www.newfront.com Open in urlscan Pro
76.76.21.241  Public Scan

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Text Content

 * Insurance
   
   
   PRODUCT & SERVICES
   
   We support clients with a variety of solutions that fit their needs.
   
    * Products
    * Services
   
   PRODUCTS
   
   
    * CASUALTY
   
   
    * CYBER RISK
   
   
    * EXECUTIVE RISK
   
   
    * PROPERTY
   
   
    * WORKERS’ COMPENSATION
   
   
    * SURETY
   
   
    * AVIATION
   
   
    * PRIVATE CLIENT
   
   SERVICES
   
   
    * GLOBAL INSURANCE
   
   
    * OH&S AND RISK CONTROL
   
   
    * RISK ANALYTICS & BENCHMARKING
   
   
    * CLAIMS ADVOCACY
   
   
    * CONTRACT REVIEW
   
   
    * ALTERNATIVE RISK FINANCING
   
   
    * MERGERS & ACQUISITIONS

 * Total Rewards
   
   
   TOTAL REWARDS
   
   Newfront works with clients to curate competitive benefit packages that
   attract, retain, and reward top talent.
   
   
   
   TOTAL REWARDS
   
   
    * TOTAL REWARDS
   
   
    * NEWFRONTIERS
   
   
    * RETIREMENT
   
   
    * BENEFITS COMPLIANCE

 * Industries
   
   
   INDUSTRY OFFERINGS
   
   Our dedicated experts serve clients across a variety of industries and
   specialties.
   
   
   View all industries
   
   INDUSTRIES
   
   
    * AGRICULTURE
   
   
    * AUTOMOTIVE
   
   
    * AVIATION
   
   
    * CONSTRUCTION
   
   
    * DIGITAL ASSETS & BLOCKCHAIN
   
   
    * DIGITAL HEALTH & TELEMEDICINE
   
   
    * EDUCATION
   
   
    * ENTERTAINMENT
   
   
    * FINTECH
   
   
    * FOOD & BEVERAGE
   
   
    * LIFE SCIENCE
   
   
    * MANUFACTURING
   
   
    * NONPROFIT ‍& SOCIAL ‍ENTERPRISE
   
   
    * PRIVATE EQUITY AND TRANSACTION ADVISORY
   
   
    * PUBLIC SECTOR
   
   
    * REAL ESTATE
   
   
    * RETAIL/ WHOLESALE
   
   
    * SHARING ECONOMY
   
   
    * TECHNOLOGY
   
   
    * TRANSPORTATION
   
   
    * VENTURE CAPITAL

 * Technology
   
   
   TECHNOLOGY
   
   Newfront provides critical guidance on market trends, the latest cost
   benchmarks, and evolving coverage requirements.
   
   
   
   TECHNOLOGY
   
   
    * TECHNOLOGY OVERVIEW
   
   
    * TOTAL REWARDS NAVIGATOR
   
   
    * PRODUCT PIPELINE

 * About
   
   
   WHO WE ARE
   
   Discover how Newfront makes a difference for clients.
   
   
   Learn more
   
   ABOUT NEWFRONT
   
   
    * CAREERS
   
   
    * LEADERSHIP
   
   
    * DE&I
   
   
    * EVENTS

 * Insights
   
   
   DISCOVER NEWFRONTIERS
   
   Newfront unveils its Premier Total Rewards Point-Solution Program
   
   
   Learn more
   
   INSIGHTS & RESOURCES
   
   
    * BLOG
   
   
    * PRESS

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PRIVACY POLICY

Last updated: May 18, 2023


INTRODUCTION

Newfront ("Company" or "We") respects your privacy and are committed to
protecting it through our compliance with our Website Privacy Policy.

This policy describes the types of information we may collect from you or that
you may provide when you visit www.newfront.com (our "Website") and our
practices for collecting, using, maintaining, protecting, and disclosing that
information.

