This privacy notice describes how Pronto General Agency, Ltd. (together with its affiliates and subsidiaries, “Pronto”) may collect, handle and process personal information in relation to the services which we provide to our clients.
This privacy notice applies to all of the services, websites and apps offered by Pronto (collectively, the “Services”), but excludes any Services which have separate privacy notices that do not incorporate this privacy notice.
Pronto is primarily responsible for the personal information collected and held in relation to any Service.
Personal Information We Use
We may collect personal information about you from a variety of sources, including information we collect from you directly (e.g., when you contact us) and from other sources. These categories are described in detail below.
Note that we may be required by law to collect certain personal information about you, or as a consequence of any contractual relationship we may have with you. Failure to provide this information may prevent or delay the fulfilment of these obligations. We will inform you at the time your information is collected if the provision of certain personal information is compulsory and the consequences of the failure to provide such personal information.
Information we collect directly from you
Depending on the service, website or app that you are using, the categories of information that we may collect directly from you include:
- Personal details (e.g., name, date of birth);
- Contact details (e.g., phone number, email address, postal address or mobile number);
- Government issued identification details (e.g., social security and national insurance numbers, passport details);
- Health and medical details (e.g., health certificates);
- Policy details (e.g., policy numbers and types);
- Bank details (e.g., payment details, account numbers and sort codes);
- Driving license details;
- Online log-in information (e.g., username, password, answers to security questions);
- Information relating to any claims;
- Other information we receive from you on applications or required questionnaires (e.g., occupation, current employer); and
- Information we collect automatically from you (e.g., click stream data, personal information and other data collected using cookies and other device identifying technologies (“Cookies”). (Our specific policy on Cookies is at the bottom of this page).
Information we collect from other sources
The categories of information that we may collect about you from other sources are:
- Personal details (e.g., name, date of birth);
- Contact details (e.g., phone number, email address, postal address or mobile number);
- Bank details (e.g., account numbers and sort codes);
- Financial information from consumer-reporting agencies for the purpose of ascertaining credit history;
- Insurance policy details (e.g., policy numbers and types);
- Driving history and license information, including traffic offenses, past and current driving license information, and prior accidents;
- Information relating to any claims; and
- Personal details of various types received when we conduct Anti Money Laundering, Countering Financing of Terrorism, Anti Bribery and Corruption, and Sanctions Screening checks.
We may receive such information from other insurers, consumer-reporting agencies, our affiliated companies, government agencies, or other third parties, including compliance screening services, in the course of conducting our business.
Sensitive personal information
We may also collect certain information about you which is considered more sensitive under local applicable laws, such as:
- Information about your race, ethnic origin, religious views and philosophical beliefs, membership in professional or trade associations, gender identity or sexual orientation for diversity and statutory monitoring purposes where appropriate; and
- Health, biometric or disability information required to administer policies or process claims.
Personal data relating to minors and other vulnerable people
We may also collect or receive personal data relating to minors (which might be defined differently in different jurisdictions), particularly but not exclusively when processing personal injury insurance claims. We recognize that personal data relating to minors and other vulnerable people is particularly sensitive. However we treat all personal and other confidential data as needing to be kept secure and confidential, so all data is treated as needing appropriate protection.
We do not knowingly collect online information from children under the age of 13. Our services are marketed towards adults of driving age. If we are notified that we have collected personal information, as defined by the Children’s Online Privacy Protection Act (“COPPA”), of a child under the age of 13, we will delete the information as expeditiously as possible.
How We Use Your Personal Information And The Basis On Which We Use It
We may use your personal information to:
- Provide, maintain, protect and personalize our services including our insurance products, consulting and client insurance management and other administration services;
- Deal with your inquiries and requests;
- Perform system administration and to report aggregate statistical information to our insurers, reinsurers, and advertisers;
- Cooperate with regulators and law enforcement bodies;
- Contact you with marketing and offers relating to products and services offered by us (unless you have opted out of marketing, or we are otherwise prevented by law from doing so);
- Personalize the marketing messages we send you to make them more relevant and interesting and to customize and enhance your website or app experience;
- Resolve complaints, as well as handle requests for data access or correction;
- Protect your, our or others’ rights and interests;
- Manage insurance claims made by you or made by others to whom you may be liable; and
- Communicate with you regarding your account or changes to our policies, terms and conditions.
