Jurisdiction-specific privacy policies

California (United States)

Cyprus

Data Privacy Policy - Cyprus

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Last updated March 2020

Where Milliman is Acting as a Data Controller

Milliman, Inc. and its affiliates (“Milliman”or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing the Cypriot affiliate’s (Milliman Limited) use and protection of personal data that individuals and clients residing within the European Economic Area, the Isle of Man, Switzerland and the UK, share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the EU-U.S. Privacy Shield, the EU General Data Protection Regulation (GDPR), and other data protection and privacy laws, as applicable.

Milliman, Inc. and Milliman Limited are joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Milliman Limited are both responsible for the compliance with applicable data protection laws.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.

Processing of Personal Data

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with visitors and the administration of the website.The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR).

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract (name, professional address, title, email and other professional contact details) for contract administration purposes. The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR). Milliman may rely on your consent(Art. 6 (1) letter (a) GDPR) for the sending of marketing communications when so required by data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication.Milliman Limited may also use professional contact details of its clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests. For those activities, the legal basis for the processing of Personal Data is Milliman Limited’s legitimate interest (Art. 6 (1) letter (f) GDPR), unless data protection and privacy law require your prior consent. We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you may write to us at data.protection@milliman.com requesting the same. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

No automated decision-making is undertaken based on the Personal Data collected from you.

Affiliates and Authorized Third-Party Agents

All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman Consultants and Actuaries S.L. and Milliman, Inc. or other entities controlled by or under common control with Milliman, Inc., for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events. We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that itself and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the GDPR (adequacy decision or Model Clauses of the European Commission). Those can be made available at Milliman’s premises, by contacting us at data.protection@milliman.com

Other Disclosures

Milliman may also disclose Personal Data and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited PersonalData (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact Milliman at data.protection@milliman.com, and Milliman will take steps to delete any such Personal Data.

Third-party Links

Milliman’ website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third Party Websites is no longer under our control and no longer subject to Milliman Personal Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Information to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Privacy Shield

Milliman is committed to handling Personal Data in accordance with this Privacy Policy and the EU-U.S. Privacy Shield Framework (or the Swiss-U.S. Privacy Shield Framework, as the case may be), as administered by the U.S. Department of Commerce. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and to view Milliman’s certification, please visit https://www.privacyshield.gov/list.

Milliman’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Milliman remains responsible and liable under the Privacy Shield Principles if third parties engaged by Milliman process the Personal Data in a manner inconsistent with the Principles, unless Milliman proves that it is not responsible for the event giving rise to any damage. Additionally, Milliman, Inc. has put in place data protection agreements with its affiliates located in the European Economic Area based on the EU Standard Contractual Clauses issued by the European Commission (the “EU Standard Contractual Clauses”).

As further explained in the "How to Contact Us" section below, Milliman encourages any individual to contact us should they have a Privacy Shield-related (or general privacy-related) complaint. Any right of access, rectification, erasure, restriction of the processing as well as the right to data portability of individuals domiciled in the European Economic Area or Switzerland may be exercised under the conditions set forth in the GDPR by contacting Milliman at data.protection@milliman.com. Furthermore, these individuals will have the right to lodge a complaint with a competent supervisory authority at any time.

Rights

You have a number of rights under the GDPR in relation to your Personal Data, namely:

  1. the right of access pursuant to Art. 15 GDPR: you have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Data and the manner in which, and the purposes for which we process your Personal Data, so that you can verify its accuracy and the lawfulness of the processing.
  2. the right to rectification pursuant to Art. 16 GDPR: you have the right to obtain from us the rectification of inaccurate Personal Data concerning you, and the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  3. the right to erasure pursuant to Art. 17 GDPR: the right to obtain from us the erasure of your Personal Data delay where (a) your Personal Data is no longer necessary for the purpose for which it was collected/processed; (b) you wish to withdraw your consent to processing (except where we have another legal ground for the processing that we may rely on); (c) where processing is based on our legitimate interests and there are no overriding legitimate grounds for processing; (d) where your Personal Data has been unlawfully processed;
  4. the right to restriction of processing pursuant to Art. 18 GDPR: you have the right to obtain from us the restriction of processing of your Personal Data where (a) the accuracy of such Personal Data is contested by you (for such period as will enable us to verify the accuracy of your Personal Data); (b) the processing of your Personal Data is unlawful, but you do object to the deletion of such data and request restriction of its use instead; (c) you consider that we no longer need your Personal Data for the purposes of the processing, but require such Personal Data for the establishment, exercise or defense of legal claims; (d) you have objected to the processing of your Personal Data on grounds of “legitimate interest” as per (iii) above, pending verification by us on whether our legitimate grounds override your own.
  5. the right to objection pursuant to Art. 21 GDPR: you have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data, which is based on point our legitimate interests, including profiling based on those provisions. We shall no longer process the Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. You may object to the processing of your Personal Data or direct marketing purposes at any time, without giving reason.
  6. the right to data portability pursuant to Art. 20 GDPR: you have the right to receive Personal Data concerning you, and which you have provided to us, in a structured, commonly used and machine-readable format, and to transmit such data to another data controller (please note this applies only where our processing of your Personal Data is based on your consent, and the processing is carried out by automated means).
  7. the right to appeal to a competent data protection supervisory authority (Art. 77 GDPR): you have the right to appeal to the competent data protection supervisory authority - in Cyprus, such authority is the “Office of the Commissioner for the Protection for Personal Data Protection” (www.dataprotection.gov.cy).

Please note that any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights as stated above, by sending us a request to data.protection@milliman.com. We will endeavor to respond to any such request as soon as possible, and in any event within the legal deadline.

How to Contact Us

Milliman’s European Data Protection Officer can be contacted at data.protection@milliman.com.

If you live in the European Union, European Economic Area, or Switzerland and you have a complaint regarding the handling of your Personal Data in accordance with the EU-U.S. or Swiss-U.S. Privacy Shield Framework and your efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the American Arbitration Association (http://go.adr.org/privacyshield.html), which has been selected as the independent recourse mechanism to resolve complaints and disputes relating to treatment of Personal Data originating in the European Union, European Economic Area, or Switzerland and transferred to the U.S. under this Privacy Policy. Under certain conditions, you may be entitled to invoke binding arbitration through the Privacy Shield Panel when other dispute resolution procedures have been exhausted. Milliman is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Australia

Privacy Policy

At Milliman, we take data privacy very seriously. This policy applies to all personal information collected by Milliman, Inc. and its affiliates in the course of their normal business activities involving an Australian link. The purpose of this policy is to set out the principles governing Milliman’s use of such information. If you give us personal information, we will treat it according to this policy.

1. What is an “Australian link”?

Milliman Australia Pty Ltd is deemed to have an “Australian link” by virtue of the fact that it is incorporated in Australia. Other members of the Milliman Group of companies will be deemed to have an Australian link, and will therefore be bound by this policy, if and to the extent that they carry on business in Australia, or collect or hold any personal information in Australia.

2. What is "personal information"?

The Privacy Act 1988 (Cth) (Act) defines "personal information" as information or an opinion about an identified individual or an individual who is reasonably identifiable:

(a) whether the information or opinion is true or not; and

(b) whether the information or opinion is recorded in a material form or not.

If information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “personal information” and will not be subject to this privacy policy.

You should be aware that the Privacy Act contains certain exemptions which may impact upon our privacy obligations. For example, employee records are generally exempt from an organisation's obligations under the Act. This exemption does not, however, permit us to use personal information contained in employee records for purposes not connected with the employment relationship. Employee records remain confidential.

3. What information do we collect?

The personal information we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through our website, Milliman’s marketing activities and contract administration:

(a) we may collect, store and process the personal information of visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with clients and the administration of the website;

(b) we may also collect, store and process the personal information of clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract (name, professional address, title, email and other professional contact details) for contract administration purposes;

(c) we may collect, store and process the personal information of the professional contact details of clients’ representatives, their employees and business partners in order to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services, and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest;

(d) we may also use professional contact details of clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests, unless there is a legal requirement to obtain prior consent; and

(e) we may also collect and process limited personal information about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes;

(f) without limiting sub-paragraph (e) above, we assume that if you use our services, you consent to the receipt of direct marketing material regarding the products and services we offer or develop. We will only use your personal information in this regard if we have collected such information directly from you, and if it is material of a type which you would reasonably expect to receive from us. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature. An alternative means of opting out is to contact us as set out below and simply request that you receive no further such communications.

In each case, however, this information will only be subject to this policy, and to protection under the Privacy Act, if it is in fact possible to identify you from that information.

4. How we collect your personal information

By voluntarily providing us with information about yourself, you are consenting to our use of that data in the manner described in this policy.

Where reasonable and practicable to do so, we will collect your personal information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

If we collect personal information from you via our website, we may use digital cookies to remember your preferences and collect online traffic data and browsing characteristics. Internet cookies are small strings of text placed on a user’s hard drive during the data exchange that happens when a browser points to a website. The browser stores the message in a text file which is sent back to the server each time the browser requests a page from the server. Cookies and other information collection technologies can only store information that is explicitly provided by the user or visitor in the first place, or information which is already known to the website such as your IP address. You can choose to adjust your browser to reject cookies or to notify you when they are being used, bearing in mind that rejecting cookies can result in a loss of some website functionality.

5. Aggregate information

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No personal information is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet service provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

6. Purpose of collection

We collect personal information for the purpose of managing the relationship with our clients, administering our website, authentication of website visitors and for contract administration. To the extent permitted by law, we may also use professional contact details of our clients’ employees for the purpose of sending surveys and questionnaires or for the purpose of organizing games, and we may source personal information from public resources (such as LinkedIn) to allow us to assess a potential interest in our services and to contact you for marketing purposes.

If we obtain any personal information about you, we may share it with other Milliman entities, wherever located, for the purposes of data processing or storage.

We may have cause to disclose personal information to our service providers who assist us in operating our computer systems. Your personal information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties. In the event that we outsource part of our infrastructure, it is possible that the entity we engage for this purpose may also have access to your personal information.

In addition, we may share your personal information with authorised third-party agents or contractors in order to provide a requested service or transaction. We only provide third-party agents with the minimum amount of personal information necessary to complete the requested service or transaction.

Subject to the foregoing, we only use your personal information in a manner consistent with the original purposes of collection or as otherwise permitted by the Australian Privacy Principles.

7. Legal obligation to disclose

We may disclose your personal information to a third party if required or authorised to do so under an Australian law or by a court or tribunal order, or where disclosure is reasonably necessary for one or more enforcement related activities conducted by or on behalf of an enforcement body, or as otherwise required or permitted by law (such as the investigation of suspicious or unlawful behavior, the defence of a legal claim or for use in connection with a confidential alternative dispute resolution process).