This policy applies solely to personal information collected in connection with
www.newfront.com, all web pages within that domain, and any other web pages that
link to this Privacy Notice (the “Website”). This policy describes the types of
information we may collect from you or that you may provide when you our
"Website and our practices for collecting, using, maintaining, protecting, and
disclosing that information. This policy does not apply to the websites of our
affiliates, who maintain individual privacy policies for their respective
websites and services.

Please read this policy carefully to understand our policies and practices
regarding your information. By accessing or using this Website, you agree to
this privacy policy. This policy may change from time to time (see Changes to
Our Privacy Policy). Your continued use of this Website after we make changes is
deemed to be acceptance of those changes, so please check the policy
periodically for updates.


HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect information from you and about users of our Website in the following
ways:

 1. Directly from you when you voluntarily provide it to us using this Website.

 2. Through automated means as you navigate through the Website.


INFORMATION VOLUNTARILY PROVIDED DIRECTLY BY YOU:

In the course of using this Website, you may choose to provide us with
information to help us meet your needs. For example, you may enter your
information on our “Contact” page with your name, e-mail address, telephone
number, street address, and/or any other information you voluntarily enter in
order to request information. In the alternative, you may also complete a
registration for an event and provide us with your contact information,
employment details and title, as well as communication preferences.


INFORMATION COLLECTED THROUGH AUTOMATED MEANS:

As you navigate through and interact with our Website, we may use automatic data
collection technologies to collect certain information about your equipment,
browsing actions, and patterns, including details of your visits to our Website,
including the resources that you access and use on the Website as well as other
communication data.

The data collection technologies we use include cookies and web beacons. Cookies
are small pieces of text that a website places on your computer to help remember
information about your visit. Web beacons are tiny graphics with a unique
identifier that are embedded invisibly on the web pages.

We use information collected from cookies and web beacons to improve your
experience and the overall quality of our services. We may also use cookies and
web beacons to collect information from third parties (such as online search
engines) to help advertise our products and services, to analyze the
effectiveness of our marketing or the performance of this Website, and to
determine whether you may be interested in other products or services.

Neither cookies nor web beacons can read data off your computer's hard drive or
collect your personal information. You can refuse to accept and delete cookies
by adjusting your browser settings. You can also opt-out of our use of certain
cookies by adjusting your cookies preferences. To learn more, please refer to
our Cookies notice.


HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT?

We may use or disclose the personal information we collect for one or more of
the following business purposes:

 * To fulfill or meet the reason for which the information is provided

 * To provide you with information, products or services that you or your
   employer request from us

 * To provide you with email alerts, event registrations and other notices
   concerning our products or services, or events or news, that may be of
   interest to you

 * To carry out our obligations and enforce our rights arising from any
   contracts entered into between you and us, including for billing and
   collections

 * To improve our Website and present its contents to you, including to gather
   your feedback or survey responses.

 * For testing, research, analysis and product development

 * To host corporate events on behalf of Newfront.

 * As necessary or appropriate to protect the rights, property or safety of us,
   our clients or others

 * To maintain network security and performance and protect against cyber
   incidents.

 * To respond to law enforcement requests and as required by applicable law,
   court order, or governmental regulations

 * As otherwise described to you at the point of collection or pursuant to your
   consent.

 * To evaluate or conduct a merger, divestiture, restructuring, reorganization,
   dissolution, or other sale or transfer of some or all of our assets, whether
   as a going concern or as part of bankruptcy, liquidation, or similar
   proceeding, in which personal information held by us is among the assets
   transferred.

Newfront is a technology and data-driven Company, and we use data to develop
innovative products and deliver cutting-edge services. Newfront is not concerned
with data analysis on an individual basis, and we take steps designed to ensure
that your data is protected through the use of aggregated or otherwise
de-identified data.


WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We will not disclose, share, sell, or otherwise use your personal information
without your consent, except to the extent required by law, in accordance with
your instructions, or as identified in this Privacy Notice. We may share your
personal information with:

Agents and Service Providers: We sometimes contract with other companies and
individuals to perform functions or services for us or on our behalf, such as
hosting this Website, sending e-mail messages, and making phone calls. They may
have access to personal information, such as email addresses, needed to perform
their functions, but are bound by contractual confidentiality obligations and
are restricted from using personal information for any reason other than those
defined in our contract.

Business Transfers: To evaluate or conduct a merger, divestiture, restructuring,
reorganization, dissolution, or other sale or transfer of some or all of our
assets, whether as a going concern or as part of bankruptcy, liquidation, or
similar proceeding, in which personal information held by us is among the assets
transferred.

Legal Matters: The Company may preserve, and has the right to disclose any
information about you or your use of this Website without your prior permission
if the Company has a good faith belief that such action is necessary to: (a)
protect and defend the rights, property, or safety of the Company or its
affiliates, other users of this Website, or the public; (b) enforce the terms
and conditions that apply to use of this Website; (c) respond to claims that any
content violates the rights of third parties; (d) respond to claims of suspected
or actual illegal activity; (e) respond to an audit or investigate a complaint
or security threat; or (f) comply with applicable law, regulation, legal
process, or governmental requests.


WHAT DO WE DO TO PROTECT YOUR PERSONAL INFORMATION?

This Website and all information that you submit through this Website is
collected, stored, and processed in the United States. We restrict access to
your personal information to only our employees, agents, partners, and service
providers who need to use it to provide this Website and our products or
services. We have taken reasonable steps to implement physical, administrative,
and technical safeguards designed to protect your personal information from
unauthorized access.


THIRD PARTY SITES

This Website may include links to other sites operated by third party
organizations. If you access another organization’s site using a link provided,
the other organization may collect information from you. Once you have left this
Website through a third party link, you should refer to those sites' policies
and terms of use. The Company is not responsible for the content or privacy
practices of linked sites.


PERSONAL INFORMATION OF MINORS

This Website is not intended for children, and we do not knowingly collect, use,
or disclose information of children under the age of thirteen (13) without the
consent of their parents or legal guardians.


COOKIES NOTICE

Updated: May 18, 2023

We use different types of cookies to optimize your experience on our Website.
Cookies are pieces of information shared between your web browser and a website.
Some cookies are necessary for making the website work. Some help us assess and
improve its performance. We also use cookies to help provide relevant content,
products and services to you. A cookie cannot read data from your computer's
hard drive.

There are different kinds of cookies with different purposes:


DIFFERENT KINDS OF COOKIES WE MAY USE:

 * Session cookies: these cookies are only stored on your computer during your
   web session. They are automatically deleted when the browser is closed. They
   usually store an anonymous session ID allowing you to browse a website
   without having to log in to each page. They do not collect any information
   from your computer

 * Persistent cookies: these cookies are stored as a file on your computer and
   remain there when you close your web browser. These cookies allow the party
   that set them to recognize your computer when it visits our Website or when
   it visits certain other sites

 * First-party cookies: these cookies are created by our Company. They are
   stored and sent between our servers and your computer’s hard drive. These
   cookies may be either Session or Persistent cookies

 * Third-party cookies: these cookies are created by one of our third-party
   partners. They are stored and sent between the third-party’s server and your
   computer’s hard drive. These cookies are usually Persistent cookies and
   enable third party features or functionality to be provided on or through the
   Website (e.g., advertising, interactive content, or analytics).


DIFFERENT PURPOSES OF COOKIES:

Depending on the page, we may use cookies for the following purposes:

 * Where Strictly Necessary: These essential cookies are necessary to enable you
   to use our Website’s features. Without these cookies, services you have asked
   for, such as obtaining a quote or logging into your account, cannot be
   provided. These cookies do not gather information about you that could be
   used for marketing purposes or recording where you have been on the internet.

