Privacy Policy

Last Updated: 29 November 2019

1. INTRODUCTION

This Privacy Policy applies to the following entities: Gallagher Risk Placements Pty Limited (ACN 062 672 173, and Arthur J. Gallagher & Co (Aus) Limited (ACN 005 543 920) and its businesses and subsidiaries, collectively referred to as “Gallagher” in this document. In this document the words ‘we’, ‘our’ and ‘us’ are also used to refer to Gallagher. ‘You’ and ‘your’ refer to you, the person whose personal information Gallagher may collect, use and disclose.

We recognise the importance of your privacy and are committed to complying with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth).

This Privacy Policy sets out our processes on the management of personal information, including how we collect personal information, the purposes for which we use this information, and to whom this information is disclosed.

 

2. WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT?

The types of personal information we collect from you depends on the circumstances in which the information is collected.

If you are a client, or potential client, we collect ‘personal information’ specific to, and required for, the services and products that we provide to you. The personal information we collect and maintain may include your:

  • name;
  • address;
  • contact details;
  • bank account details;
  • information relating to your business; or
  • such similar information about other persons that you may or intend to conduct business with.

For some products and services we may also collect and maintain ‘sensitive information’. This may include:

  • health information;
  • genetic information;
  • biometric information;
  • religious beliefs or affiliations;
  • membership of a professional or trade association;
  • membership of a trade union; or
  • any criminal convictions.

If you apply for employment with us or seek to provide services to us we may collect additional information such as your qualifications, work history and references. 

 

3. HOW DO WE COLLECT PERSONAL INFORMATION?

Gallagher collects information either directly from you or from third parties. We will collect information directly from you when you provide it to us or our agents or contractors (for example when you engage us to be your insurance broker or as part of our marketing campaigns that we conduct), via our website or otherwise when you deal with us online (including through our social media pages). We may obtain personal information from third parties such as:

  • past insurers;
  • your employer;
  • premium funders;
  • other service providers including health service providers;
  • publicly available sources; or
  • our related companies. 

 

4. FOR WHAT PURPOSES DO WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION?

In general we collect, use and disclose your personal information so that we can provide the services you have retained us for or for purposes connected with our business operations.  This includes:

  • providing insurance broking services (and other related services) to you, including but not limited to:
    • analysing risks;
    • properly administering your claims or claims brought against you or your employer;
    • providing health services to you;
    • providing insurance, financial and investment advice;
    • arranging and placing insurance cover;
    • facilitating the payment of funds owing to insurers;
    • facilitating payment of money to you from either us or insurers; or
    • initiating and maintaining your or your employee’s membership of relevant organisations (such as superannuation funds or industry associations);
  • dealing with your enquiries, requests and complaints;
  • receiving goods or services from you, where you are one of our suppliers;
  • contacting you in relation to any marketing campaigns and offers about our products and services, or those of our business partners;
  • enabling you to use our apps that you download;
  • improving our products and services, and our websites and apps;
  • considering you for a job with us (whether as an employee or contractor) or in the context of other business relationships with us;
  • performing system administration; or
  • cooperating with regulators and law enforcement bodies.

 

In respect of sensitive personal information, we predominately will use, hold and disclose that information for the purpose of providing products and services to you or perform internal administrative or risk and compliance tasks.

 

5. HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION

Disclosure of your personal information to third parties generally

We may disclose your personal information to third parties in connection with the purposes described in section 4 of this Privacy Policy. This may include disclosing your personal information to the following types of third parties:

  • to suppliers in connection with the provision of services to you, for example insurers, agents, loss adjusters, risk managers, investment managers, external administrators. Some of these third parties are appointed by Gallagher to perform specific tasks on a case-by-case basis, others provide insurance, financial and related services to you as recommended by us;
  • our employees, independent contractors, related bodies corporate and related entities;
  • our contractors and other third parties that provide goods and services to us (including website and data hosting providers);
  • our accountants, insurers, lawyers, auditors and other professional advisers and agents; or
  • otherwise to any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees).

Disclosure of your personal information to third parties overseas

On some occasions we may also need to disclose your personal information (which might be sensitive information) to overseas third parties, including service providers, insurers, underwriting agencies and insurance brokers. In particular, this may also include related parties such as subsidiaries of our ultimate parent company, Arthur J. Gallagher & Co, located in the United States of America, United Kingdom, New Zealand, Singapore or India to assist in providing our services to you and assist in performing internal administrative or compliance tasks connected to the services.

Disclosure of your personal information required by law

We may also be required by law to disclose your personal information, such as when we are required to comply with a subpoena, warrant or other legal process.