8. Security

We take all reasonable steps to protect personal information from misuse, interference and loss, and from unauthorized access, modification or disclosure. We store your personal data on a secure server that is password protected and shielded from the outside world by a firewall. We have in place security policies that are intended to ensure, as far as possible, the security and integrity of all our information, including your personal information. If we forward personal information to any third party, we require that those third parties have appropriate technical and organisational measures in place to comply with this privacy policy and applicable laws.

9. Data Retention

Milliman retains personal information only as long as necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or not prohibited by law. Milliman will delete or de-identify your personal information once the purpose of the collection and processing of such personal information has been fulfilled. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your personal information for any other purpose for which we still have legal grounds for holding such information. In certain cases, if no other legal grounds exist, we will maintain limited personal information (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

10. Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect personal information from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with personal information without their consent, the parent or legal guardian should contact Milliman at data.privacy@milliman.com, and Milliman will take steps to delete any such Personal Data.

11. Access and correction

Australian Privacy Principle 12 permits you to obtain access to the personal information we hold about you in certain circumstances, and Australian Privacy Principle 13 allows you to correct inaccurate personal information subject to certain exceptions. If you wish to seek access for this purpose, please contact our Chief Compliance Officer at data.privacy@milliman.com.

There is no charge for requesting access. If access is subsequently provided, a small fee may be charged.

12. Complaint procedure

If you have a complaint concerning the manner in which we maintain the privacy of your personal information, please contact us as set out below. All complaints will be considered by our Chief Compliance Officer at data.privacy@milliman.com and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.

13. Overseas transfer

The United Kingdom and the European Union

Your personal information may be transferred from Australia to recipients located in the United Kingdom or the European Union. The United Kingdom, and countries which are members of the European Union, have data protection laws which protect personal information in a way which is at least substantially similar to the Australian Privacy Principles, and there will be mechanisms available to you to enforce protection of your personal information under that overseas law. In the circumstances, we do not require the overseas recipients to comply with the Australian Privacy Principles and we will not be liable for a breach of the Australian Privacy Principles if your personal information is mishandled.

The United States of America

Your personal information may be transferred from Australia to recipients located in the United States of America. The United States of America does not have data protection laws as comprehensive as Australia’s, and we will accordingly take reasonable steps to secure a contractual commitment from the recipient to handle your information in accordance with the Australian Privacy Principles.

14. Third-party links

Milliman’s website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your personal information.

We do not disclose your personal information to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third-Party Websites is no longer under our control and no longer subject to this privacy policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your personal information should you have decided to disclose your personal information to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any personal information that you choose to provide to such a Third-Party Website and use of Third Party Websites is strictly at your own risk.

15. Amendments to this policy

We reserve the right to change and modify this privacy policy at any time without prior notice. Your continued use of our services following the posting on our website of changes to these terms means you accept these changes. You will always have access to the most recent policy on https://au.milliman.com.

16. How to contact us about privacy

If you have any queries, or if you seek access to your personal information, or if you have a complaint about our privacy practices, you can contact us on: data.privacy@milliman.com.

France

Data Privacy Policy - France

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Last updated March 2020

Where Milliman is Acting as a Data Controller

Milliman, Inc. and its affiliates (“Milliman”or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing the French affiliate’s (Milliman SAS) use and protection of personal data that individuals and clients residing within the European Economic Area, the Isle of Man, Switzerland and the UK, share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the EU-U.S. Privacy Shield, the EU General Data Protection Regulation (GDPR), and other data protection and privacy laws, as applicable.

Milliman, Inc. and Milliman SAS are joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Milliman SAS are both responsible for the compliance with applicable data protection laws.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.

Processing of Personal Data

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with visitors and the administration of the website.The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR).

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract(name, professional address, title, email and other professional contact details)for contract administration purposes.The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR). Milliman may rely on your consent(Art. 6 (1) letter (a) GDPR) for the sending of marketing communications when so required by data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication. Milliman SAS may also use professional contact details of its clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests. For those activities, the legal basis for the processing of Personal Data is Milliman SAS’ legitimate interest(Art. 6 (1) letter (f) GDPR), unless data protection and privacy law require your prior consent. We may also collect and process limited Personal Data about you from public 2resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you may write to us at data.protection@milliman.com requesting the same. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

No automated decision-making is undertaken based on the Personal Data collected from you.

Affiliates and Authorized Third-Party Agents

All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman SAS and Milliman, Inc. or other entities controlled by or under common control with Milliman, Inc., for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events. We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that itself and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the GDPR (adequacy decision or Model Clauses of the European Commission). Those can be made available at Milliman’s premises, by contacting us at data.protection@milliman.com

Other Disclosures

Milliman may also disclose PersonalData and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited PersonalData (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact Milliman at data.protection@milliman.com, and Milliman will take steps to delete any such Personal Data.

Third-party Links

Milliman’ website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third Party Websites is no longer under our control and no longer subject to Milliman Personal Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Information to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Privacy Shield

Milliman is committed to handling Personal Data in accordance with this Privacy Policy and the EU-U.S. Privacy Shield Framework (or the Swiss-U.S. Privacy Shield Framework, as the case may be), as administered by the U.S. Department of Commerce. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and to view Milliman’s certification, please visit https://www.privacyshield.gov/list.

Milliman’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Milliman remains responsible and liable under the Privacy Shield Principles if third parties engaged by Milliman process the Personal Data in a manner inconsistent with the Principles, unless Milliman proves that it is not responsible for the event giving rise to any damage. Additionally, Milliman, Inc. has put in place data protection agreements with its affiliates located in the European Economic Area based on the EU Standard Contractual Clauses issued by the European Commission (the “EU Standard Contractual Clauses”).

As further explained in the "How to Contact Us" section below, Milliman encourages any individual to contact us should they have a Privacy Shield-related (or general privacy-related) complaint. Any right of access, rectification, erasure, restriction of the processing as well as the right to data portability of individuals domiciled in the European Economic Area or Switzerland may be exercised under the conditions set forth in the GDPR by contacting Milliman at data.protection@milliman.com. Furthermore, these individuals will have the right to lodge a complaint with a competent supervisory authority at any time.

Rights

You have a number of rights under the GDPR in relation to your Personal Data, namely:

  1. the right of access pursuant to Art. 15 GDPR: you have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Data and the manner in which, and the purposes for which we process your Personal Data, so that you can verify its accuracy and the lawfulness of the processing.
  2. the right to rectification pursuant to Art. 16 GDPR: you have the right to obtain from us the rectification of inaccurate Personal Data concerning you, and the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  3. the right to erasure pursuant to Art. 17 GDPR: the right to obtain from us the erasure of your Personal Data delay where (a) your Personal Data is no longer necessary for the purpose for which it was collected/processed; (b) you wish to withdraw your consent to processing (except where we have another legal ground for the processing that we may rely on); (c) where processing is based on our legitimate interests and there are no overriding legitimate grounds for processing; (d) where your Personal Data has been unlawfully processed;
  4. the right to restriction of processing pursuant to Art. 18 GDPR: you have the right to obtain from us the restriction of processing of your Personal Data where (a) the accuracy of such Personal Data is contested by you (for such period as will enable us to verify the accuracy of your Personal Data); (b) the processing of your Personal Data is unlawful, but you do object to the deletion of such data and request restriction of its use instead; (c) you consider that we no longer need your Personal Data for the purposes of the processing, but require such Personal Data for the establishment, exercise or defense of legal claims; (d) you have objected to the processing of your Personal Data on grounds of “legitimate interest” as per (iii) above, pending verification by us on whether our legitimate grounds override your own.
  5. the right to objection pursuant to Art. 21 GDPR: you have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data, which is based on point our legitimate interests, including profiling based on those provisions. We shall no longer process the Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. You may object to the processing of your Personal Data or direct marketing purposes at any time, without giving reason.
  6. the right to data portability pursuant to Art. 20 GDPR: you have the right to receive Personal Data concerning you, and which you have provided to us, in a structured, commonly used and machine-readable format, and to transmit such data to another data controller (please note this applies only where our processing of your Personal Data is based on your consent, and the processing is carried out by automated means).
  7. the right to appeal to a competent data protection supervisory authority (Art. 77 GDPR): you have the right to appeal to the competent data protection supervisory authority -in Spain, such authority is the “Agencia Española de Protección de Datos” (www.aepd.es).

Please note that any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights as stated above, by sending us a request to data.protection@milliman.com. We will endeavor to respond to any such request as soon as possible, and in any event within the legal deadline.

How to Contact Us

Milliman’s European Data Protection Officer can be contacted at data.protection@milliman.com.

If you live in the European Union, European Economic Area, or Switzerland and you have a complaint regarding the handling of your Personal Data in accordance with the EU-U.S. or Swiss-U.S. Privacy Shield Framework and your efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the American Arbitration Association (http://go.adr.org/privacyshield.html), which has been selected as the independent recourse mechanism to resolve complaints and disputes relating to treatment of Personal Data originating in the European Union, European Economic Area, or Switzerland and transferred to the U.S. under this Privacy Policy. Under certain conditions, you may be entitled to invoke binding arbitration through the Privacy Shield Panel when other dispute resolution procedures have been exhausted. Milliman is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

India

Data Privacy Policy - India


Last updated July 2020

Where Milliman is Acting as a Data Controller

Milliman, Inc. and its affiliates (“Milliman” or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing the Indian affiliates’ (Milliman India Private Ltd and Milliman Advisors LLP) use and protection of personal data that individuals and clients residing within India share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the (Indian) Information Technology Act, 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 (“Indian data privacy laws”), and other data protection and privacy laws, as applicable.

Milliman, Inc. and the Milliman Indian affiliates are joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and the Milliman Indian affiliates are each responsible for the compliance with applicable data protection laws.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.

Processing of Personal Data

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with clients and the administration of the website. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (including as provided under Art. 6 (1) letter (f) GDPR).

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract (name, professional address, title, email and other professional contact details) for contract administration purposes. The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (including as provided under Art. 6 (1) letter (f) GDPR). Milliman may rely on your consent for the sending of marketing communications when so required by data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication. The Milliman Indian affiliates may also use professional contact details of their clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests. For those activities, the legal basis for the processing of Personal Data is the Milliman Indian affiliates’ legitimate interest (including as provided under Art. 6 (1) letter (f) GDPR), unless data protection and privacy law require your prior consent. We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you may write to us at data.protection@milliman.com requesting the same. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

No automated decision-making is undertaken based on the Personal Data collected from you.

Affiliates and Authorized Third-Party Agents

All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman’s Indian affiliates and Milliman, Inc., or other entities controlled by or under common control with Milliman, Inc., for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events. We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that it and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the GDPR (adequacy decision or Model Clauses of the European Commission). Those can be made available at Milliman’s premises, by contacting us at data.protection@milliman.com.

Other Disclosures

Milliman may also disclose Personal Data and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited Personal Data (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact Milliman at data.protection@milliman.com, and Milliman will take steps to delete any such Personal Data.