 * Performance and Functionality Cookies: These cookies allow our Website to
   remember choices you make and provide enhanced features, such as auto-logon.
   They may also be used to provide services you have requested such as
   receiving updates or information from a query. The information these cookies
   collect is usually de-identified. They do not gather any information about
   you that could be used for advertising or remember where you have been on the
   internet.

 * Analytics: These cookies collect information about how many visitors use our
   Website, how they use the Website, whether there are any inefficiencies in
   the site structure, or whether there are web page error messages. This
   information is used to improve the way that our Website works.

 * Advertising Cookies: These cookies are used for the purpose of displaying
   advertisements that will be relevant to you and for managing the performance
   of advertisements. Advertising cookies are generally third-party cookies and
   may be present even if there are no visible advertisements on the Website.


HOW TO CONTROL COOKIES AND OTHER TRACKING TECHNOLOGIES

 * Cookies: You can update your preferences to restrict collection of certain
   cookies at this link.

 * Browser: You may also restrict cookies using your web browser controls, which
   vary by browser. Visit your browser’s help menu for additional information.

 * Web beacons: In most instances, web beacons are dependent on cookies. By
   adjusting your cookies preferences to restrict cookies, you will also
   restrict web beacons with dependency on those cookies.


CHANGES TO OUR COOKIES NOTICE

We reserve the right to amend this cookies policy at our discretion and at any
time. When we make changes to this policy, we will update this notice's
effective date. Your continued use of our Website following the posting of
changes constitutes your acceptance of such changes.


CHANGES TO OUR PRIVACY NOTICE

We reserve the right to amend this privacy policy at our discretion and at any
time. When we make changes to this privacy policy, we will post the updated
notice on the Website and update the notice's effective date. Your continued use
of our Website following the posting of changes constitutes your acceptance of
such changes.




APPLICABILITY OF THIS PRIVACY POLICY TO INTERNATIONAL USERS

This Privacy Policy is crafted and provided in accordance with and subject to
U.S. law and GDPR, where applicable. If you access this Website from a location
outside of the United States, you agree that your use of this Website is subject
to the terms of this Privacy Policy. You also agree and accept that your
personal information will be transferred to and processed in the U.S. in
accordance with U.S. law or GDPR, where specified, and not the specific laws of
the country where you reside.


PRIVACY POLICY FOR CALIFORNIA RESIDENTS

This Privacy Policy for California Residents supplements the information
contained in Company’s Privacy Policy and applies solely to all visitors, users,
and others who reside in the State of California ("consumers" or "you").

In particular, our Website has collected the following categories of personal
information from consumers within the last twelve (12) months:


CATEGORIES OF INFORMATION COLLECTED FROM YOU:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online
identifier, Internet Protocol address, email address, account name, Social
Security number, driver's license number, passport number, or other similar
identifiers.

YES

B. Personal information categories listed in the California Customer Records
statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or
description, address, telephone number, passport number, driver's license or
state identification card number, insurance policy number, education,
employment, employment history, bank account number, credit card number, debit
card number, or any other financial information, medical information, or health
insurance information. Some personal information included in this category may
overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship,
religion or creed, marital status, medical condition, physical or mental
disability, sex (including gender, gender identity, gender expression, pregnancy
or childbirth and related medical conditions), sexual orientation, veteran or
military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or
considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity
patterns used to extract a template or other identifier or identifying
information, such as, fingerprints, faceprints, and voiceprints, iris or retina
scans, keystroke, gait, or other physical patterns, and sleep, health, or
exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a
website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and
Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational
institution or party acting on its behalf, such as grades, transcripts, class
lists, student schedules, student identification codes, student financial
information, or student disciplinary records. Examples: Education level, school
attended.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological
trends, predispositions, behavior, attitudes, intelligence, abilities, and
aptitudes.

NO


WHAT ARE SOURCES OF PERSONAL INFORMATION?

We may receive personal information from you from the following sources:

 * From you, through direct interactions, including forms.

 * Internet websites, through passive collection of information about your
   interactions, including page clicks, time spent, or other automatically
   collected metadata.

