaccurate or to erase your personal information;
  • withdraw your consent to the processing of your personal information, at any time, where you previously consented to the processing of your personal information. If the Company requests your consent to process your personal information and you do consent, you may use the contact information below to withdraw your consent. Any withdrawal shall not affect the lawfulness of processing based on your consent before its withdrawal, and the Company will continue to retain the information that you provided us before you withdrew your consent for as long as allowed or required by applicable law.   In addition, if Brown & Brown has an alternative legal basis for processing your personal information without your consent, the Company may continue processing your personal information based on that alternative legal basis for processing.
  • lodge a complaint with the supervisory authority where you live, where you work, or where you believe the violation occurred if you believe that your personal information has been processed in violation of applicable data protection law.

Additional Rights Applicable to DIFC, EU, and UK Residents

Subject to any limitations and exceptions provided by the law applicable to your country of residence, DIFC, EU and UK residents also have the right to:

  • request restriction of processing of your personal information in certain situations, such as while a dispute concerning the accuracy of personal information is being resolved;
  • request data portability: Subject to certain limitations, the right to data portability allows you to obtain from the Company, or to ask the Company to send to a third party, a copy of your personal information in electronic form that you provided to the Company.
  • object to the processing of your personal information: You have the right to object to the processing of your personal information based solely on the Company’s legitimate interests. If you do object in these circumstances, the processing of your personal information will be stopped unless there is an overriding, compelling reason to continue the processing or the processing is necessary to establish, pursue or defend legal claims.

How to Exercise Your Privacy Rights

For EU and UK residents: you can exercise your rights by submitting a request to us at [email protected] or on line at Privacy Web Form or via mail to Brown & Brown, Europe 7th Floor, Corn Exchange, 55 Mark Lane, London EC3R 7NE, United Kingdom. The Company will respond to such requests in accordance with applicable data protection law.

For DIFC, Hong Kong, Malaysia, and Singapore residents: you can exercise your rights by submitting a request to us at [email protected] or via mail to Brown & Brown, Europe 7th Floor, Corn Exchange, 55 Mark Lane, London EC3R 7NE, United Kingdom. The Company will respond to such requests in accordance with applicable data protection law.

For Canada, Bermuda and Cayman Island residents: to exercise your rights, please submit a request to us by visiting our online privacy rights portal and completing the request webform. Alternatively, you may call us at +1 (888) 914-9661 and enter the following PIN: 363 845 when prompted to do so.  You will be asked to provide information necessary for us to process your request. The Company will respond to such requests in accordance with applicable data protection law.

Additional Information for Residents of Bermuda

If you reside in Bermuda: In addition to the rights described above, you also have the right to object to the processing of your personal information: (a) for purposes of direct marketing; or (b) where the processing causes or is likely to cause substantial damage or distress to you or others.

Additional Information for Residents of Cayman Islands

If you reside in Cayman Islands: In addition to the rights described above, you also have the right to, subject to applicable limitations and exceptions, restrict or block the processing of your personal information.

Additional Information for Individuals Whose Personal Information is Processed by Nexus Underwriting (DIFC), Ltd.

If Nexus Underwriting (DIFC), Ltd., processes your personal information, you may exercise the rights described above which apply to residents of the Dubai International Financial Centre.

Additional Information for Residents of Malaysia 

If you reside in Malaysia: In addition to the rights described above, you also have the right to object to the processing of your personal information: (a) for purposes of direct marketing; or (b) where the processing causes or is likely to cause substantial damage or distress to you or others.