Accessing, Correcting, or Removing Your Personal Information
If you would like to review your personal information, correct the personal information you have provided to us, and/or request that we remove your information from our records, contact Pronto’s General Counsel via the contact information noted below with the access, correction, or removal request. Each request will be reviewed and responded to in accordance with applicable laws. In order to cover internal costs for responding to access requests, Pronto may charge a reasonable fee to individuals desiring access to their personal information.
Disclosure and Use of Personal Information
We may share your personal information with third parties for the purposes described in this privacy notice under the following circumstances:
- We may share your personal information with our insurers and their business partners for the purpose of processing claims and other insurance and company administration purposes. This includes reinsurance companies, other insurance agents or brokers, lawyers, actuaries, testifying experts, loss adjusters, claims handlers, etc.
- We may share your personal information with our service providers and business partners that perform marketing services and other business operations for us. For example, we may partner with other companies to process secure payments, fulfill orders, optimize our services, send newsletters and marketing emails, support email and messaging services and analyze information.
- We work closely with other businesses and companies that fall under the Pronto family of companies and our parent groups, including Risk Placement Services, Inc. (“RPS”) and its parent, Arthur J. Gallagher, Inc. We may share your personal information with other group companies for marketing purposes (subject to applicable laws or regulations), internal reporting and other purposes as described in this privacy notice.
- Law enforcement agencies, courts, regulators, government or quasi-governmental authorities or other third parties acting under the color of law. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, to enforce or apply any agreements between us and you, to resolve any disputes, or otherwise to protect our rights or the rights of any third party.
- Asset purchasers. We will not sell your personal information to third parties other than to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy notice.
- Online ad technology firms. We may transfer information about you to ad technology firms so that they may recognize your devices and deliver interest-based content and advertisements to you. The information may include your name, postal address, email, device ID, or other identifier in encrypted form. These firms may collect additional information from you, such as your IP address and information about your browser or operating system; may combine information about you with information from other companies in data sharing cooperatives in which we participate; and may place or recognize their own unique cookie on your browser.
Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the Services). See the section on “International Data Transfer” below for more information.
When required by applicable law, when we share personal information with corporate third parties we will ensure that such third parties maintain a comparable level of protection of the personal information as set out in this privacy notice by using contractual or other means. To the fullest extent permitted by applicable law, we exclude all liability arising from the use of your personal information by third parties. When required by applicable law, data transfers will be logged and documented, identifying the recipient of the data, the purpose of the transmission, and the type of data that was transmitted. Where required by law to do so, we can on request confirm the name of each third party that personal information is, or will be, transferred to.
Information Security And Storage
We implement technical, organizational, administrative and physical measures to help ensure a level of security appropriate to the risk to the personal information we collect, use, disclose and process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to help ensure the security of the processing. However, the transmission of information via the Internet is not completely secure, and although we will do our best to protect your personal information, we cannot guarantee the security of information as it is transmitted to our websites or apps. As such, any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to help prevent unauthorized access.
We limit internal access to our servers and have physical, electronic, and administrative safeguards in place to guard all personal information that we receive from visitors to our websites and apps. At Pronto, we adhere to high standards of ethics and integrity in performing our jobs and conducting business. However, it should be noted that there are some things, such as viruses and hacker attacks, which Pronto cannot control.
Pronto disposes of Personal Information in a secure manner by destroying or permanently erasing electronic data, and by disposing of hard copy data via burning, pulverizing, or utilizing shredding methods designed to ensure that Personal Information cannot be read or reconstructed.
Live chat sessions on our site are encrypted to encode information that you share with our operators. By contrast, be aware that email messages sent in clear text over the public internet can be observed by an unintended third party. Non-encrypted Internet e-mail communications may be accessed and viewed by other internet users without your knowledge and permission while in transit to us. If you wish to keep your information private, please do not use electronic mail to communicate information to us or request information from us that you consider to be confidential and/or proprietary. If you wish, you may contact us instead via telephone at the phone number provided elsewhere in this website.