Milliman’ website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third-Party Websites is no longer under our control and no longer subject to this Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Data to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third-Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Rights

You have the following rights under the Indian data privacy laws in relation to your Personal Data, namely:

  1. the right of access: you have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Data and the manner in which, and the purposes for which we process your Personal Data, so that you can verify its accuracy and the lawfulness of the processing.
  2. the right to rectification: you have the right to obtain from us the rectification of inaccurate Personal Data concerning you, and the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.

Please note that any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights as stated above, by sending us a request to data.protection@milliman.com. We will endeavor to respond to any such request as soon as possible, and in any event within the legal deadline.

How to Contact Us

If you have any complaint regarding the handling of your Personal Data, you may contact Milliman’s Data Protection Officer at data.protection@milliman.com.

Ireland

Data Privacy Policy - Ireland

______________________________________________________________________________________________________________

Last updated March 2020

Where Milliman is Acting as a Data Controller

Milliman, Inc. and its affiliates (“Milliman”or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing the Irish affiliate’s (Milliman Limited) use and protection of personal data that individuals and clients residing within the European Economic Area, the Isle of Man, Switzerland and the UK, share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the EU-U.S. Privacy Shield, the EU General Data Protection Regulation (GDPR), and other data protection and privacy laws, as applicable.

Milliman, Inc. and Milliman Limited are joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Milliman Limited are both responsible for the compliance with applicable data protection laws.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.

Processing of Personal Data

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with visitors and the administration of the website.The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR).

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract (name, professional address, title, email and other professional contact details) for contract administration purposes. The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR). Milliman may rely on your consent(Art. 6 (1) letter (a) GDPR) for the sending of marketing communications when so required by data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication.Milliman Limited may also use professional contact details of its clients’ employees for the purpose of sending. surveys, questionnaires or for the purpose of organizing contests. For those activities, the legal basis for the processing of Personal Data is Milliman Limited’s legitimate interest (Art. 6 (1) letter (f) GDPR), unless data protection and privacy law require your prior consent. We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you may write to us at data.protection@milliman.com requesting the same. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

No automated decision-making is undertaken based on the Personal Data collected from you.

Affiliates and Authorized Third-Party Agents

All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman Limited and Milliman, Inc. or other entities controlled by or under common control with Milliman, Inc., for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events. We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that itself and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the GDPR (adequacy decision or Model Clauses of the European Commission). Those can be made available at Milliman’s premises, by contacting us at data.protection@milliman.com

Other Disclosures

Milliman may also disclose PersonalData and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited PersonalData (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact Milliman at data.protection@milliman.com, and Milliman will take steps to delete any such Personal Data.

Third-party Links

Milliman’ website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third Party Websites is no longer under our control and no longer subject to Milliman Personal Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Information to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Privacy Shield

Milliman is committed to handling Personal Data in accordance with this Privacy Policy and the EU-U.S. Privacy Shield Framework (or the Swiss-U.S. Privacy Shield Framework, as the case may be), as administered by the U.S. Department of Commerce. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and to view Milliman’s certification, please visit https://www.privacyshield.gov/list.

Milliman’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Milliman remains responsible and liable under the Privacy Shield Principles if third parties engaged by Milliman process the Personal Data in a manner inconsistent with the Principles, unless Milliman proves that it is not responsible for the event giving rise to any damage. Additionally, Milliman, Inc. has put in place data protection agreements with its affiliates located in the European Economic Area based on the EU Standard Contractual Clauses issued by the European Commission (the “EU Standard Contractual Clauses”).

As further explained in the "How to Contact Us" section below, Milliman encourages any individual to contact us should they have a Privacy Shield-related (or general privacy-related) complaint. Any right of access, rectification, erasure, restriction of the processing as well as the right to data portability of individuals domiciled in the European Economic Area or Switzerland may be exercised under the conditions set forth in the GDPR by contacting Milliman at data.protection@milliman.com. Furthermore, these individuals will have the right to lodge a complaint with a competent supervisory authority at any time -in Switzerland, such authority is the “Eidgenössischer Datenschutz-und Öffentlichkeitsbeauftraget” (www.edoeb.admin.ch).

Rights

You have a number of rights under the Act in relation to your Personal Data, including the right to request that incorrect Personal Data be corrected (Art. 5 of the Act) and the right to request information about the processing of your Personal Data (Art. 8 of the Act).

Please note that any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights as stated above, by sending us a request to data.protection@milliman.com. We will endeavor to respond to any such request as soon as possible, and in any event within the legal deadline.

How to Contact Us

Milliman’s European Data Protection Officer can be contacted at data.protection@milliman.com.

If you live in the European Union, European Economic Area, or Switzerland and you have a complaint regarding the handling of your Personal Data in accordance with the EU-U.S. or Swiss-U.S. Privacy Shield Framework and your efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the American Arbitration Association (http://go.adr.org/privacyshield.html), which has been selected as the independent recourse mechanism to resolve complaints and disputes relating to treatment of Personal Data originating in the European Union, European Economic Area, or Switzerland and transferred to the U.S. under this Privacy Policy. Under certain conditions, you may be entitled to invoke binding arbitration through the Privacy Shield Panel when other dispute resolution procedures have been exhausted. Milliman is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Isle of Man

Data Privacy Policy - Isle of Man

______________________________________________________________________________________________________________

Last updated March 2020

Where Milliman is Acting as a Data Controller

Milliman, Inc. and its affiliates (“Milliman”or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing the Manx affiliate’s (Milliman Limited) use and protection of personal data that individuals and clients residing within the European Economic Area, the Isle of Man, Switzerland and the United Kingdom, share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the EU-U.S. Privacy Shield, the Manx Data Privacy Act 2018 and its secondary legislation including the references to the EU General Data Protection Regulation or “GDPR” (Data Protection (Application of GDPR) Order 2018)and other data protection and privacy laws, as applicable.

Milliman, Inc. and Milliman Limited are joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Milliman Limited are both responsible for the compliance with applicable data protection laws.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.

Processing of Personal Data

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with visitors and the administration of the website.The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR).

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract (name, professional address, title, email and other professional contact details)for contract administration purposes. The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR). Milliman may rely on your consent(Art. 6 (1) letter (a) GDPR) for the sending of marketing communications when so required by data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication.Milliman Limited may also use professional contact details of its clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests. For those activities, the legal basis for the processing of Personal Data is Milliman Limited’s legitimate interest (Art. 6 (1) letter (f) GDPR), unless data protection and privacy law require your prior consent. We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you may write to us at data.protection@milliman.com requesting the same. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

No automated decision-making is undertaken based on the Personal Data collected from you.

Affiliates and Authorized Third-Party Agents

All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman Limited and Milliman, Inc. or other entities controlled by or under common control with Milliman, Inc., for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events. We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that itself and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the GDPR (adequacy decision or Model Clauses of the European Commission). Those can be made available at Milliman’s premises, by contacting us at data.protection@milliman.com

Other Disclosures

Milliman may also disclose Personal Data and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited PersonalData (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact Milliman at data.protection@milliman.com, and Milliman will take steps to delete any such Personal Data.

Third-party Links

Milliman’ website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third Party Websites is no longer under our control and no longer subject to Milliman Personal Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Information to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Privacy Shield

Milliman is committed to handling Personal Data in accordance with this Privacy Policy and the EU-U.S. Privacy Shield Framework (or the Swiss-U.S. Privacy Shield Framework, as the case may be), as administered by the U.S. Department of Commerce. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and to view Milliman’s certification, please visit https://www.privacyshield.gov/list.

Milliman’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Milliman remains responsible and liable under the Privacy Shield Principles if third parties engaged by Milliman process the Personal Data in a manner inconsistent with the Principles, unless Milliman proves that it is not responsible for the event giving rise to any damage. Additionally, Milliman, Inc. has put in place data protection agreements with its affiliates located in the European Economic Area based on the EU Standard Contractual Clauses issued by the European Commission (the “EU Standard Contractual Clauses”).

As further explained in the "How to Contact Us" section below, Milliman encourages any individual to contact us should they have a Privacy Shield-related (or general privacy-related) complaint. Any right of access, rectification, erasure, restriction of the processing as well as the right to data portability of individuals domiciled in the European Economic Area or Switzerland may be exercised under the conditions set forth in the GDPR by contacting Milliman at data.protection@milliman.com. Furthermore, these individuals will have the right to lodge a complaint with a competent supervisory authority at any time.

Rights

You have a number of rights under the GDPR in relation to your Personal Data, namely:

  1. the right of access pursuant to Art. 15 GDPR: you have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Data and the manner in which, and the purposes for which we process your Personal Data, so that you can verify its accuracy and the lawfulness of the processing.
  2. the right to rectification pursuant to Art. 16 GDPR: you have the right to obtain from us the rectification of inaccurate Personal Data concerning you, and the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  3. the right to erasure pursuant to Art. 17 GDPR: the right to obtain from us the erasure of your Personal Data delay where (a) your Personal Data is no longer necessary for the purpose for which it was collected/processed; (b) you wish to withdraw your consent to processing (except where we have another legal ground for the processing that we may rely on); (c) where processing is based on our legitimate interests and there are no overriding legitimate grounds for processing; (d) where your Personal Data has been unlawfully processed;
  4. the right to restriction of processing pursuant to Art. 18 GDPR: you have the right to obtain from us the restriction of processing of your Personal Data where (a) the accuracy of such Personal Data is contested by you (for such period as will enable us to verify the accuracy of your Personal Data); (b) the processing of your Personal Data is unlawful, but you do object to the deletion of such data and request restriction of its use instead; (c) you consider that we no longer need your Personal Data for the purposes of the processing, but require such Personal Data for the establishment, exercise or defense of legal claims; (d) you have objected to the processing of your Personal Data on grounds of “legitimate interest” as per (iii) above, pending verification by us on whether our legitimate grounds override your own.
  5. the right to objection pursuant to Art. 21 GDPR: you have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data, which is based on point our legitimate interests, including profiling based on those provisions. We shall no longer process the Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. You may object to the processing of your Personal Data or direct marketing purposes at any time, without giving reason.
  6. the right to data portability pursuant to Art. 20 GDPR: you have the right to receive Personal Data concerning you, and which you have provided to us, in a structured, commonly used and machine-readable format, and to transmit such data to another data controller (please note this applies only where our processing of your Personal Data is based on your consent, and the processing is carried out by automated means).
  7. the right to appeal to a competent data protection supervisory authority (Art. 77 GDPR): you have the right to appeal to the competent data protection supervisory authority -in the Isle of Man, such authority is the “Information Commissioner” (www.inforights.im).

Please note that any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights as stated above, by sending us a request to data.protection@milliman.com. We will endeavor to respond to any such request as soon as possible, and in any event within the legal deadline.

How to Contact Us

Milliman’s European Data Protection Officer can be contacted at data.protection@milliman.com.

