This Privacy Shield Notice ("Notice") describes how Hagerty and its subsidiaries and affiliates in the United States ("US") collect, use, and disclose certain personally identifiable information that we receive in the US from the European Union ("EU Personal Data"). This Notice applies to the following US affiliated entities:
Hagerty recognizes that the EU has established strict protections regarding the handling of EU Personal Data, including requirements to provide adequate protection for EU Personal Data transferred outside of the EU. To provide adequate protection for certain EU Personal Data about members, corporate customers, suppliers, business partners, job applicants and employees received in the US, Hagerty has elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce ("Privacy Shield"). Hagerty adheres to the Privacy Shield Principles of:
For purposes of enforcing compliance with the Privacy Shield, Hagerty is subject to the investigatory and enforcement authority of the US Federal Trade Commission ("FTC"). For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov. To review Hagerty’s representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list.
We process EU Personal Data for the following purposes:
Hagerty will only process EU Personal Data in ways that are compatible with the purpose that Hagerty collected it for, or for purposes the individual later authorizes. Before we use your EU Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. Hagerty maintains reasonable procedures to help ensure that EU Personal Data is reliable for its intended use, accurate, complete, and current.
Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process EU Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of EU Personal Data that we transfer to them.
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your EU Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
Hagerty maintains reasonable and appropriate security measures to protect EU Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
You may have the right to access the EU Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EU Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
You can direct any questions or complaints about the use or disclosure of your EU Personal Data to us at firstname.lastname@example.org. You may also contact our EU affiliate Hagerty International Limited, at email@example.com or telephone us at 0333 323 1138 with any questions or concerns. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EU Personal Data within 45 days of receiving your complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. If your complaint regards human resource data, please contact your local European Data Protection Authority ("DPA") as your local DPA is the only method of recourse for human resource data. Hagerty agrees to comply with the European DPAs in these instances. Please find your DPA here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with Truste and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).
If you have any questions about this Notice or would like to request access to your EU Personal Data, please contact us as follows: firstname.lastname@example.org.
We reserve the right to amend this Notice from time to time consistent with the Privacy Shield’s requirements.
Effective Date: August 30, 2018
Last modified: November 19, 2019