 

6. WHAT HAPPENS IF YOU DO NOT PROVIDE US WITH PERSONAL INFORMATION?

If you choose to withhold requested or required personal information, Gallagher or any third-party suppliers may not be able to provide the products or services you require.

 

7. SECURITY

Gallagher will take steps as are reasonable in the circumstances to protect any personal information that we hold from misuse, interference and loss, and to protect it from unauthorised access, modification and disclosure.

Gallagher’s premises throughout Australia maintain physical security over paper files, electronic data stores and other records. We also maintain computer and network security, such as user identifiers and passwords to control access to computer systems where personal information is stored.

 

8. COOKIES & TRACKING 

We collect information about our websites and its visitors using cookies (and similar tracking technologies). A cookie is a small data file that a website saves on your device when you visit the site, and its primary purpose is to help a website keep track of your visits and activity. Cookies can also be used for targeted advertising (or “remarketing”). You cannot be personally identified from this information (unless it has been aggregated with other personally identifiable information). 

We use cookies (and similar tracking technologies) for a variety of reasons, including:

  • to assist us in measuring and improving our websites;
  • to better understand the people accessing our websites;
  • to help improve our content;
  • to personalize your experience; and 
  • engage in targeted advertising, and monitor the performance of it. 

In particular, we note we use the following:

  • Google Analytics Cookies: this web-analytics tool that allows us to collect information about how visitors use our site. For example, the information we collect includes the date and time of your visit to our sites, the pages viewed, information downloaded, certain geographical information, type of internet browsers you use;
  • Google AdWords and GoogleAds: we use these tools to display tailored advertising to you, through Google and third party vendors, on different websites across the internet based on your prior visits to our site;
  • LinkedIn Cookies: we use the LinkedIn “Event Specific Image Pixel” and “ Insight Tag” which allows us (through cookies) to monitor conversion tracking and gain information about website audiences and demographics for LinkedIn ad campaigns; and   
  • Hubspot Cookies: we use “Hubspot” (a customer relationship management system) and its “HubSpot tracking code”, which (through cookies) also helps us monitor our website’s traffic, and how visitors are using our website. If are an existing client or prospective lead that we have added to the Hubspot CRM platform, then it may be possible for us to aggregate your use of our website with your Hubspot profile.

If you prefer not to receive or activate cookies you can adjust your internet browser to refuse cookies or to warn you when cookies are being used. Our websites may not function properly or optimally if cookies have been turned off.

In particular, we note that you can also opt out of Google's use of cookies or device identifiers by visiting Google's “Ads Settings”, “Google Marketing Platform opt-out page” or “Network Advertising Initiative opt-out page”. You can also set ad preferences in the settings section of your relevant social media websites.

 

9. YOUR RIGHTS

Accessing and correcting your personal information

If you:

  • would like to access or revise your personal information; or
  • believe that the information we currently have on record is incorrect or incomplete,

then please contact our head office (see below contact details), or contact your local Gallagher office.

Direct Marketing  

We regularly distribute to our clients general information and newsletters regarding Gallagher’s products and services, including marketing campaigns, either by mail, email or telephone. If we believe it may be of interest to you we may, from time to time, supply you with specific information regarding some of our products and services.

We provide a simple ‘opt-out’ option for these kinds of communications. Alternatively, you may update your preferences by contacting our head office (see below contact details), or by contacting your local Gallagher office.

Privacy Complaints

If you have any questions, comments or complaints about our collection, use or disclosure of personal information, or if you believe that we have not complied with this Privacy Policy or the Privacy Act, you can contact our head office (see below contact details).  Your complaint will be managed via Gallagher’s Internal Privacy Complaint Procedure. This Procedure assures you of a timely and accurate response to your complaint.

When contacting us please provide as much detail as possible in relation to your question, comment or complaint.

If you are not satisfied with the outcome of our assessment of your complaint, you may wish to contact the Office of the Australian Information Commissioner. For further information on Privacy please visit the Australian Government - Office of the Australian Information Commissioner Website at www.oaic.gov.au.

Contact Details

Please address all privacy complaints, queries, access, correction, update or unsubscribe requests to our Risk and Compliance Department by telephone on 1800 068 000 or by email to privacy@ajg.com.au

 

10. CHANGES TO OUR PRIVACY POLICY

We may change our Privacy Policy from time to time. The current version is available on our website located at www.ajg.com.au or you may request that Gallagher provide you with a copy by post, email or other form. We do not charge for this service.

We are here to help at Arthur J. Gallagher Australia. Please fill out the form below with your enquiry and we will get in contact with you as soon as possible.

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