If you live in the European Economic Area, the Isle of Man, Switzerland or the United Kingdom and you have a complaint regarding the handling of your Personal Data in accordance with the EU-U.S. or Swiss- U.S. Privacy Shield Framework and your efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the American Arbitration Association (http://go.adr.org/privacyshield.html), which has been selected as the independent recourse mechanism to resolve complaints and disputes relating to treatment of Personal Data originating in the European Economic Area, the Isle of Man, Switzerland or the United Kingdom and transferred to the U.S. under this Privacy Policy. Under certain conditions, you may be entitled to invoke binding arbitration through the Privacy Shield Panel when other dispute resolution procedures have been exhausted. Milliman is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Italy

Data Privacy Policy - Italy

______________________________________________________________________________________________________________

Last updated March 2020

Where Milliman is Acting as a Data Controller

Milliman, Inc. and its affiliates (“Milliman”or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing the Romanian affiliate’s (Milliman SRL) use and protection of personal data that individuals and clients residing within the European Economic Area, the Isle of Man, Switzerland and the UK, share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the EU-U.S. Privacy Shield, the EU General Data Protection Regulation (GDPR), and other data protection and privacy laws, as applicable.

Milliman, Inc. and Milliman S.R.L. are joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Milliman S.R.L. are both responsible for the compliance with applicable data protection laws.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.

Processing of Personal Data

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with visitors and the administration of the website.The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR).

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract (name, professional address, title, email and other professional contact details) for contract administration purposes.The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR). Milliman may rely on your consent(Art. 6 (1) letter (a) GDPR) for the sending of marketing communications when so required by data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication. Milliman S.R.L. may also use professional contact details of its clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests. For those activities, the legal basis for the processing of Personal Data is Milliman S.R.L.’s legitimate interest (Art. 6 (1) letter (f) GDPR), unless data protection and privacy law require your prior consent. We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you may write to us at data.protection@milliman.com requesting the same. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

No automated decision-making is undertaken based on the Personal Data collected from you.

Affiliates and Authorized Third-Party Agents

All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman SRLand Milliman, Inc. or other entities controlled by or under common control with Milliman, Inc., for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events. We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that itself and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the GDPR (adequacy decision or Model Clauses of the European Commission). Those can be made available at Milliman’s premises, by contacting us at data.protection@milliman.com

Other Disclosures

Milliman may also disclose PersonalData and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited PersonalData (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact Milliman at data.protection@milliman.com, and Milliman will take steps to delete any such Personal Data.

Third-party Links

Milliman’ website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third Party Websites is no longer under our control and no longer subject to Milliman Personal Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Information to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Privacy Shield

Milliman is committed to handling Personal Data in accordance with this Privacy Policy and the EU-U.S. Privacy Shield Framework (or the Swiss-U.S. Privacy Shield Framework, as the case may be), as administered by the U.S. Department of Commerce. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and to view Milliman’s certification, please visit https://www.privacyshield.gov/list.

Milliman’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Milliman remains responsible and liable under the Privacy Shield Principles if third parties engaged by Milliman process the Personal Data in a manner inconsistent with the Principles, unless Milliman proves that it is not responsible for the event giving rise to any damage. Additionally, Milliman, Inc. has put in place data protection agreements with its affiliates located in the European Economic Area based on the EU Standard Contractual Clauses issued by the European Commission (the “EU Standard Contractual Clauses”).

As further explained in the "How to Contact Us" section below, Milliman encourages any individual to contact us should they have a Privacy Shield-related (or general privacy-related) complaint. Any right of access, rectification, erasure, restriction of the processing as well as the right to data portability of individuals domiciled in the European Economic Area or Switzerland may be exercised under the conditions set forth in the GDPR by contacting Milliman at data.protection@milliman.com. Furthermore, these individuals will have the right to lodge a complaint with a competent supervisory authority at any time.

Rights

You have a number of rights under the GDPR in relation to your Personal Data, namely:

  1. the right of access pursuant to Art. 15 GDPR: you have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Data and the manner in which, and the purposes for which we process your Personal Data, so that you can verify its accuracy and the lawfulness of the processing.
  2. the right to rectification pursuant to Art. 16 GDPR: you have the right to obtain from us the rectification of inaccurate Personal Data concerning you, and the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  3. the right to erasure pursuant to Art. 17 GDPR: the right to obtain from us the erasure of your Personal Data delay where (a) your Personal Data is no longer necessary for the purpose for which it was collected/processed; (b) you wish to withdraw your consent to processing (except where we have another legal ground for the processing that we may rely on); (c) where processing is based on our legitimate interests and there are no overriding legitimate grounds for processing; (d) where your Personal Data has been unlawfully processed;
  4. the right to restriction of processing pursuant to Art. 18 GDPR: you have the right to obtain from us the restriction of processing of your Personal Data where (a) the accuracy of such Personal Data is contested by you (for such period as will enable us to verify the accuracy of your Personal Data); (b) the processing of your Personal Data is unlawful, but you do object to the deletion of such data and request restriction of its use instead; (c) you consider that we no longer need your Personal Data for the purposes of the processing, but require such Personal Data for the establishment, exercise or defense of legal claims; (d) you have objected to the processing of your Personal Data on grounds of “legitimate interest” as per (iii) above, pending verification by us on whether our legitimate grounds override your own.
  5. the right to objection pursuant to Art. 21 GDPR: you have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data, which is based on point our legitimate interests, including profiling based on those provisions. We shall no longer process the Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. You may object to the processing of your Personal Data or direct marketing purposes at any time, without giving reason.
  6. the right to data portability pursuant to Art. 20 GDPR: you have the right to receive Personal Data concerning you, and which you have provided to us, in a structured, commonly used and machine-readable format, and to transmit such data to another data controller (please note this applies only where our processing of your Personal Data is based on your consent, and the processing is carried out by automated means).
  7. the right to appeal to a competent data protection supervisory authority (Art. 77 GDPR): you have the right to appeal to the competent data protection supervisory authority -in Spain, such authority is the “Agencia Española de Protección de Datos” (www.aepd.es).

Please note that any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights as stated above, by sending us a request to data.protection@milliman.com. We will endeavor to respond to any such request as soon as possible, and in any event within the legal deadline.

How to Contact Us

Milliman’s European Data Protection Officer can be contacted at data.protection@milliman.com.

If you live in the European Union, European Economic Area, or Switzerland and you have a complaint regarding the handling of your Personal Data in accordance with the EU-U.S. or Swiss-U.S. Privacy Shield Framework and your efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the American Arbitration Association (http://go.adr.org/privacyshield.html), which has been selected as the independent recourse mechanism to resolve complaints and disputes relating to treatment of Personal Data originating in the European Union, European Economic Area, or Switzerland and transferred to the U.S. under this Privacy Policy. Under certain conditions, you may be entitled to invoke binding arbitration through the Privacy Shield Panel when other dispute resolution procedures have been exhausted. Milliman is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Japan

Data Privacy Policy - Japan


Last updated June 2020

Where Milliman is Acting as a Data Controller

Milliman, Inc. and its affiliates (“Milliman” or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing Milliman’s and the Japan affiliate’s (Milliman Japan) use and protection of personal data that individuals and clients residing within Japan share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the EU-U.S. Privacy Shield, the EU General Data Protection Regulation (GDPR), and other data protection and privacy laws, as applicable.

Milliman, Inc. and Milliman Japan are joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Milliman Japan are both responsible for the compliance with applicable data protection laws.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.

Processing of Personal Data

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with clients and the administration of the website. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR).

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract (name, professional address, title, email and other professional contact details) for contract administration purposes. The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR). Milliman may rely on your consent (Art. 6 (1) letter (a) GDPR) for the sending of marketing communications when so required by data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication. Milliman Japan may also use professional contact details of its clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests. For those activities, the legal basis for the processing of Personal Data is Milliman Japan’s legitimate interest (Art. 6 (1) letter (f) GDPR), unless data protection and privacy law require your prior consent. We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you may write to us at data.protection@milliman.com requesting the same. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

No automated decision-making is undertaken based on the Personal Data collected from you.

Affiliates and Authorized Third-Party Agents

All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman Japan and Milliman, Inc. or other entities controlled by or under common control with Milliman, Inc., for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events. We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that itself and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the GDPR (adequacy decision or Model Clauses of the European Commission). Those can be made available at Milliman’s premises, by contacting us at data.protection@milliman.com.

Other Disclosures

Milliman may also disclose Personal Data and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited Personal Data (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact Milliman at data.protection@milliman.com, and Milliman will take steps to delete any such Personal Data.

Third-party Links

Milliman’ website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third-Party Websites is no longer under our control and no longer subject to Milliman Personal Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Information to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third-Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Privacy Shield

Milliman is committed to handling Personal Data in accordance with this Privacy Policy and the EU-U.S. Privacy Shield Framework (or the Swiss-U.S. Privacy Shield Framework, as the case may be), as administered by the U.S. Department of Commerce. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and to view Milliman’s certification, please visit: https://www.privacyshield.gov/list. Milliman’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Milliman remains responsible and liable under the Privacy Shield Principles if third parties engaged by Milliman process the Personal Data in a manner inconsistent with the Principles, unless Milliman proves that it is not responsible for the event giving rise to any damage.

Rights

You have a number of rights under the GDPR in relation to your Personal Data, namely:

  1. the right of access pursuant to Art. 15 GDPR: you have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Data and the manner in which, and the purposes for which we process your Personal Data, so that you can verify its accuracy and the lawfulness of the processing.
  2. the right to rectification pursuant to Art. 16 GDPR: you have the right to obtain from us the rectification of inaccurate Personal Data concerning you, and the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  3. the right to erasure pursuant to Art. 17 GDPR: the right to obtain from us the erasure of your Personal Data delay where (a) your Personal Data is no longer necessary for the purpose for which it was collected/processed; (b) you wish to withdraw your consent to processing (except where we have another legal ground for the processing that we may rely on); (c) where processing is based on our legitimate interests and there are no overriding legitimate grounds for processing; (d) where your Personal Data has been unlawfully processed;
  4. the right to restriction of processing pursuant to Art. 18 GDPR: you have the right to obtain from us the restriction of processing of your Personal Data where (a) the accuracy of such Personal Data is contested by you (for such period as will enable us to verify the accuracy of your Personal Data); (b) the processing of your Personal Data is unlawful, but you do object to the deletion of such data and request restriction of its use instead; (c) you consider that we no longer need your Personal Data for the purposes of the processing, but require such Personal Data for the establishment, exercise or defense of legal claims; (d) you have objected to the processing of your Personal Data on grounds of “legitimate interest” as per (iii) above, pending verification by us on whether our legitimate grounds override your own.
  5. the right to objection pursuant to Art. 21 GDPR: you have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data, which is based on point our legitimate interests, including profiling based on those provisions. We shall no longer process the Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. You may object to the processing of your Personal Data or direct marketing purposes at any time, without giving reason.
  6. the right to data portability pursuant to Art. 20 GDPR: you have the right to receive Personal Data concerning you, and which you have provided to us, in a structured, commonly used and machine-readable format, and to transmit such data to another data controller (please note this applies only where our processing of your Personal Data is based on your consent, and the processing is carried out by automated means).
  7. the right to appeal to a competent data protection supervisory authority (Art. 77 GDPR): you have the right to appeal to the competent data protection supervisory authority Please note that any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights as stated above, by sending us a request to data.protection@milliman.com. We will endeavor to respond to any such request as soon as possible, and in any event within the legal deadline.

