We make our Platform available to authorized employees, contractors, and other agents of our clients (our “Clients”) who have successfully completed the registration process required to use the Platform (each a “Registered User”, “you”, or “your”), in each case to support insurance-related risk analyses and other services that may be offered from time to time. Please read this Privacy Notice carefully to better understand how we collect, use, and disclose Personal Information about you as you use our Platform and Services (defined below).
RGAX partners with our Clients to support insurance-related risk analyses and other informational services in connection with our Clients’ prospective and current customers (each, an “Insured Person”). Our Platform allows Clients through their Registered Users to submit insurance-related data, files, content, or other information about an Insured Person (collectively, “Client Information”). By evaluating Client Information submitted through our Platform, RGAX is able to assist our Clients in maintaining accurate risk- and insurance-related information, data, and profiles for their Insured Persons (the “Services”).
We strive to respect privacy and we recognize the need for appropriate protection and management of any Personal Information that is shared with us in connection with your use of our Platform and Services. As used in this Privacy Notice, “Personal Information” means any information relating to an identified or identifiable person. You may choose whether or not to provide or disclose Personal Information in connection with your use of our Platform or Services. If you choose not to provide any Personal Information we request, you may still visit and use parts of our Platform but may be unable to access or use certain features, options, programs, products, and services offered on our Platform. Our Platform may contain links to third-party websites and services that are not owned or controlled by RGAX (collectively, “Third Party Websites”). We do not endorse any such Third Party Websites or the information, materials, products, or services contained on or accessible through such Third Party Websites. We have no control over, no obligation to monitor, and are not responsible for the privacy practices or the content of any Third Party Websites, and you visit them at your own risk and understand that this Privacy Notice does not apply to your use of any such Third Party Website. Accordingly, you expressly relieve us from any and all liability arising from your use of any Third Party Website. We encourage you to read the terms and conditions and privacy policy or privacy notice of any Third Party Website that you visit.
We and our third-party service providers (“Providers”) may collect the below categories of Personal Information about you when you use our Platform:
In order to receive insurance-related risk analyses and other informational services, Clients may provide us with the below categories of Personal Information about Insured Persons:
Our Platform may require you, or provide you the opportunity, to submit certain information that may constitute Personal Information in the following ways:
(a) Contact Information.
In areas of our Platform and in printed materials, we may provide you the opportunity to submit a form with basic contact information, such as your name, email, and communications you send to us. When you submit a form to us, you are giving RGAX permission to use such information to inform you of technical or transactional information regarding our Platform.
(b) Account Login Information.
We may process your username and password (whether alone or in combination with other data to detect fraud) to enable you to log into our Platform, and we process information relating to access privileges granted to you to appropriately control your access to restricted content. We process this Personal Information only as necessary to provide you with our Platform, as well as to further our legitimate interests of protecting our Platform and the content on our Platform.
(c) Secure Document Submissions.
RGAX makes its Platform available to assist Clients in their insurance-related risk analyses and to provide from time to time other services. To initiate such processes, our Clients must submit their insurance-related data files through our Platform (each, a “Submission”). As a Registered User, Submissions you make on behalf of a Client (your employer) may contain the personal information (including sensitive personal information) of an Insured Person collected by or on behalf of the Client for its own lawful purposes. The Client is responsible for (i) obtaining all legally-required consents for RGAX’s use of Personal Information of an Insured Person in a Submission to provide Services, (ii) complying with all data protection laws applicable to the Client’s use of Personal Information, the Submission and the Services, and (iii) adopting policies and procedures to identify and prevent errors in a Submission and protect the Personal Information of an Insured Person. With respect to every Submission you make, you represent and warrant that you have the full right and authority, acting on behalf of the Client, to: (A) make such Submission in your professional, employment-related capacity and (B) permit us and our Providers to process the information contained in the Submission in accordance with this Privacy Notice and our Terms of Use ( https://cdn2.hubspot.net/hubfs/3796847/RGAx/content/rgax-terms-of-use.pdf?t=1513010559578). With respect to every Submission you make, we will use commercially reasonable efforts to employ appropriate administrative, physical, and technical safeguards necessary to protect the confidentiality, integrity, and security of such Submission.
(d) Providers.
We use certain Providers on our Platform to enhance your experience or deliver certain features, functionality, products, and services to you. These Providers may collect Personal Information about you when they are performing services on our behalf and/or when you are using certain functions on our Platform that are operated by these third parties. For example, when you make a Submission to our Platform, Providers acting on our behalf may collect, store, and process the information contained in such Submission. Any information, including Personal Information, collected by such Providers will be subject to either: (i) contractual obligations between RGAX and such third party provider or (ii) the privacy notices or privacy policies of such Provider, if any. For more information on our Providers, please see Section 6(a) of this Privacy Notice.
