Global Captive Management LTD Privacy Notice

Executive Summary

This Privacy Notice applies to any personal information you provide to us and any personal information we collect when you contact us, visit or use our websites or applications, visit one of our office locations, attend an event or seminar we are hosting, whether in person or virtual, or utilize our services (“Services”) which are provided by HMA Group Holdings, LLC or any of our affiliated companies (collectively, “Global Captive Management LTD”, “we”, or “us”).

Information We Collect

When you use our Services, we may automatically collect information about your Internet service provider, your operating system, browser, type, domain name, Internet protocol (IP) address, your access times, the website that referred you to us, the pages and aspects of the Services you requested, and the date and time of those requests.

Additionally, we may collect the following information in order to provide our Services, which, in addition to the above, is considered personal information:

Contact information: may include name, email, physical address, social media handle or phone number.

Unique identifiers: may include passport number, driver’s license number, or any other identifying documentation issued by a federal, state, or local agency.

Demographic details: may include your date of birth, age, gender, race, image, marital status, background information, or insurance requirements.

Employment information: may include job title, employee number, employment status, salary, background information, or health and wellness benefits.

Health information: may include medical records, health status, medical outcomes, claim summaries, and other information which may or may not be regulated under the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

Benefits information: may include benefit elections, claims made under your applicable benefit programs or insurance policies, retirement information, employment information, contribution summaries, and other voluntary information relating to your health and wellness benefits.

Financial information: may include credit history, salary, tax information, deductions, benefits data, and insurance contribution or payout information.

Claims information: may include claim summaries, background information, driving/motor vehicle records (MVRs), credit reports, medical files, or other necessary documentation.

Finally, we may also collect certain marketing information you provide in connection with any marketing campaigns, events, or seminars hosted by us. Such information may include an indication of your interest in our Services, comments, feedback, or other forms of interaction that may occur through said marketing campaigns, events, or seminars. We will also make note of your communication preferences.

Information Provided by You or Third Parties to Us

In general, you can visit our website and utilize some of our Services without telling us who you are or revealing any personal information. In some instances, you may be prompted to provide some information, such as an email address, name, address, or zip code in order to receive additional information regarding our Services.  We will only use the personal information you have shared with us for the purposes as stated in this Privacy Notice.

Depending on the Services being provided, we may obtain your personal information from third parties such as our vendors and service providers (including to confirm and supplement information you provide to us directly), your employer, your health plan, applicable insurance carriers, and our motor vehicle record (MVR) providers.

Legal Grounds for the Use of Your Information

GCM generally collects only the personal information necessary to fulfill your request. You may provide additional information on your own volition – such additional information is always optional.

The law of the Cayman Islands allows us to process personal information, so long as we have grounds under the law to do so. It also requires us to tell you what those grounds are. When we process your personal information, we will rely on one of the following processing conditions:

  1. Performance of a Contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;
  2. Legal Obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
  3. Legitimate Interests: we may process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
  4. Your Consent: we may occasionally ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting GCM at the address listed at the end of the Privacy Policy.

GCM only collects “sensitive” personal information when the relevant individuals voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards.

Cookies and Automatic Collection

We and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Services. The technologies we use for this automatic data collection may include cookies and web beacons that permit us to verify system and server integrity and generate statistics around the popularity of certain content. We process the information collected through such technologies, which may include or be combined with personal information, to help operate certain features of our Services, to enhance your experience through personalization, and to help us better understand the features of our Services that you and other users are most interested in.

We also use analytics services including Google Analytics that uses cookies and other technologies that collect your personal information to assist us with analyzing our site traffic usage to optimize, maintain, and secure our Site and inform subsequent business decisions. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data from sites or apps that use our services.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

How We Use the Information

If you provide personal information, we may use that information to contact you or to provide our Services. Additionally, we may use personal information to improve our marketing and promotional efforts, to analyze site usage, and to improve our content, layout, and Services. Information collected automatically through cookies may be combined with your previously submitted personal information. We may process your information we have collected in connection with the Services which may include: brokerage services, insurance consulting, ancillary benefit services and consulting, wellness consulting, benchmarking, marketing, research, and other similar offerings. In addition to the performance of our Services, we may process your information to meet our legal and regulatory obligations, prevent and detect fraud, with the consent of the provider, or for other legitimate interests.

How We Share Your Data

We will not sell, exchange, or otherwise distribute your personal information without your consent, except to the extent required by law, required in order to provide our Services, or as identified in this Privacy Notice. Your information may be shared with our affiliates, agents or service providers, in a business transfer, or in certain legal matters which require such disclosure. Additionally, we may disclose your information to insurance carriers, risk management agencies, legal advisers, accountants, auditors, insurance adjusters, claim investigators, third party administrators, medical professionals, law enforcement bodies, or regulators and government bodies.

Your Privacy Rights

Depending on where you are located, you may have certain rights with respect to your personal information, including the right to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information.
  • Data portability.
  • Opt-out of personal data processing for targeted advertising and sales.
  • Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
  • Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

If you are a California resident, please see our CCPA Privacy Notice for California Residents for more information. To exercise any of these rights please email Privacy@holmesmurphy.com or call (800) 247-7756. To appeal a decision regarding a consumer rights request an appeal by emailing Privacy@holmesmurphy.com or calling (800) 247-7756.

Links to Other Websites

Our services may have links to other websites that are not operated by us. If you visit one of these linked websites, you are then subject to the policies of the owner of the linked website. We are not responsible for the contents of those websites and have no control over what information they may or may not collect from you.

Data Security and Retention

We take reasonable steps to maintain physical, technical, and administrative security of any information you provide to use in order to protect the confidentiality, integrity, and availability of the information and ensure that such information is processed in accordance with applicable privacy laws.

We will retain your personal information only as long as necessary in connection with your use of our Services or as required by law. We may also retain some data for internal analysis purposes only. Such data will be retained for a short period of time, unless used to strengthen our security or improve functionality.

Use by Children

We will not knowingly allow anyone under the age of thirteen (13) to provide us any personal information online. Global Captive Management LTD cares about protecting the privacy of children and believes children should always have the permission of their parents before transmitting any personal information over the internet.

Compensation Disclosure

Global Captive Management LTD and its affiliates receive compensation from insurance carriers and other third-party vendors for services provided through the receipt of commissions and profit-sharing arrangements. Profit-sharing payments from insurance carriers are based on the profitability and/or premium growth of all the business Global Captive Management LTD or its affiliates has with an insurance carrier and is not determined solely by the profitability of your account.

International Users

 If you are visiting our website or otherwise using our Services from outside of the United States, please be aware that we are based in the United States and where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Privacy Notice.

Changes to This Privacy Notice

Please note that we may modify or update this Privacy Notice from time to time, so please review it periodically. If we make material changes to how we treat personal information, we will notify you according to applicable law. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to our website. You are responsible for periodically visiting our website and this Privacy Notice to check for any changes. 

Questions or Concerns

If you have any questions, concerns, or complaints about this Privacy Notice, they should be directed to Global Captive Management LTD at Privacy@holmesmurphy.com, call (800) 247-7756, or directed to the address below:

Global Captive Management LTD
Attn: Legal Department
Building 3, 2nd Floor
23 Lime Tree Bay Avenue
P.O. Box 1363
Grand Cayman, KY1-1108
CAYMAN ISLANDS

In any event, you always have the right to lodge a complaint with the Office of the Ombudsman, Cayman Islands.