How to Contact Us

Milliman’s Data Protection Officer can be contacted at data.protection@milliman.com.

Korea

Data Privacy Policy - Korea


Last updated June 2020

Where Milliman is Acting as a Data Controller

Milliman, Inc. and its affiliates (“Milliman” or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing the Korean affiliate’s (Milliman Korea) use and protection of personal data that individuals and clients residing within South Korea share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the Korean Personal Information Protection Act (KPIPA), and other data protection and privacy laws, as applicable.

Milliman, Inc. and Milliman Korea are joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Milliman Korea are both responsible for the compliance with applicable data protection laws.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers please review our Cookie Policy which can be found here.

Processing of Personal Data

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with clients and the administration of the website. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 15(1)(vi) of KPIPA).

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract (name, professional address, title, email and other professional contact details) for contract administration purposes. The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 15(1)(vi) of KPIPA). Milliman may rely on your consent (Art. 15(1)(i) of KPIPA) for the sending of marketing communications when so required by data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication. Milliman Korea may also use professional contact details of its clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests. For those activities, the legal basis for the processing of Personal Data is Milliman Korea’s legitimate interest (Art. 15(1)(vi) of KPIPA), unless data protection and privacy laws require your prior consent. We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you may write to us at data.protection@milliman.com requesting the same. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

No automated decision-making, including profiling, is undertaken based on the Personal Data collected from you.

Affiliates and Authorized Third-Party Agents

All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman Korea and Milliman, Inc. or other entities controlled by or under common control with Milliman, Inc., for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events. We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that it and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the KPIPA. Those can be made available at Milliman’s premises, by contacting us at data.protection@milliman.com.

Other Disclosures

Milliman may also disclose Personal Data and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited Personal Data (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact Milliman at data.protection@milliman.com, and Milliman will take steps to delete any such Personal Data.

Third-party Links

Milliman’s website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third-Party Websites is no longer under our control and no longer subject to this Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Information to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third-Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Rights

You have a number of rights under the KPIPA and the Korean Credit Information Use and Protection Act (KCIUPA) in relation to your Personal Data and credit information, namely:

  1. the right of access pursuant to Art. 35 of KPIPA: you have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Data and the manner in which, and the purposes for which we process your Personal Data, so that you can verify its accuracy and the lawfulness of the processing.
  2. the right to rectification and erasure pursuant to Art. 36 of KPIPA: you have the right to request rectification or erasure of Personal Data concerning you.
  3. the right to suspension of processing pursuant to Art. 37 of KPIPA: you have the right to request suspension of processing your Personal Data. Nonetheless, such request may be denied if (a) a special provision exists in law or processing of your Personal Data is required to comply with other legal obligations; (b) there is a concern that such request might cause bodily harm or damage the life of a third party or if it could violate a third party’s property rights or other benefits; (c) a public institution cannot perform its task as prescribed in other law without processing your Personal Data; or (d) it is impossible to perform the agreed upon task without processing your Personal Data, assuming that you have not explicitly expressed your intent to terminate the contract.
  4. the right to withdrawal of consent pursuant to Art. 39-7 of KPIPA: you have the right to withdraw your consent to collect, use, and provide Personal Data at any time. Said provision becomes effective as of August 5, 2020.
  5. the right to transfer credit information pursuant to Art. 33-2 of KCIUPA (effective August 5, 2020): if Personal Data includes credit information, the owner of credit information has the right to request transfer of its personal credit information to (a) the owner of credit information; (b) personal credit information management company; (c) credit information provider/user prescribed by a Presidential Decree; (d) personal credit rating company; (e) other entity prescribed by a Presidential Decree.

    If Personal Data includes credit information, the scope of transferable personal credit information is determined by a Presidential Decree considering: (a) information directly collected from the owner of credit information by the credit information provider/user; (b) information directly provided to the credit information provider/user by the owner of credit information; and (c) information created in transactions between the credit information provider/user and the owner of credit information.

    If Personal Data includes credit information, transferable personal credit information shall not be information newly generated or processed by credit information provider/user.

    Upon receipt of transfer request of personal credit information, the credit information provider/user shall, without delay, transfer personal credit information through a secured and credible data processing unit, despite other applicable laws such as Act on Real Name Financial Transactions and Confidentiality, Framework Act on National Taxes, Framework Act on Local Taxes, KPIPA, etc.

    The credit information provider/user that transferred personal credit information may not need to notify the owner of credit information.

    The credit information provider/user may deny or suspend credit information owner’s transfer request for reasons prescribed by a Presidential Decree, such as when the identity of the credit information owner cannot be verified.
  6. the right to appeal to a competent data protection supervisory authority (Art. 62 of KPIPA): anyone who suffers infringement on the rights or interests involving his/her Personal Data in the course of processing Personal Data by a controller may report such infringement to the Minister of the Interior and Safety.

    The Minister of the Interior and Safety may designate a specialized institution to efficiently receive and handle the claim reports, as prescribed by Presidential Decree. In such cases, such specialized institution shall establish and operate a personal information infringement call center, namely, Privacy Call Center.

Please note that any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights as stated above, by sending us a request to data.protection@milliman.com. We will endeavor to respond to any such request as soon as possible, and in any event within the legal deadline.

How to Contact Us

If you have any questions or feedback relating to your Personal Data or about this Privacy Policy, please contact Milliman’s Data Protection Officer at data.protection@milliman.com.

Poland

Data Privacy Policy - Poland

______________________________________________________________________________________________________________

Last updated March 2020

Where Milliman is Acting as a Data Controller

Milliman, Inc. and its affiliates (“Milliman”or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing the Polish affiliate’s (Milliman Sp. Z.o.o.) use and protection of personal data that individuals and clients residing within the European Economic Area, the Isle of Man, Switzerland and the UK, share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the EU-U.S. Privacy Shield, the EU General Data Protection Regulation (GDPR), and other data protection and privacy laws, as applicable.

Milliman, Inc. and Milliman Sp. Z.o.o. are joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Milliman Sp. Z.o.o. are both responsible for the compliance with applicable data protection laws.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.

Processing of Personal Data

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with visitors and the administration of the website.The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR).

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract (name, professional address, title, email and other professional contact details) for contract administration purposes.The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR). Milliman may rely on your consent(Art. 6 (1) letter (a) GDPR) for the sending of marketing communications when so required by data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication. Milliman Sp. Z.o.o. may also use professional contact details of its clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests. For those activities, the legal basis for the processing of Personal Data is Milliman Sp. Z.o.o.’s legitimate interest (Art. 6 (1) letter (f) GDPR), unless data protection and privacy law require your prior consent. We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you may write to us at data.protection@milliman.com requesting the same. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

No automated decision-making is undertaken based on the Personal Data collected from you.

Affiliates and Authorized Third-Party Agents

All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman Sp. Z.o.o.and Milliman, Inc. or other entities controlled by or under common control with Milliman, Inc., for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events. We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that itself and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the GDPR (adequacy decision or Model Clauses of the European Commission). Those can be made available at Milliman’s premises, by contacting us at data.protection@milliman.com

Other Disclosures

Milliman may also disclose PersonalData and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited PersonalData (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact Milliman at data.protection@milliman.com, and Milliman will take steps to delete any such Personal Data.

Third-party Links

Milliman’ website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third Party Websites is no longer under our control and no longer subject to Milliman Personal Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Information to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Privacy Shield

Milliman is committed to handling Personal Data in accordance with this Privacy Policy and the EU-U.S. Privacy Shield Framework (or the Swiss-U.S. Privacy Shield Framework, as the case may be), as administered by the U.S. Department of Commerce. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and to view Milliman’s certification, please visit https://www.privacyshield.gov/list.

Milliman’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Milliman remains responsible and liable under the Privacy Shield Principles if third parties engaged by Milliman process the Personal Data in a manner inconsistent with the Principles, unless Milliman proves that it is not responsible for the event giving rise to any damage. Additionally, Milliman, Inc. has put in place data protection agreements with its affiliates located in the European Economic Area based on the EU Standard Contractual Clauses issued by the European Commission (the “EU Standard Contractual Clauses”).

As further explained in the "How to Contact Us" section below, Milliman encourages any individual to contact us should they have a Privacy Shield-related (or general privacy-related) complaint. Any right of access, rectification, erasure, restriction of the processing as well as the right to data portability of individuals domiciled in the European Economic Area or Switzerland may be exercised under the conditions set forth in the GDPR by contacting Milliman at data.protection@milliman.com. Furthermore, these individuals will have the right to lodge a complaint with a competent supervisory authority at any time.

Rights

You have a number of rights under the GDPR in relation to your Personal Data, namely:

  1. the right of access pursuant to Art. 15 GDPR: you have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Data and the manner in which, and the purposes for which we process your Personal Data, so that you can verify its accuracy and the lawfulness of the processing.
  2. the right to rectification pursuant to Art. 16 GDPR: you have the right to obtain from us the rectification of inaccurate Personal Data concerning you, and the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  3. the right to erasure pursuant to Art. 17 GDPR: the right to obtain from us the erasure of your Personal Data delay where (a) your Personal Data is no longer necessary for the purpose for which it was collected/processed; (b) you wish to withdraw your consent to processing (except where we have another legal ground for the processing that we may rely on); (c) where processing is based on our legitimate interests and there are no overriding legitimate grounds for processing; (d) where your Personal Data has been unlawfully processed;
  4. the right to restriction of processing pursuant to Art. 18 GDPR: you have the right to obtain from us the restriction of processing of your Personal Data where (a) the accuracy of such Personal Data is contested by you (for such period as will enable us to verify the accuracy of your Personal Data); (b) the processing of your Personal Data is unlawful, but you do object to the deletion of such data and request restriction of its use instead; (c) you consider that we no longer need your Personal Data for the purposes of the processing, but require such Personal Data for the establishment, exercise or defense of legal claims; (d) you have objected to the processing of your Personal Data on grounds of “legitimate interest” as per (iii) above, pending verification by us on whether our legitimate grounds override your own.
  5. the right to objection pursuant to Art. 21 GDPR: you have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data, which is based on point our legitimate interests, including profiling based on those provisions. We shall no longer process the Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. You may object to the processing of your Personal Data or direct marketing purposes at any time, without giving reason.
  6. the right to data portability pursuant to Art. 20 GDPR: you have the right to receive Personal Data concerning you, and which you have provided to us, in a structured, commonly used and machine-readable format, and to transmit such data to another data controller (please note this applies only where our processing of your Personal Data is based on your consent, and the processing is carried out by automated means).
  7. the right to appeal to a competent data protection supervisory authority (Art. 77 GDPR): you have the right to appeal to the competent data protection supervisory authority -in Spain, such authority is the “Agencia Española de Protección de Datos” (www.aepd.es).