Certain information on our Platform is collected automatically by means of various software tools, as described below. We have a legitimate interest in using such information to assist in log-in, systems administration, and information security and abuse prevention purposes, as well as to track user trends, understand the usage of our Platform, analyze the effectiveness of our Platform, and improve our Platform. Some or all of the automatically collected information may, alone or in combination with other information, constitute Personal Information under certain laws pertaining to data privacy. Some of our Providers may also use cookies or other methods to gather information regarding your use of our Platform. These Providers may use these cookies or other tracking methods for their own purposes by evaluating information about your use of our Platform in combination with any Personal Information about you that they may have. The use of this information, including any Personal Information they may have about you, by these Providers is subject to the privacy notices or privacy policies of such Providers, if any, rather than this Privacy Notice.
(a) Log Files on Our Platform.
We may maintain certain log files relating to the access and use of our Platform. The information inside the log files may include internet protocol (“IP”) addresses, type of browser, Internet Service Provider (“ISP”), date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us (collectively, “Log Data”). Log Data may be used to monitor and analyze the use of the Platform, perform technical administration, enhance functionality and user-friendliness, and better tailor our Platform to your and our other visitors’ needs. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the purposes provided in this Privacy Notice.
(b) Cookies.
We use cookies, which are small pieces of data stored in text files, to make interactions with our Platform easy, efficient, and meaningful. When you visit our Platform, our servers may send a cookie to your computer or other device. Cookies collect and allow us to compile information about the usage of our Platform and interaction with emails from us. Standing alone, cookies do not personally identify you; they merely recognize your web browser. Unless you choose to identify yourself to us, either by responding to an email, opening an account, or filling out a web form, you remain anonymous to us. If you identify yourself to us, then these cookies may also collect Personal Information and may allow us to track your usage of our Platform, determine your usage preferences, and improve and customize your experience when using our Platform. We may use cookies that are session-based or persistent. Session cookies exist only during one session; that is, they are downloaded to your web browser when you visit our Platform, but then disappear from your computer/device when you close your browser software or turn off your computer/device. Persistent cookies, on the other hand, are used for multiple visits to our Platform and remain on your computer/device after you close your browser or turn off your computer/device.
(c) Do Not Track Signals.
RGAX does not track users of our Platform across third-party websites to provide targeted advertising. Accordingly, we do not currently respond or take any action with respect to a web browser’s “do not track” signal or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Information about an individual consumer’s online activities over time and across third-party websites or online products and services.
(d) Analytics.
We may use certain third-party analytics services to improve the functionality, features, or delivery of our Platform. We may also use these analytics services to record mouse clicks, mouse movements, scrolling activity, as well as any text that you type into our Platform. For example, we may use Google Analytics on our Platform to track user trends and usage. For more information on Google Analytics’ processing of Personal Information as it relates to our Platform, please see http://www.google.com/policies/privacy/partners/. By using a browser plugin provided by Google, you can opt out of Google Analytics.
(e) Web Beacons.
We may use web beacons, either alone or in conjunction with cookies, to compile information about your usage of our Platform and interaction with communications from us. Web beacons, also known as pixels, are clear electronic images that can recognize certain types of information on your computer/device, such as cookies, when you view a particular site or email tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you open an email or click on a link in the email that directs you to our Platform. We may also use web beacons to operate and improve our Platform and email communications. Unlike cookies, however, web beacons are not stored on your computer/device, so even if you disable cookies on your web browser, web beacons may still load and be used as described above.
If you submit or we collect Personal Information through our Platform, then such Personal Information may be used in the following ways:
In addition, we may use your Personal Information as otherwise described to you at the time of collection or with your consent.
We do not sell, lease, rent, or otherwise disclose the Personal Information collected from our Platform to third parties unless otherwise stated in this Privacy Notice or unless you otherwise consent to us doing so. The following sets forth when and where we disclose Personal Information collected through our Platform.
(a) Providers.
We may transfer Personal Information to our Providers to perform tasks on our behalf and to assist us in providing our Platform. For example, we may share your Personal Information with Providers who assist us in performing core functions (such as hosting, data storage, and security) related to the operation of our Platform and/or by making certain interactive tools available to you as a user of our Platform. We may also use Providers for technical and customer support, application development, data analysis (quantitative and qualitative), tracking and reporting functions, quality assurance, and other services. In the performance of Services, we may share Personal Information from or about you so that we can deliver our Platform effectively. Providers receive your Personal Information as necessary to perform their role, and we use commercially reasonable efforts to only engage with Providers that post a publicly available privacy notice or privacy policy.
(b) Professional Advisors.
We may share your Personal Information with our auditors, lawyers, or other professional advisors so they can support our business. These professional advisors are bound by obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
(c) De-Identified and Aggregated Information.
