Last updated May 2024
This Notice describes how Milliman, Inc. and its affiliates (“Milliman” or “we”) handle the Personal Information of California residents when they interact with Milliman as a business contact (“you”). This Notice is being provided in accordance with the California Consumer Privacy Act 2018 (Cal. Civ. Code § 1798.100 et seq.), as amended by the California Privacy Rights Act of 2020 (together, “CCPA”). For more complete information about Milliman’s California Consumer Privacy Policy, please visit our U.S. Data Privacy Policy.
This Notice applies to the Personal Information we collect, use, disclose, and process when you interact with Milliman in a business-to-business capacity. The term “Business Contacts” shall include representatives, officers, agents and employees, business partners, providers, parties to a contract, and any other person which contacts or interacts with Milliman in the context of establishing, developing, maintaining, servicing, or otherwise furthering a business relationship.
“Personal Information” means information that identifies, relates to, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a Business Contact. This Notice does not cover:
We collect Personal Information about you in the following ways:
The following describes the categories of Personal Information Milliman may collect about you (and may have collected in the last twelve (12) months).
Milliman may process the Personal Information described above for the following business purposes:
For the avoidance of doubt, Milliman does not process, collect, use, or disclose Sensitive Personal Information (as that term is defined in § 1798.140(ae) of the CCPA) beyond the purposes authorized by the CCPA.
Milliman retains Business Contacts Personal Information for as long as necessary to fulfill the purposes outlined in this Notice, unless a longer retention period is required by law. If Personal Information must be kept for administrative, legal, or regulatory purposes, Milliman will keep the minimum amount of Personal Information necessary to comply with such purposes.
To carry out the purposes outlined above, Milliman may disclose Personal Information to third parties and other recipients for a business purpose, such as:
Milliman does not sell or share the above categories of Personal Information. The CCPA defines “sell” as the disclosure of Personal Information for monetary or other valuable consideration, and “share” as the disclosure of Personal Information by a business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration. Milliman may add to the categories of Personal Information it collects and the purposes for which it uses Personal Information. In such cases, Milliman will inform Business Contacts. We do not sell or share the Personal Information of individuals under 16 years of age.
Individuals who are residents of the State of California have certain individual rights as outlined below.
Upon receipt of a verifiable Consumer request, and as required by the CCPA, Milliman will provide a response to such requests in accordance with § 1798.130 of the CCPA.
Right To Know About Personal Information Collected or Disclosed. You have the right to request more information regarding the following topics, to the extent applicable:
Right To Request Deletion of Your Personal Information. You have the right to request that Milliman delete the Personal Information it has collected or maintains about you. Once a verified request is received, Milliman will let you know what, if any, Personal Information can be deleted from its records, and Milliman will direct any service providers and contractors to whom it disclosed your Personal Information to also delete your Personal Information from their records.
There may be circumstances where Milliman cannot delete your Personal Information or direct service providers or contractors to delete your Personal Information from their records. Such instances include, but are not limited to, enabling solely internal uses that are reasonably aligned with your expectations based on your relationship with Milliman and compatible with the context in which you provided the information or to comply with a legal obligation.
Right to Request Correction. You have the right to request that Milliman correct any inaccurate Personal Information it maintains about you, taking into account the nature of that information and purpose for processing it.
Right to Opt-Out. You have the right to opt-out of the “sale” and “sharing” of your Personal Information, as those terms are defined under the CCPA. As described above, we do not “sell” or share your Personal Information, and therefore do not offer a mechanism to exercise the right to opt-out.
Right to Limit the Use and Disclosure. We use and/or disclose sensitive personal information for the permitted purposes specified in the CCPA and therefore do not offer a mechanism to exercise the right to limit the use of sensitive personal information.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. Milliman will not discriminate or retaliate against you for exercising any of your rights as described above.
Requests for the application of your rights may be submitted by either:
Milliman reserves the right to only respond to verifiable Consumer requests to know, delete, or correct.
Milliman reserves the right to amend this Notice at any time without advance notice.
If you have any questions or comments about this Notice, you may contact us at [email protected].