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LUNA INSURANCE AND REINSURANCE BROKERS SRO is a leading global professional services firm providing a broad range of risk, retirement and health solutions. LUNA INSURANCE AND REINSURANCE BROKERS SRO is committed to protecting your privacy. This commitment reflects the value we place on earning and keeping the trust of our customers, business partners, and others who share their personal information with us.

What does this Privacy Statement do? This Privacy Statement ("Statement") explains LUNA INSURANCE AND REINSURANCE BROKERS SRO's information processing practices. It applies to any personal information you provide to LUNA INSURANCE AND REINSURANCE BROKERS SRO and any personal information we collect from other sources. This Statement is a statement of our practices and of your rights regarding your personal information. This is not a contractual document, and it does not create any rights or obligations on either party, beyond those which already exist under data protection laws. This Statement does not apply to your use of a third party site linked to on this website.

Who is responsible for your information? Throughout this Statement, "LUNA INSURANCE AND REINSURANCE BROKERS SRO " refers to LUNA SRO plc, including its affiliated companies and subsidiaries (also referred to as "we", "us", or "our"). The LUNA SRO entity responsible for your personal information (and the controller for the purposes of data protection laws) will be the member of LUNA SRO that originally collects information from or about you. This may also be explained in separate privacy notices made available when your personal information are first collected by that LUNA Insurance and Reinsurance Brokers SRO entity, for example where you or the business you work for engages us to provide a service.Some of the services which LUNA Insurance and Reinsurance Brokers SRO provides to its clients are provided as a processor, which means that the Client remains primarily responsible for your information. In these circumstances, we may re-direct a query about our use of your information to our client.

Quick read: LUNA Insurance and Reinsurance Brokers SRO collects personal information from its clients (about their employees and customers) to provide risk based services, such as insurance broking, risk management consulting and employee Benefits and pension administration. LUNA Insurance and Reinsurance Brokers SRO also collects some personal information directly, for example over its websites and applications. LUNA Insurance and Reinsurance Brokers SRO uses personal information to deliver services to clients. For its own purposes, it also uses personal information to analyse and improve how it delivers those services, to contact representatives of its clients or prospective clients and to market to them. If LUNA Insurance and Reinsurance Brokers SRO uses your personal information, you will have certain important rights which you can exercise. The rights you will be able to exercise will depend on how and why LUNA Insurance and Reinsurance Brokers SRO uses your information.

Do we disclose your personal information? Within LUNAInsurance and Reinsurance Brokers SRO We may share your personal information with other LUNA Insurance and Reinsurance Brokers SRO entities, brands, divisions, and subsidiaries to serve you, including for the activities listed above We do not rent, sell or otherwise disclose personal information about our online visitors with unaffiliated third parties for their own marketing use. We do not share your personal information with third parties except in the following circumstances discussed below.

Business Partners We disclose personal information to business partners who provide certain specialized services to us, or who co-operate with us on projects. These business partners operate as separate controllers, and are responsible for their own compliance with data protection laws. You should refer to their privacy notices for more information about their practices.

Examples include:
*Banking and finance products - credit and fraud reporting agencies, debt collection agencies, insurers, reinsurers, and managed fund organizations for financial planning, investment products and trustee or custodial services in which you invest
* Insurance broking and insurance products - insurers, reinsurers, other insurance intermediaries, insurance reference bureaus, medical service providers, fraud detection agencies, our advisers such as loss adjusters, lawyers and accountants and others involved in the claims handling process.

Authorized Service Providers
We may disclose your information to service providers we have retained (as processors) to perform services on our behalf (either in relation to services performed for our clients, or information which LUNA Insurance and Reinsurance Brokers SRO uses for its own purposes, such as marketing). These service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements. .

Examples include:
* IT service providers who manage our IT and back office systems and telecommunications networks;
* marketing automation providers,
* contact center providers.
These third parties appropriately safeguard your data, and their activities are limited to the purposes for which your data was provided.

Legal Requirements and Business Transfers
We may disclose personal information (i) if we are required to do so by law, legal process, statute, rule, regulation, or professional standard, or to respond to a subpoena, search warrant, or other legal request. (ii) in response to law enforcement authority or other government official requests, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iv) in connection with an investigation of suspected or actual illegal activity or (v) in the event that LUNA Insurance and Reinsurance Brokers SRO is subject to a merger or acquisition to the new owner of the business. Disclosure may also be required for company audits or to investigate a complaint or security threat.

Do we transfer your personal information across geographies?
We are a global organization and may transfer certain personal information across geographical borders to LUNA Insurance and Reinsurance Brokers SRO entities, authorized service providers or business partners in other countries working on our behalf in accordance with applicable law. Our affiliates and third parties may be based locally or they may be overseas some of which have not been determined by the European Commission to have an adequate level of data protection. When we do, we use a variety of legal mechanisms to help ensure your rights and protections travel with your data: . we ensure transfers within LUNA Insurance and Reinsurance Brokers SRO are covered by agreements based on the EU Commission's standard contractual clauses, which contractually oblige each member to ensure that personal information receives an adequate and consistent level of protection wherever it resides within LUNA Insurance and Reinsurance Brokers SRO; -where we transfer your personal information outside LUNA Insurance and Reinsurance Brokers SRO or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information. Some of these assurances are well recognized certification schemes like the EU - US Privacy Shield for the protection of personal information transferred from within the EU to the United States, or the standard contractual clauses, or -where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information are disclosed. Examples of countries we transfer personal information to include, but are not limited to, the United States of America, the United Kingdom, Ireland, Singapore, India and the Philippines. If you would like further information about whether your information will be disclosed to overseas recipients, please contact us as noted below. You also have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments, which may be redacted for reasons of commercial confidentiality) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

Do we transfer your personal information across geographies?
The security of your personal information is important to us and LUNA Insurance and Reinsurance Brokers SRO has implemented reasonable physical, techniical and administrative security standards to protect personal information from loss, misuse, alteration or destruction. We protect your personal information against unauthorized access, use or disclosure, using security technologies and procedures, such as encryption and limited access. Only authorized individuals access your personal information, and they receive training about the importance of protecting personal information. Our service providers and agents are contractually bound to maintain the confidentiality of personal information and may not use the information for any unauthorized purpose.

Contact Us
If you have any questions, would like further information about our privacy and information handling practices, would like to discuss opt-outs or withdrawing consent, or would like to make a complaint about a breach of the Act or this Statement, please contact the Privacy Officer: Alternatively, you have the right to contact your local Data Protection Authority. If you have any questions relating to this Statement, please contact us at the LUNAInsurance and Reinsurance Brokers SRO.

Changes to this Statement
We may update this Statement from time to time. When we do, we will post the current version on this site, and we will revise the version date located at the bottom of this page. We encourage you to periodically review this Statement so that you will be aware of our privacy practices. This Statement was last updated on Feb 04, 2014.