 * Internet cookies. For more information, see our Cookies Notice.

 * Advertising networks.

 * Internet service providers.

 * Data analytics providers.

 * Operating systems and platforms.

 * Observations from monitoring behavior, such as store video camera or
   surveillance systems.

 * Search terms.

 * Data brokers or resellers.

 * Social media services, like Instagram or Facebook.

 * Government databases.


HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT AND WITH WHOM DO WE SHARE IT?

Click here for an explanation of how we use personal information.

Click here for an explanation of who may have access to your personal
information.

In addition, in the past 12 months, the Company may have shared the categories
of personal information below collected from this Website to fulfill its
business purpose.


CATEGORIES OF INFORMATION COLLECTED FROM YOU:

Category

Examples

Shared for Business Purposes

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online
identifier, Internet Protocol address, email address, account name, Social
Security number, driver's license number, passport number, or other similar
identifiers.

YES

B. Personal information categories listed in the California Customer Records
statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or
description, address, telephone number, passport number, driver's license or
state identification card number, insurance policy number, education,
employment, employment history, bank account number, credit card number, debit
card number, or any other financial information, medical information, or health
insurance information. Some personal information included in this category may
overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship,
religion or creed, marital status, medical condition, physical or mental
disability, sex (including gender, gender identity, gender expression, pregnancy
or childbirth and related medical conditions), sexual orientation, veteran or
military status, genetic information (including familial genetic information).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or
considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity
patterns used to extract a template or other identifier or identifying
information, such as, fingerprints, faceprints, and voiceprints, iris or retina
scans, keystroke, gait, or other physical patterns, and sleep, health, or
exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a
website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and
Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational
institution or party acting on its behalf, such as grades, transcripts, class
lists, student schedules, student identification codes, student financial
information, or student disciplinary records. Examples: Education level, school
attended.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological
trends, predispositions, behavior, attitudes, intelligence, abilities, and
aptitudes.

NO




YOUR RIGHTS AS A CALIFORNIA RESIDENT

Under California law, some California residents have specific rights regarding
their personal information, described below. When required, we will respond to
most requests within 45 days, unless it is reasonably necessary for us to extend
our response time.


RIGHT TO KNOW AND DATA PORTABILITY

You have the right to request that We disclose to the you any of the information
below, provided that you submit a valid and verifiable request:

 * The categories of personal information we have collected about you in the
   last 12 months (also called a data portability request).

 * The categories of sources for the personal information we have collected
   about you in the last 12 months.

 * Our business or commercial purpose for collecting that personal information.

 * The categories of third parties with whom we share that personal information.

 * The specific pieces of personal information we collected about you.

 * If we sold your personal information for a business purpose, a list of the
   personal information types that each category of recipient purchased.

 * If we disclosed your personal information to a third party for a business
   purpose, a list of the personal information types that each category of
   recipient received.


RIGHT TO DELETE PERSONAL INFORMATION

You have the right to request that we delete any of your personal information
that we collected from you and retained, subject to certain exceptions. If you
submit a valid and verifiable request and we can confirm your identity and/or
authority to make the request, we will determine if retaining the information is
necessary for us or our service providers to:

 * Complete a transaction for which we collected the personal information,
   provide a good or service that you requested, take actions reasonably
   anticipated within the context of our ongoing business relationship with you,
   or otherwise perform our contract with you

 * Detect security incidents, protect against malicious, deceptive, fraudulent,
   or illegal activity, or prosecute those responsible for such activities;

 * Debug products to identify and repair errors that impair existing intended
   functionality.

 * Exercise free speech, ensure the right of another consumer to exercise their
   free speech rights, or exercise another right provided for by law;

 * Comply with the California Electronic Communications Privacy Act (Cal. Penal
   Code § 1546 seq.);

 * Engage in public or peer-reviewed scientific, historical, or statistical
   research in the public interest that adheres to all other applicable ethics
   and privacy laws, when the information's deletion may likely render
   impossible or seriously impair the research's achievement, if you previously
   provided informed consent;

 * Enable solely internal uses that are reasonably aligned with consumer
   expectations based on your relationship with us;

 * Comply with a legal obligation; and/or

 * Make other internal and lawful uses of that information that are compatible
   with the context in which you provided it.