For certain services on our website, such as live chat or webcasts, we will ask for information about you such as your name, business, and email address. In cases where we use a third-party vendor to provide online services, the vendor has agreed to keep your information confidential. For example, transcripts of live chat sessions may be archived in a database by our vendor for review by our operators.
Links To Other Sites
We may provide links to other websites not owned or controlled by us that we think might be useful or of interest to you. We are not, however, responsible for the privacy practices used by other website owners or the content or accuracy contained on those other websites. Links to other websites do not constitute or imply endorsement by us of those web sites, any products or services described on those websites or any other material contained in them. We advise that you contact any third party websites directly for their individual privacy policies.
International Data Transfer
We may transfer certain personal information across geographical borders to our affiliates, subsidiaries, our parent, Risk Placement Services, Inc. (“RPS”), RPS’s parent company, Arthur J. Gallagher, Inc., or service providers (working in conjunction with us or on our behalf) worldwide. Such transfers are made in accordance with applicable law.
Your California Privacy Rights
The provisions in this section relate solely to residents of the State of California. We included this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this section.
Applicability of the CCPA — Pronto As A Service Provider
Pronto is in the business of assisting individuals and companies and insurance carriers with providing insurance related solutions. In our role as an insurance broker or agent, we act as a service provider on behalf of our clients and insurance carriers. To this end, if not stated otherwise in this section or in a separate disclosure, we process your CCPA Covered Personal Information in the role of a service provider (as defined by the CCPA) on behalf of a customer (and/or its affiliates) or an insurance carrier who is the responsible business (as defined by the CCPA) for your CCPA Covered Personal Information. When acting as a service provider, we will only collect, use, and otherwise process your CCPA Covered Personal Information as directed by our customers and as otherwise permitted by the CCPA and applicable law. If your data has been submitted to us by or on behalf of our customer and you wish to exercise any CCPA consumer rights you may have under applicable data protection laws, please direct your requests to exercise any rights to the applicable customer directly. If you submit your request directly to us, consistent with the CCPA, we will inform you that you should submit the request directly to the business on whose behalf we process the information; where feasible, we will provide you with contact information for that business.
Your CCPA Consumer Rights
Effective January 1, 2020, the CCPA obligates businesses that collect consumer information (as that term is defined in the CCPA) to fulfill the following rights of California residents who submit a verifiable consumer request. As stated above, where we act as a CCPA service provider and receive a response directly from you, we will direct you to submit your request to the customer or carrier on whose behalf we process your information.
Sales Opt Out and Opt In
The CCPA gives consumers the right to opt out and opt in to the sales of their personal information. Pronto does not sell consumer personal information.
Right to Non-Discrimination
The CCPA prohibits businesses from discriminating against consumers because they exercised any of the consumers’ rights under the CCPA. We will not discriminate against you for exercising any of your CCPA consumer’s rights.
Exercising Access, Data Portability, and Deletion Rights
As stated above, we function as a CCPA service provider with respect to our corporate clients and insurance carriers that function as CCPA businesses. Where we act as a service provider and your data has been submitted to us by or on behalf of our corporate client or insurance carrier, we will not be able to substantively address your request to exercise consumer’s rights, and we will ask you to submit your request directly to the relevant business.
Other California Privacy Rights
California’s “Shine the Light” law permits our website and app visitors who are California residents to request and obtain from us once a year, free of charge, certain information about Personal Information (if any) we disclosed to third parties for direct marketing purposes. If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please send us an email or deliver the request via postal mail using the contact detail found in the Contact Us section below.
Pronto is primarily responsible for the personal information collected in relation to that Service. You may contact us directly at Legal Department, Attention: General Counsel, 805 Media Luna, Suite 300, Brownsville, Texas 78520. If you do not hear from us as quickly as you need to, you may contact our parent company, Risk Placement Services, Inc. (“RPS”). RPS’s North American Data Protection team can be contacted at Contact_Us@RPSins.com.
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority in your country of residence.
We may obtain information about your general internet usage by using a ‘cookie’ file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help Pronto to improve our sites and to deliver a better and more personalized service. They enable us to:
- Estimate our audience size and usage pattern;
- Store information about your preferences, and so allow us to customize our site according to your individual interests;
- Speed up your searches; and
- Recognize you when you return to our site.