Please note that any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights as stated above, by sending us a request to data.protection@milliman.com. We will endeavor to respond to any such request as soon as possible, and in any event within the legal deadline.

How to Contact Us

Milliman’s European Data Protection Officer can be contacted at data.protection@milliman.com.

If you live in the European Union, European Economic Area, or Switzerland and you have a complaint regarding the handling of your Personal Data in accordance with the EU-U.S. or Swiss-U.S. Privacy Shield Framework and your efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the American Arbitration Association (http://go.adr.org/privacyshield.html), which has been selected as the independent recourse mechanism to resolve complaints and disputes relating to treatment of Personal Data originating in the European Union, European Economic Area, or Switzerland and transferred to the U.S. under this Privacy Policy. Under certain conditions, you may be entitled to invoke binding arbitration through the Privacy Shield Panel when other dispute resolution procedures have been exhausted. Milliman is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Romania

Data Privacy Policy - Romania

______________________________________________________________________________________________________________

Last updated March 2020

Where Milliman is Acting as a Data Controller

Milliman, Inc. and its affiliates (“Milliman”or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing the Romanian affiliate’s (Milliman SRL) use and protection of personal data that individuals and clients residing within the European Economic Area, the Isle of Man, Switzerland and the UK, share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the EU-U.S. Privacy Shield, the EU General Data Protection Regulation (GDPR), and other data protection and privacy laws, as applicable.

Milliman, Inc. and Milliman SRL are joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Milliman SRL are both responsible for the compliance with applicable data protection laws.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.

Processing of Personal Data

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with visitors and the administration of the website.The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR).

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract (name, professional address, title, email and other professional contact details) for contract administration purposes.The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR). Milliman may rely on your consent(Art. 6 (1) letter (a) GDPR) for the sending of marketing communications when so required by data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication. Milliman SRL may also use professional contact details of its clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests. For those activities, the legal basis for the processing of Personal Data is Milliman SRL’s legitimate interest (Art. 6 (1) letter (f) GDPR), unless data protection and privacy law require your prior consent. We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you may write to us at data.protection@milliman.com requesting the same. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

No automated decision-making is undertaken based on the Personal Data collected from you.

Affiliates and Authorized Third-Party Agents

ll Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman SRLand Milliman, Inc. or other entities controlled by or under common control with Milliman, Inc., for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events. We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that itself and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the GDPR (adequacy decision or Model Clauses of the European Commission). Those can be made available at Milliman’s premises, by contacting us at data.protection@milliman.com

Other Disclosures

Milliman may also disclose PersonalData and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited PersonalData (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact Milliman at data.protection@milliman.com, and Milliman will take steps to delete any such Personal Data.

Third-party Links

Milliman’ website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third Party Websites is no longer under our control and no longer subject to Milliman Personal Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Information to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Privacy Shield

Milliman is committed to handling Personal Data in accordance with this Privacy Policy and the EU-U.S. Privacy Shield Framework (or the Swiss-U.S. Privacy Shield Framework, as the case may be), as administered by the U.S. Department of Commerce. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and to view Milliman’s certification, please visit https://www.privacyshield.gov/list.

Milliman’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Milliman remains responsible and liable under the Privacy Shield Principles if third parties engaged by Milliman process the Personal Data in a manner inconsistent with the Principles, unless Milliman proves that it is not responsible for the event giving rise to any damage. Additionally, Milliman, Inc. has put in place data protection agreements with its affiliates located in the European Economic Area based on the EU Standard Contractual Clauses issued by the European Commission (the “EU Standard Contractual Clauses”).

As further explained in the "How to Contact Us" section below, Milliman encourages any individual to contact us should they have a Privacy Shield-related (or general privacy-related) complaint. Any right of access, rectification, erasure, restriction of the processing as well as the right to data portability of individuals domiciled in the European Economic Area or Switzerland may be exercised under the conditions set forth in the GDPR by contacting Milliman at data.protection@milliman.com. Furthermore, these individuals will have the right to lodge a complaint with a competent supervisory authority at any time.

Rights

You have a number of rights under the GDPR in relation to your Personal Data, namely:

  1. the right of access pursuant to Art. 15 GDPR: you have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Data and the manner in which, and the purposes for which we process your Personal Data, so that you can verify its accuracy and the lawfulness of the processing.
  2. the right to rectification pursuant to Art. 16 GDPR: you have the right to obtain from us the rectification of inaccurate Personal Data concerning you, and the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  3. the right to erasure pursuant to Art. 17 GDPR: the right to obtain from us the erasure of your Personal Data delay where (a) your Personal Data is no longer necessary for the purpose for which it was collected/processed; (b) you wish to withdraw your consent to processing (except where we have another legal ground for the processing that we may rely on); (c) where processing is based on our legitimate interests and there are no overriding legitimate grounds for processing; (d) where your Personal Data has been unlawfully processed;
  4. the right to restriction of processing pursuant to Art. 18 GDPR: you have the right to obtain from us the restriction of processing of your Personal Data where (a) the accuracy of such Personal Data is contested by you (for such period as will enable us to verify the accuracy of your Personal Data); (b) the processing of your Personal Data is unlawful, but you do object to the deletion of such data and request restriction of its use instead; (c) you consider that we no longer need your Personal Data for the purposes of the processing, but require such Personal Data for the establishment, exercise or defense of legal claims; (d) you have objected to the processing of your Personal Data on grounds of “legitimate interest” as per (iii) above, pending verification by us on whether our legitimate grounds override your own.
  5. the right to objection pursuant to Art. 21 GDPR: you have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data, which is based on point our legitimate interests, including profiling based on those provisions. We shall no longer process the Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. You may object to the processing of your Personal Data or direct marketing purposes at any time, without giving reason.
  6. the right to data portability pursuant to Art. 20 GDPR: you have the right to receive Personal Data concerning you, and which you have provided to us, in a structured, commonly used and machine-readable format, and to transmit such data to another data controller (please note this applies only where our processing of your Personal Data is based on your consent, and the processing is carried out by automated means).
  7. the right to appeal to a competent data protection supervisory authority (Art. 77 GDPR): you have the right to appeal to the competent data protection supervisory authority -in Spain, such authority is the “Agencia Española de Protección de Datos” (www.aepd.es).

Please note that any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights as stated above, by sending us a request to data.protection@milliman.com. We will endeavor to respond to any such request as soon as possible, and in any event within the legal deadline.

How to Contact Us

Milliman’s European Data Protection Officer can be contacted at data.protection@milliman.com.

If you live in the European Union, European Economic Area, or Switzerland and you have a complaint regarding the handling of your Personal Data in accordance with the EU-U.S. or Swiss-U.S. Privacy Shield Framework and your efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the American Arbitration Association (http://go.adr.org/privacyshield.html), which has been selected as the independent recourse mechanism to resolve complaints and disputes relating to treatment of Personal Data originating in the European Union, European Economic Area, or Switzerland and transferred to the U.S. under this Privacy Policy. Under certain conditions, you may be entitled to invoke binding arbitration through the Privacy Shield Panel when other dispute resolution procedures have been exhausted. Milliman is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Singapore

Data Privacy Policy - Singapore


Last updated June 2020

Milliman, Inc. and its affiliates (“Milliman” or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing Milliman's and the Singapore affiliate’s (Milliman Private Limited) collection, use, disclosure, processing and protection of Personal Data (as defined below) that individuals and clients residing within Singapore share with us, hereafter “you.” Milliman is committed to handling Personal Data in accordance with this Privacy Policy, Singapore's Personal Data Protection Act (Act 26 of 2012) (“PDPA”), and other data protection and privacy laws, as applicable.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.

Processing of Personal Data

In this Privacy Policy, "Personal Data" means any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which the organisation has or is likely to have access.

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. By providing any Personal Data in the course of interacting with us, including via this website, in connection with Milliman’s marketing activities or contract administration, you agree and consent to the collection, use, disclosure and processing of your Personal Data for the purposes and in the manner set out in this Privacy Policy. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may, to the extent permitted by law or with your consent, collect, use, disclose, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with clients and the administration of the website;.

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract (name, professional address, title, email and other professional contact details) for contract administration purposes. The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest.

Furthermore, where permitted by applicable data protection and privacy laws, Milliman may also collect, use, disclose, store or otherwise process (i) your Personal Data for the sending of marketing communications; and (ii) professional contact details of its clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests. We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, texts and/or SMS, or if you wish to unsubscribe from direct marketing communications from us, you may write to us at data.protection@milliman.com requesting the same. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

You should also ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.

Affiliates and Authorized Third-Party Agents

All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman Private Limited and Milliman, Inc. or other entities controlled by or under common control with Milliman, Inc., for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events. We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that itself and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the PDPA and/or any other applicable data protection and privacy laws. Those can be made available at Milliman’s premises, by contacting us at data.protection@milliman.com.

Other Disclosures

Milliman may also disclose Personal Data and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited Personal Data (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact Milliman at data.protection@milliman.com, and Milliman will take steps to delete any such Personal Data.

Third-party Links

Milliman’ website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third-Party Websites is no longer under our control and no longer subject to this Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Information to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third-Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Rights

Depending on the applicable law, you have a number of rights under the PDPA or such other applicable data protection and privacy laws in relation to your Personal Data, including:

  1. the right to make an access or a correction request: If you wish to make (a) a request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
  2. the right to withdraw your consent: The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

    If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Milliman may not be in a position to continue to provide its products and services to you, or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Milliman, and your being in breach of your contractual obligations or undertakings. Milliman's legal rights and remedies in such event are expressly reserved.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclosure without consent is permitted or required under applicable laws, and any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights, by sending us a request to data.protection@milliman.com. We will endeavor to respond to any such request as soon as possible, and in any event within the legal deadline.

How to Contact Us

If you:

  1. have any questions or feedback relating to your Personal Data or about this Privacy Policy;
  2. would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy; or
  3. would like to obtain access and make correction to your Personal Data records,

please contact Milliman’s Data Protection Officer at data.protection@milliman.com.

Please note that if your Personal Data has been provided to us by a third party (e.g. your employer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to Milliman on your behalf.

This Privacy Policy shall be governed in all respects by the laws of Singapore.

Spain

Data Privacy Policy - Spain

______________________________________________________________________________________________________________

Last updated March 2020

Where Milliman is Acting as a Data Controller

Milliman, Inc. and its affiliates (“Milliman”or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing the Spanish affiliate’s (Milliman Consultants and Actuaries S.L.) use and protection of personal data that individuals and clients residing within the European Economic Area, the Isle of Man, Switzerland and the UK, share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the EU-U.S. Privacy Shield, the EU General Data Protection Regulation (GDPR), and other data protection and privacy laws, as applicable.

