JMB Insurance provides this notice of its privacy policies in compliance
with the Public Law 106-102 (1999), commonly known as the Gramm-Leach-Bliley
Act. Title V of this Act limits certain disclosures of nonpublic personal
information by financial institutions, including insurance brokers like JMB
Insurance. This notice is intended to provide an overview of our clients’
rights (including former clients) relative to how we collect and use
personal information that is disclosed to us. It should be noted that this
Act only pertains to certain personal information and does not cover
business information.
In order to properly serve our clients, we routinely collect certain
non-public information. This is used to assist us in determining the proper
products for our clients, assemble underwriting information for the carriers
who we contact to obtain quotes and place coverage, and provide services.
Although we generally are not directly involved with the administration of
claims on life, accident or health insurance products, we may from time to
time participate in the administration of certain claims where non-public
personal information may become relevant. To comply with this Act, when we
anticipate that personal medical or health information may be disclosed to
us, we will request the execution of a disclosure authorization relating to
the federal Health Insurance Portability and Accountability Act. JMB
Insurance employees with access to non-public personal information are
required to comply with this policy.
What kind of non-public personal or proprietary financial information do we collect and from whom?
We obtain most information directly through personal contact or though other
sources we consult as we deem applicable to the situation. This may include
review of a client’s website or other internet-based sources. We may also
collect non-public personal financial information from other sources. Third-
party sources of this information might include government agencies,
consumer reporting agencies, courts and other government or private records.
The types of such information we gather depends on the nature of the
insurance involved and/or or services we perform. We generally receive the
following information directly from our clients:
- Name
Address- Birth date and Birthplace
- Marital Status
- Gender
- Social Security Number
- Personal and Family Medical Information
- Employment and Income Information
- Lifestyle Matters such as Hobbies and Habits
We also may come to know various other information about our clients based
on their business conducted with us, our affiliates and/or third-parties
with whom we deal or from persons we contact to verify representations and
information provided, such as:
- Payment and credit history
- Tax obligations
- Investment preferences
Correspondence through electronic media (such as email or through our
website) may generate additional information that is non-public.
To whom do we disclose non-public personal information?
We do not disclose any non-public personal financial information to anyone,
except as we may deem necessary to service our clients or comply with
applicable law as well as insurance and securities industry regulations. For
example, we may disclose non-public personal information in connection with
our survey of insurance markets and the filing of coverage applications with
various insurance carriers, general agents, registered brokers through whom
we or our producers market regulated products under SEC and FINRA rules,
such as variable annuities, or other industry sources. Such disclosures may
be made to affiliated or non-affiliated persons or entities involved in the
underwriting, processing, servicing and marketing of insurance products and
adjusting and administration of claims and may include disclosures to
companies that perform services on our behalf or with whom we have joint
marketing agreements. We will not disclose any information if such
disclosure would be contrary to applicable law; however, there are times
when we are required by law or permitted to provide your non-public personal
information to authorized persons or entities, including, but not limited
to:
- Complying with legal process, such as a subpoena, warrant, summons or discovery request in connection with a lawsuit or an administrative action by a federal, state or local authority.
- Responding to investigations or audits by regulatory authorities.
- Monitoring or disclosure of communications as required by federal or state law.
How do we safeguard non-public personal information in our records?
Except as set forth below, access to nonpublic personal information is
limited to those persons and entities who need to know the information in
order to properly underwrite, process, service and/or market insurance
products or services, and/or to file, adjust and administer claims that may
be made by or against our clients, and/or to otherwise properly service
accounts. We will keep information in our possession physically and
electronically secure. If we discover that certain non-public personal
information we possess may be inaccurate or false, we will make a reasonable
attempt to re-verify and correct the information.
While we do not sell or otherwise disclose client lists or other client information in the ordinary course of business other than as explained herein, we reserve our right to disclose information in certain circumstances:
JMB Insurance reserves the right to disclose, sell or transfer client
information (including, but not limited to, name, address, age, gender, zip
code, state and country of residency and other information of our clients,
their employees and/or their respective family members) to (1) a potential
buyer or other successor in connection with the potential sale, merger or
transfer of all or a portion of our business or accounts, or (2) consultants
or other third-party contractors to the extent such disclosure is necessary
in connection with the establishment or improvement of JMB Insurance’s
systems or procedures, who agrees in connection with such disclosure to
comply with confidentiality and protection procedures that are similar in
nature and scope to those set forth herein. If in the future, we determine
to share information with affiliates or third parties (including, but not
limited to financial services companies) in order that they may market
additional products or services other than through joint marketing
agreements with us, we will first provide clients with the opportunity to
“opt out” in which case their information will not be shared. This does not
apply to insurance industry sources that receive such information in
connection with our services, as described above.
Our policy regarding dispute resolution:
Any controversy or claim arising out of or relating to our privacy policy,
or the breach thereof, shall absent contrary contractual terms between us,
be settled by arbitration in accordance with the rules of the American
Arbitration Association, and judgment upon the award rendered by the
arbitrator(s) may be entered in any court having jurisdiction thereof.
Questions and further information:
Please email us at:
privacy@jmbins.com.
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