If none of the above retention conditions apply, we will delete your personal
information from our records and direct any applicable service providers to do
the same.


RIGHT TO CORRECT

If you believe any personal information collected by this Website is inaccurate,
you have the right to submit a verifiable request that the Company correct the
information.


RIGHT TO LIMIT USE

As a California resident, you also have the right to restrict sensitive personal
information use and disclosure for the same. The Company does not collect
sensitive personal information using this Website.


HOW TO EXERCISE THESE RIGHTS

To exercise your rights described above, please submit a verifiable consumer
request to us as follows:

 * Email: privacy@newfront.com

A “verifiable consumer request” means a request that provides sufficient
information to enable us to reasonably verify you and fulfill your request. We
cannot respond to your request or provide you with personal information if we
cannot verify your identity or authority to make the request and confirm the
personal information relates to you. Examples of information necessary include:

 * Confirmation of certain pieces of information about you, such as phone number
   and address;

 * Proof of identity;

 * Detail to allow us to understand, evaluate, and respond to your request.

Only you or a person legally authorized to act on your behalf may make a
verifiable consumer request related to your personal information. You may make a
verifiable consumer request for access or deletion no more than twice within a
12-month period. You will not be required to create an account with us in order
to submit a verifiable request, though we may communicate with you about your
request via a pre-established account if applicable.


DO NOT SELL MY PERSONAL INFORMATION

Although the Company does not sell your personal information, you have the right
to opt-out of sharing personal information for cross-context behavioral
advertising purposes, also known as “targeted advertising.” Personal information
related to targeted advertising is generally collected through the use of third
party cookies. To opt-out of sharing your personal information for cross-context
behavioral advertising purposes, you can adjust your Website preferences. For
more information about cookies, see our Cookies notice.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under
California law. Unless permitted by law, we will not:

 * Deny you goods or services.

 * Charge you different prices or rates for goods or services, including through
   granting discounts or other benefits, or imposing penalties.

 * Provide you a different level or quality of goods or services.

 * Suggest that you may receive a different price or rate for goods or services
   or a different level or quality of goods or services.


CHANGES TO OUR PRIVACY NOTICE

We reserve the right to amend this privacy policy at our discretion and at any
time. When we make changes to this privacy policy, we will post the updated
notice on the Website and update the notice's effective date. Your continued use
of our Website following the posting of changes constitutes your acceptance of
such changes.


NOTICE AT COLLECTION

By completing a “Schedule a Consultation” request form, you acknowledge that
Newfront is collecting your personal information to support its business
operations, including to contact you at your request.  We will not share or sell
this contact information and will retain such information in accordance with our
data retention policies and regulatory obligations.


PRIVACY POLICY FOR EU CITIZENS

This Privacy Policy for European Union citizens supplements the information
contained in Company’s Privacy Policy and applies solely to all visitors, users,
and others who are citizens of the EU, regardless of physical location
("consumers" or "you").


HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT AND WITH WHOM DO WE SHARE IT?

Click here for an explanation of how we use personal information.

Click here for an explanation of who may have access to your personal
information.

In addition to the partners listed above, we may transfer certain personal
information across geographical borders to Newfront partners through the
Worldwide Broker Network (WBN), authorized service providers or business
partners in other countries working on our behalf in accordance with applicable
law. Our affiliates and third parties may be based locally, or they may be
overseas some of which have not been determined by the European Commission to
have an adequate level of data protection.