Milliman, Inc. and Milliman Consultants and Actuaries S.L. are joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Milliman Consultants and Actuaries S.L. are both responsible for the compliance with applicable data protection laws.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.

Processing of Personal Data

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with visitors and the administration of the website.The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR).

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract (name, professional address, title, email and other professional contact details) for contract administration purposes. The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR). Milliman may rely on your consent(Art. 6 (1) letter (a) GDPR) for the sending of marketing communications when so required by data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication. Milliman Consultants and Actuaries S.L. may also use professional contact details of its clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests. For those activities, the legal basis for the processing of Personal Data is Milliman Consultants and Actuaries S.L.’s legitimate interest (Art. 6 (1) letter (f) GDPR), unless data protection and privacy law require your prior consent. We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you may write to us at data.protection@milliman.com requesting the same. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

No automated decision-making is undertaken based on the Personal Data collected from you.

Affiliates and Authorized Third-Party Agents

All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman Consultants and Actuaries S.L. and Milliman, Inc. or other entities controlled by or under common control with Milliman, Inc., for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events. We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that itself and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the GDPR (adequacy decision or Model Clauses of the European Commission). Those can be made available at Milliman’s premises, by contacting us at data.protection@milliman.com

Other Disclosures

Milliman may also disclose Personal Data and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited PersonalData (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact Milliman at data.protection@milliman.com, and Milliman will take steps to delete any such Personal Data.

Third-party Links

Milliman’ website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third Party Websites is no longer under our control and no longer subject to Milliman Personal Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Information to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Privacy Shield

Milliman is committed to handling Personal Data in accordance with this Privacy Policy and the EU-U.S. Privacy Shield Framework (or the Swiss-U.S. Privacy Shield Framework, as the case may be), as administered by the U.S. Department of Commerce. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and to view Milliman’s certification, please visit https://www.privacyshield.gov/list.

Milliman’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Milliman remains responsible and liable under the Privacy Shield Principles if third parties engaged by Milliman process the Personal Data in a manner inconsistent with the Principles, unless Milliman proves that it is not responsible for the event giving rise to any damage. Additionally, Milliman, Inc. has put in place data protection agreements with its affiliates located in the European Economic Area based on the EU Standard Contractual Clauses issued by the European Commission (the “EU Standard Contractual Clauses”).

As further explained in the "How to Contact Us" section below, Milliman encourages any individual to contact us should they have a Privacy Shield-related (or general privacy-related) complaint. Any right of access, rectification, erasure, restriction of the processing as well as the right to data portability of individuals domiciled in the European Economic Area or Switzerland may be exercised under the conditions set forth in the GDPR by contacting Milliman at data.protection@milliman.com. Furthermore, these individuals will have the right to lodge a complaint with a competent supervisory authority at any time.

Rights

You have a number of rights under the GDPR in relation to your Personal Data, namely:

  1. the right of access pursuant to Art. 15 GDPR: you have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Data and the manner in which, and the purposes for which we process your Personal Data, so that you can verify its accuracy and the lawfulness of the processing.
  2. the right to rectification pursuant to Art. 16 GDPR: you have the right to obtain from us the rectification of inaccurate Personal Data concerning you, and the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  3. the right to erasure pursuant to Art. 17 GDPR: the right to obtain from us the erasure of your Personal Data delay where (a) your Personal Data is no longer necessary for the purpose for which it was collected/processed; (b) you wish to withdraw your consent to processing (except where we have another legal ground for the processing that we may rely on); (c) where processing is based on our legitimate interests and there are no overriding legitimate grounds for processing; (d) where your Personal Data has been unlawfully processed;
  4. the right to restriction of processing pursuant to Art. 18 GDPR: you have the right to obtain from us the restriction of processing of your Personal Data where (a) the accuracy of such Personal Data is contested by you (for such period as will enable us to verify the accuracy of your Personal Data); (b) the processing of your Personal Data is unlawful, but you do object to the deletion of such data and request restriction of its use instead; (c) you consider that we no longer need your Personal Data for the purposes of the processing, but require such Personal Data for the establishment, exercise or defense of legal claims; (d) you have objected to the processing of your Personal Data on grounds of “legitimate interest” as per (iii) above, pending verification by us on whether our legitimate grounds override your own.
  5. the right to objection pursuant to Art. 21 GDPR: you have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data, which is based on point our legitimate interests, including profiling based on those provisions. We shall no longer process the Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. You may object to the processing of your Personal Data or direct marketing purposes at any time, without giving reason.
  6. the right to data portability pursuant to Art. 20 GDPR: you have the right to receive Personal Data concerning you, and which you have provided to us, in a structured, commonly used and machine-readable format, and to transmit such data to another data controller (please note this applies only where our processing of your Personal Data is based on your consent, and the processing is carried out by automated means).
  7. the right to appeal to a competent data protection supervisory authority (Art. 77 GDPR): you have the right to appeal to the competent data protection supervisory authority -in Spain, such authority is the “Agencia Española de Protección de Datos” (www.aepd.es).

Please note that any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights as stated above, by sending us a request to data.protection@milliman.com. We will endeavor to respond to any such request as soon as possible, and in any event within the legal deadline.

How to Contact Us

Milliman’s European Data Protection Officer can be contacted at data.protection@milliman.com.

If you live in the European Union, European Economic Area, or Switzerland and you have a complaint regarding the handling of your Personal Data in accordance with the EU-U.S. or Swiss-U.S. Privacy Shield Framework and your efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the American Arbitration Association (http://go.adr.org/privacyshield.html), which has been selected as the independent recourse mechanism to resolve complaints and disputes relating to treatment of Personal Data originating in the European Union, European Economic Area, or Switzerland and transferred to the U.S. under this Privacy Policy. Under certain conditions, you may be entitled to invoke binding arbitration through the Privacy Shield Panel when other dispute resolution procedures have been exhausted. Milliman is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Switzerland

Data Privacy Policy - Switzerland

______________________________________________________________________________________________________________

Last updated March 2020

Where Milliman is Acting as a Data Controller

Milliman, Inc. and its affiliates (“Milliman”or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing the Swiss affiliate’s (Milliman AG) use and protection of personal data that individuals and clients residing within the European Economic Area, the Isle of Man, Switzerland and the UK, share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the EU-U.S. Privacy Shield, the Federal Act on Data Protection as amended from time to time(the “Act”), and other data protection and privacy laws, as applicable.

Milliman, Inc. and Milliman AG re joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Milliman AG are both responsible for the compliance with applicable data protection laws.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.

Processing of Personal Data

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with visitors and the administration of the website.The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR).

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract(name, professional address, title, email and other professional contact details)for contract administration purposes.The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. The basis for the processing of Personal Data is Milliman’s legitimate interest. Milliman may rely on your consent for the sending of marketing communications when so required by data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication. Milliman AG may also use professional contact details of its clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests.For those activities, the basis for the processing of Personal Data is Milliman AG’s legitimate interest, unless data protection and privacy law require your prior consent. We maya also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you may write to us at data.protection@milliman.com requesting the same. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

No automated decision-making is undertaken based on the Personal Data collected from you.

Affiliates and Authorized Third-Party Agents

All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman AG and Milliman, Inc. or other entities controlled by or under common control with Milliman, Inc., for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events. We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that itself and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the GDPR (adequacy decision or Model Clauses of the European Commission). Those can be made available at Milliman’s premises, by contacting us at data.protection@milliman.com

Other Disclosures

Milliman may also disclose PersonalData and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited PersonalData (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact Milliman at data.protection@milliman.com, and Milliman will take steps to delete any such Personal Data.

Third-party Links

Milliman’ website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third Party Websites is no longer under our control and no longer subject to Milliman Personal Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Information to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Privacy Shield

Milliman is committed to handling Personal Data in accordance with this Privacy Policy and the EU-U.S. Privacy Shield Framework (or the Swiss-U.S. Privacy Shield Framework, as the case may be), as administered by the U.S. Department of Commerce. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and to view Milliman’s certification, please visit https://www.privacyshield.gov/list.

Milliman’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Milliman remains responsible and liable under the Privacy Shield Principles if third parties engaged by Milliman process the Personal Data in a manner inconsistent with the Principles, unless Milliman proves that it is not responsible for the event giving rise to any damage. Additionally, Milliman, Inc. has put in place data protection agreements with its affiliates located in the European Economic Area based on the EU Standard Contractual Clauses issued by the European Commission (the “EU Standard Contractual Clauses”).

As further explained in the "How to Contact Us" section below, Milliman encourages any individual to contact us should they have a Privacy Shield-related (or general privacy-related) complaint. Any right of access, rectification, erasure, restriction of the processing as well as the right to data portability of individuals domiciled in the European Economic Area or Switzerland may be exercised under the conditions set forth in the GDPR by contacting Milliman at data.protection@milliman.com. Furthermore, these individuals will have the right to lodge a complaint with a competent supervisory authority at any time -in Switzerland, such authority is the “Eidgenössischer Datenschutz-und Öffentlichkeitsbeauftraget” (www.edoeb.admin.ch).

Rights

You have a number of rights under the Act in relation to your Personal Data, including the right to request that incorrect Personal Data be corrected (Art. 5 of the Act) and the right to request information about the processing of your Personal Data (Art. 8 of the Act).

Please note that any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights as stated above, by sending us a request to data.protection@milliman.com. We will endeavor to respond to any such request as soon as possible, and in any event within the legal deadline.

How to Contact Us

Milliman’s European Data Protection Officer can be contacted at data.protection@milliman.com.

If you live in the European Union, European Economic Area, or Switzerland and you have a complaint regarding the handling of your Personal Data in accordance with the EU-U.S. or Swiss-U.S. Privacy Shield Framework and your efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the American Arbitration Association (http://go.adr.org/privacyshield.html), which has been selected as the independent recourse mechanism to resolve complaints and disputes relating to treatment of Personal Data originating in the European Union, European Economic Area, or Switzerland and transferred to the U.S. under this Privacy Policy. Under certain conditions, you may be entitled to invoke binding arbitration through the Privacy Shield Panel when other dispute resolution procedures have been exhausted. Milliman is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Turkey

Data Privacy Policy - Turkey

______________________________________________________________________________________________________________

Last updated March 2020

Where Milliman is Acting as a Data Controller

Milliman, Inc. and its affiliates (“Milliman”or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing the Turkish affiliate’s (Milliman. Aktueryalve Stratejik Danışmanlık Limited Şirketi) use and protection of Personal Data that individuals and clients residing in Turkey share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the Turkish data protection law no 6698 (the “Law”) and other data protection and privacy laws, as applicable.

Milliman, Inc. and Milliman Aktueryal ve Stratejik Danışmanlık Limited Şirketiare joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Milliman Aktueryal ve Stratejik Danışmanlık Limited Şirketiare both responsible for the compliance with applicable data protection laws.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.