To better serve you and improve our Platform and Services, RGAX may conduct research utilizing certain anonymized Personal Information in statistical form. This research may be compiled and analyzed on an aggregate basis, and we may share this de-identified or aggregated information with our affiliates and third parties with whom we do business. This de-identified or aggregated information does not identify a user personally. RGAX may also disclose de-identified or aggregated information in order to describe our Platform and Services to current and prospective third parties with whom we conduct business and to other third parties for other lawful purposes.
(d) In the Event of Merger, Sale, or Change of Control.
We may transfer or assign this Privacy Notice and any Personal Information to a related or third-party entity as part of a merger, acquisition, sale, or other change of control of our business, assets, or equity, including in connection with any bankruptcy or similar proceedings.
(e) As Required or Appropriate by Law.
We may disclose Personal Information if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process, or governmental request; (ii) enforce our Terms of Use (https://cdn2.hubspot.net/hubfs/3796847/RGAx/content/rgax-terms-of-use.pdf?t=1513010559578), including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of RGAX, our users, or the public.
(a) Access, amend, erase, or export Personal Information. If you would like to access, amend, erase, or export Personal Information about you collected through our Platform, you may submit a request through our Rights Request page (https://www.rgare.com/our-company/responsibility/policies-and-governance-center/rights-requests) and we will use commercially reasonable efforts to respond in a timely manner. Please note, however, that the only way to make some requested changes to your account may be by you through your secure account management page following your successful login. Our Client (your employer) may also request changes to your account information and we will comply with such request in accordance with the terms and conditions of any agreement between us and such Client. If you are a resident of Virginia and we do not take action within a reasonable period of time following your request to exercise your rights, you have the right to appeal by submitting a request through our Rights Request page (https://www.rgare.com/our-company/responsibility/policies-and-governance-center/rights-requests).
(b) Privacy Questions. You may submit a request to privacy@rgare.com or write to us at the following mailing address. We will promptly review all such requests in accordance with applicable laws.
Reinsurance Group of America, Incorporated
Attn.: Global Security and Privacy Office
16600 Swingley Ridge Road
Chesterfield, Missouri 63017-1706
Please note that our Platform and Service are directed towards users who reside in the United States. By using our Platform or Service, you consent to the collection, storage, processing, and transfer of Personal Information in and to the United States, or other countries and territories, pursuant to the laws of the United States. While some of these countries may not offer the same level of privacy protection as your own, we commit to uphold the privacy protections as explained in this Privacy Notice.
We reserve the right to retain any Personal Information as long as the Personal Information is needed to: (a) fulfill the purposes that are described in this Privacy Notice and (b) comply with applicable law.
The security of Personal Information is important to us. We have reasonable and appropriate security measures (including technical and organizational measures) in place to protect against the loss, misuse, and alteration of any Personal Information we receive about you through the Platform. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee the absolute security of Personal Information, our Platform, or our Services.
We do not target children and do not knowingly collect any Personal Information directly from children under the age of eighteen (18). If you disclose Personal Information on our Platform, you represent to us: (a) that you are at least eighteen (18) years of age and (b) no Personal Information disclosed by you relates to a child. If you are the parent or legal guardian of a child under the age of 13 whom you have reason to believe has provided his or her own Personal Information to us, you have the right to request the removal of that child’s Personal Information from our database. In order to request such removal, please submit your request through our Rights Request page: https://www.rgare.com/our-company/responsibility/policies-and-governance-center/rights-requests. You may be required to verify your identity as the child’s parent or legal guardian in order to have the child’s Personal Information or Personal Information removed. Otherwise, in compliance with the Children’s Online Privacy Protection Act, any information we may receive from Users we believe to be under the age of 13 will be purged from our database.
Our Platform and Services may change and evolve over time. We may update this Privacy Notice from time to time at our discretion to reflect changes to our information practices. We will provide you with advance notice of a material change to this Privacy Notice prior to your access of any portion of the Platform. We may (i) require that you re-accept the updated version of this Privacy Notice, (ii) send you an electronic notification advising of the update to this Privacy Notice, or (iii) include a notice on our Platform. We do not ordinarily provide notice of a non-material change to this Privacy Notice.
We encourage you to periodically review this page for the latest information on our privacy practices. The “Last Updated” legend at the top of this page will be updated with each change to this Privacy Notice. Your continued use of the Platform and/or utilization of any Services after this Privacy Notice has been updated (and after advance notice for a material change) indicates your agreement and acceptance of the updated version of the Privacy Notice. If the updated Privacy Notice is not acceptable to you, your sole recourse is to stop using and accessing the Platform and Services. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to the Platform.
Any comments, concerns, or questions regarding our Privacy Notice may be sent to us at privacy@rgare.com.