When we do, we use a variety of legal mechanisms to help ensure your rights and
protections travel with your data:

 * We seek to cover applicable data transfers with agreements based on the EU
   Commission’s standard contractual clauses, which contractually oblige each
   member to ensure that personal information receives an adequate and
   consistent level of protection wherever it resides within Newfront;

 * where we transfer your personal information outside Newfront or to third
   parties who help provide our products and services, we seek to obtain
   contractual commitments from them to protect your personal information. Some
   of these assurances are well recognized certification schemes like the EU –
   US Privacy Shield for the protection of personal information transferred from
   within the EU to the United States, or the standard contractual clauses; or

 * where we receive requests for information from law enforcement or regulators,
   we carefully validate these requests before any personal information are
   disclosed.

If you would like further information about whether your information will be
disclosed to overseas recipients, please contact us as noted below. You also
have a right to contact us for more information about the safeguards we have put
in place (including a copy of relevant contractual commitments, which may be
redacted for reasons of commercial confidentiality) to ensure the adequate
protection of your personal information when this is transferred as mentioned
above.


YOUR RIGHTS UNDER GDPR

Subject to certain exemptions, and in some cases dependent upon the processing
activity we are undertaking, you have certain rights in relation to your
personal information.

We may ask you for additional information to confirm your identity and for
security purposes, before disclosing the personal information requested to you.
We reserve the right to charge a fee where permitted by law, for instance if
your request is manifestly unfounded or excessive.

You can exercise your rights by contacting us. Subject to legal and other
permissible considerations, we will make every reasonable effort to honor your
request promptly or inform you if we require further information in order to
fulfil your request.

We may not always be able to fully address your request, for example if it would
impact the duty of confidentiality we owe to others, or if we are legally
entitled to deal with the request in a different way.

 * Right to Access: You have right to access personal information which Newfront
   holds about you. If you have created a profile, you can access that
   information by visiting Newfront Connect.

 * Right to Rectification: You have a right to request us to correct your
   personal information where it is inaccurate or out of date.

 * Right to be Forgotten (Right to Erasure): You have the right under certain
   circumstances to have your personal information erased. Your information can
   only be erased if your data is no longer necessary for the purpose for which
   it was collected, and we have no other legal ground for processing the data.

 * Right to Restrict Processing: You have the right to restrict the processing
   of your personal information, but only where:
   
   * its accuracy is contested, to allow us to verify its accuracy; or
   
   * the processing is unlawful, but you do not want it erased; or
   
   * it is no longer needed for the purposes for which it was collected, but we
     still need it to establish, exercise or defend legal claims; or
   
   * you have exercised the right to object, and verification of overriding
     grounds is pending.

 * Right to Data Portability: You have the right to data portability, which
   requires us to provide personal information to you or another controller in a
   commonly used, machine readable format, but only where the processing of that
   information is based on (i) consent; or (ii) the performance of a contract to
   which you are a party.

 * Right to Object to Processing: You have the right to object the processing of
   your personal information at any time, but only where that processing has our
   legitimate interests as its legal basis. If you raise an objection, we have
   an opportunity to demonstrate that we have compelling legitimate interests
   which override your rights and freedoms.

 * Right to Decline Automated Decision Making: You have the right to not be
   subject to decisions based solely on automated decision making, which produce
   legal or significant effects for you, except where these are (i) necessary
   for a contract to which you are a party; (ii) authorized by law; (iii) based
   on your explicit consent.
   
   * Even where such decisions are permitted, you can contest the decision and
     require Newfront to exercise human intervention.
   
   * We currently do not use automated decision making (including automated
     decision making using profiling) when processing your personal information.
     If we ever use an automated decision-making solution, you have a right to
     request that a decision based off your personal information cannot be
     solely decided via an automated process.


CONTACT US

To exercise your rights described above, please contact us:

 * Email: privacy@newfront.com




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We are transforming the risk management, business insurance, total rewards, and
retirement services space through the combination of elite expertise and
cutting-edge technology. Newfront Insurance Services is a trade name licensed to
sell insurance products in all 50 states, the District of Columbia, and Puerto
Rico. See this link for a list of our licenses.

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