Processing of Personal Data

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with visitors and the administration of the website.The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR).

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract(name, professional address, title, email and other professional contact details)for contract administration purposes.The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) of the Law). Milliman may also rely on your consent (Art. 5(1) of the Law) for the sending of marketing communications when so required by data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication. Milliman Aktueryal ve Stratejik Danışmanlık Limited Şirketi may also use professional contact details of its clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests. For those activities, the legal basis for the processing of Personal Data is Milliman Aktueryal ve Stratejik Danışmanlık Limited Şirketi’s legitimate interest (Art. 5(2) letter (f) of the Law), unless data protection and privacy law require your prior consent. We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you may write to us at data.protection@milliman.com requesting the same. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

No automated decision-making is undertaken based on the Personal Data collected from you.

Affiliates and Authorized Third-Party Agents

All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman Aktueryalve Stratejik Danışmanlık Limited Şirketi and Milliman, Inc. or other entities controlled by or under common control with Milliman, Inc., located in the U.S. and/or Europe, for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events. We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those. affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that itself and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the GDPR (adequacy decision or Model Clauses of the European Commission). Those can be made available at Milliman’s premises, by contacting us at data.protection@milliman.com

Other Disclosures

Milliman may also disclose Personal Data and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited PersonalData (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact Milliman at data.protection@milliman.com, and Milliman will take steps to delete any such Personal Data.

Third-party Links

Milliman’ website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third Party Websites is no longer under our control and no longer subject to Milliman Personal Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Information to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Privacy Shield

Milliman is committed to handling Personal Data in accordance with this Privacy Policy and the EU-U.S. Privacy Shield Framework (or the Swiss-U.S. Privacy Shield Framework, as the case may be), as administered by the U.S. Department of Commerce. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and to view Milliman’s certification, please visit https://www.privacyshield.gov/list.

Milliman’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Milliman remains responsible and liable under the Privacy Shield Principles if third parties engaged by Milliman process the Personal Data in a manner inconsistent with the Principles, unless Milliman proves that it is not responsible for the event giving rise to any damage. Additionally, Milliman, Inc. has put in place data protection agreements with its affiliates located in the European Economic Area based on the EU Standard Contractual Clauses issued by the European Commission (the “EU Standard Contractual Clauses”).

As further explained in the "How to Contact Us" section below, Milliman encourages any individual to contact us should they have a Privacy Shield-related (or general privacy-related) complaint. Any right of access, rectification, erasure, restriction of the processing as well as the right to data portability of individuals domiciled in the European Economic Area or Switzerland may be exercised under the conditions set forth in the GDPR by contacting Milliman at data.protection@milliman.com. Furthermore, these individuals will have the right to lodge a complaint with a competent supervisory authority at any time.

Rights

You have a number of rights under the GDPR in relation to your Personal Data, namely:

  1.  the right to learn whether Personal Data are processed or not, to request information if Personal Data are processed, to learn the purpose of the processing and to know the third parties to whom the Personal Data is transferred, pursuant to Art. 11of the Law: you have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Data and the manner in which, and the purposes for which we process your Personal Data, so that you can verify its accuracy and the lawfulness of the processing.You have right to know the third parties to whom his Personal Data are transferred in country or abroad.
  2.  the right to rectification pursuant to Art. 11 of the Law: you have the right to obtain from the us the rectification of inaccurate Personal Data concerning you, and the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.Where you Personal Data is transferred to third parties, you have a right to request from us the notification of the rectification of inaccurate Personal Data to third parties to whom your Personal Data have been transferred.
  3.  the right to erasure pursuant to Art. 11 of the Law: the right to obtain from us the erasure of your Personal Data delay where (a) your Personal Data is no longer necessary for the purpose for which it was collected/processed; (b) you wish to withdraw your consent to processing (except where we have another legal ground for the processing that we may rely on); (c) where processing is based on our legitimate interests and there are no overriding legitimate grounds for processing; (d) where your Personal Data has been unlawfully processed; You have right to request from us the notification of the erasure of your Personal Data to third parties to whom your Personal Data have been transferred.
  4.  the right to object to the occurrence of a result against the person himself/herself by analyzing the data processed solely through automated systems pursuant to Art. 11of the Law.
  5.  the right to request compensation for the damage arising for the unlawful processing of your Personal Data.

Please note that any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights as stated above, by sending us a request to data.protection@milliman.com. We will endeavor to respond to any such request as soon as possible, and in any event within the legal deadline.

How to Contact Us

Milliman can be contacted at data.protection@milliman.com. Milliman welcomes feedback and questions on this Privacy Policy. If for any reason you wish to contact us, please send an email (data.protection@milliman.com). Complaints will be resolved internally in accordance with Milliman’s complaints procedures.

United Kingdom

Data Privacy Policy - United Kingdom

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Last updated March 2020

Where Milliman is Acting as a Data Controller

Milliman, Inc. and its affiliates (“Milliman”or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing the UK affiliate’s (Milliman LLP) use and protection of personal data that individuals and clients residing within the European Economic Area, the Isle of Man, Switzerland and the United Kingdom, share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the EU-U.S. Privacy Shield, any successor adequacy decision, the UK Data Protection Act 2018 together with its references to theEU General Data Protection Regulation (GDPR) and other data protection and privacy laws, as applicable.

Milliman, Inc. and Milliman LLP are joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Milliman LLP are both responsible for the compliance with applicable data protection laws.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.

Processing of Personal Data

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with visitors and the administration of the website.The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR).

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract (name, professional address, title, email and other professional contact details)for contract administration purposes. The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR). Milliman may rely on your consent(Art. 6 (1) letter (a) GDPR) for the sending of marketing communications when so required by data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication. Milliman LLP may also use professional contact details of its clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests. For those activities, the legal basis for the processing of Personal Data is Milliman LLP’s legitimate interest (Art. 6 (1) letter (f) GDPR), unless data protection and privacy law require your prior consent. We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you may write to us at data.protection@milliman.com requesting the same. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

No automated decision-making is undertaken based on the Personal Data collected from you.

Affiliates and Authorized Third-Party Agents

All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman LLP and Milliman, Inc. or other entities controlled by or under common control with Milliman, Inc., for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events. We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that itself and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the GDPR (adequacy decision or Model Clauses of the European Commission). Those can be made available at Milliman’s premises, by contacting us at data.protection@milliman.com

Other Disclosures

Milliman may also disclose PersonalData and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited PersonalData (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact Milliman at data.protection@milliman.com, and Milliman will take steps to delete any such Personal Data.

Third-party Links

Milliman’ website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third Party Websites is no longer under our control and no longer subject to Milliman Personal Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Information to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Privacy Shield

Milliman is committed to handling Personal Data in accordance with this Privacy Policy and the EU-U.S. Privacy Shield Framework (or the Swiss-U.S. Privacy Shield Framework, as the case may be), as administered by the U.S. Department of Commerce. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and to view Milliman’s certification, please visit https://www.privacyshield.gov/list.

Milliman’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Milliman remains responsible and liable under the Privacy Shield Principles if third parties engaged by Milliman process the Personal Data in a manner inconsistent with the Principles, unless Milliman proves that it is not responsible for the event giving rise to any damage. Additionally, Milliman, Inc. has put in place data protection agreements with its affiliates located in the European Economic Area and the United Kingdom based on the EU Standard Contractual Clauses issued by the European Commission (the “EU Standard Contractual Clauses”).

As further explained in the "How to Contact Us" section below, Milliman encourages any individual to contact us should they have a Privacy Shield-related (or general privacy-related) complaint. Any right of access, rectification, erasure, restriction of the processing as well as the right to data portability of individuals domiciled in the European Economic Area or Switzerland may be exercised under the conditions set forth in the GDPR by contacting Milliman at data.protection@milliman.com. Furthermore, these individuals will have the right to lodge a complaint with a competent supervisory authority at any time.

Rights

You have a number of rights under the GDPR in relation to your Personal Data, namely:

  1. the right of access pursuant to Art. 15 GDPR: you have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Data and the manner in which, and the purposes for which we process your Personal Data, so that you can verify its accuracy and the lawfulness of the processing.
  2. the right to rectification pursuant to Art. 16 GDPR: you have the right to obtain from us the rectification of inaccurate Personal Data concerning you, and the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  3. the right to erasure pursuant to Art. 17 GDPR: the right to obtain from us the erasure of your Personal Data delay where (a) your Personal Data is no longer necessary for the purpose for which it was collected/processed; (b) you wish to withdraw your consent to processing (except where we have another legal ground for the processing that we may rely on); (c) where processing is based on our legitimate interests and there are no overriding legitimate grounds for processing; (d) where your Personal Data has been unlawfully processed;
  4. the right to restriction of processing pursuant to Art. 18 GDPR: you have the right to obtain from us the restriction of processing of your Personal Data where (a) the accuracy of such Personal Data is contested by you (for such period as will enable us to verify the accuracy of your Personal Data); (b) the processing of your Personal Data is unlawful, but you do object to the deletion of such data and request restriction of its use instead; (c) you consider that we no longer need your Personal Data for the purposes of the processing, but require such Personal Data for the establishment, exercise or defense of legal claims; (d) you have objected to the processing of your Personal Data on grounds of “legitimate interest” as per (iii) above, pending verification by us on whether our legitimate grounds override your own.
  5. the right to objection pursuant to Art. 21 GDPR: you have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data, which is based on point our legitimate interests, including profiling based on those provisions. We shall no longer process the Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. You may object to the processing of your Personal Data or direct marketing purposes at any time, without giving reason.
  6. the right to data portability pursuant to Art. 20 GDPR: you have the right to receive Personal Data concerning you, and which you have provided to us, in a structured, commonly used and machine-readable format, and to transmit such data to another data controller (please note this applies only where our processing of your Personal Data is based on your consent, and the processing is carried out by automated means).
  7. the right to appeal to a competent data protection supervisory authority (Art. 77 GDPR): you have the right to appeal to the competent data protection supervisory authority -in Spain, such authority is the “Agencia Española de Protección de Datos” (www.aepd.es).

Please note that any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights as stated above, by sending us a request to data.protection@milliman.com. We will endeavor to respond to any such request as soon as possible, and in any event within the legal deadline.

How to Contact Us

Milliman’s European Data Protection Officer can be contacted at data.protection@milliman.com.

If you live in the European Union, European Economic Area, or Switzerland and you have a complaint regarding the handling of your Personal Data in accordance with the EU-U.S. or Swiss-U.S. Privacy Shield Framework and your efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the American Arbitration Association (http://go.adr.org/privacyshield.html), which has been selected as the independent recourse mechanism to resolve complaints and disputes relating to treatment of Personal Data originating in the European Union, European Economic Area, or Switzerland and transferred to the U.S. under this Privacy Policy. Under certain conditions, you may be entitled to invoke binding arbitration through the Privacy Shield Panel when other dispute resolution procedures have been exhausted. Milliman is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).