Privacy Notice

Updated: 12 September 2025

This Privacy Notice applies to Harman Kemp Limited, and its affiliates and subsidiaries (collectively, “we,” “our,” “us,” or “Harman Kemp”). A full list of affiliates and subsidiaries is available on request.

In this Privacy Notice, we identify the personal data that we collect about you and how we use that data. This Privacy Notice applies to any personal data you provide to Harman Kemp and any personal data we collect from other sources, unless you are provided a more specific privacy statement at the time of data collection. This Privacy Notice does not apply to any third-party websites, applications or portals (“Sites”) linked to Harman Kemp’s Sites, or to any Harman Kemp Sites that have their own privacy notices. If you provide personal data to us about other people, you must provide them with a copy of this Privacy Notice and obtain any consent required for the processing of that person’s data in accordance with this Privacy Notice.

If you have any questions about this Privacy Notice, please contact us using the details set out in the Contact Us section. When using our Sites, you should read this Privacy Notice alongside the Site’s Terms of Use.

The following sections will guide you through our practices for the collection, usage, disclosure and retention of your personal data:

• Who we are

• How we process your personal data

• How we protect your personal data

• How we protect your personal data when sending it abroad

• Marketing activities

• Profiling and automated decision-making

• How long we keep your personal data

• Your personal data rights

• Contact us

• Updates to this Privacy Notice

1. Who we are

We provide a range of professional services including insurance, (re)insurance brokerage, risk and claims management, employee benefits and human resources consulting and administration, financial, pension administration and actuarial services through our various affiliates and subsidiaries.

2. How we process your personal data

2.1 Individuals in scope of this Privacy Notice

This Privacy Notice provides information for those individuals whose personal data we process, including:

• Business contacts, such as brokers, (re)insurers, managing agents (MGAs), loss adjusters, experts instructed in relation to claims, service providers, suppliers, professional advisors, conference attendees, visitors to our offices, government officials and authorities.

• Customers, claimants and plan beneficiaries, such as those in respect of insurance policies we place as part of our core insurance business activities (e.g., parties covered under the policies, potential beneficiaries of the policies, claimants and other parties involved in claims in respect of the policies), and any other customers in relation to our various service offerings.

• Users of our Sites.

• Other individuals, such as those requesting or receiving our marketing information, making general inquiries, entering competitions or promotions, or whose images we use in marketing or are captured on CCTV.

2.2 How we collect your personal data

We collect your personal data in a number of ways, which vary based on how you interact with us and as allowed by applicable law. The following summarises our various collection points:

• Directly from you or your authorised representative, such as when you provide your personal data to us, including from any of our Sites, surveys, live events, market research, and other direct communications and/or solicitations.

• From our clients and partners, such as commercial clients, (re)insurers, network partners, brokers, employers, benefit plan sponsors, benefit plan administrators, premium finance companies, health service providers, pension trustees, data/marketing list providers and third-party service providers.

• Publicly available sources, such as social media platforms, property and assets registers, and claims and convictions records.

• Harman Kemp affiliate companies.

• Government authorities, such as police and regulators.

• Background checks and screening tools, such as insurance industry fraud prevention and detection databases, credit agencies and sanctions screening tools.

• Other third parties.

2.3 Personal data we collect

We collect the following types of personal data depending on the purpose of your interaction with us (e.g., as business contact, customer, claimant, insured) and as allowed by applicable law:

• Basic personal and demographic information, such as your name, date of birth, age, gender and marital status.

• Contact information, such as your address, telephone number and email address.

• Unique identifiers, such as identification numbers issued by government bodies or agencies (e.g., your national identifier number or social security number, passport number, ID number, tax identification number, driver’s licence number).

• Beneficiary information, such as details of relationships, family members and dependants.

• Employment information, such as your job title, employer, employment status, salary information, employment benefits, pensionable service periods, employment history and professional certifications and training.

• Financial information, such as your bank account numbers and statements, credit card numbers, transaction information, tax information, details of your income, property, assets, investments and investment preferences, pension and benefits, debts, and creditworthiness.

• Policy information, such as your policy number, policy start and end dates, premiums, individual terms, mid-term adjustments, reasons for cancellation, risk profile, details of policy coverage and underwriting history.

• Claim information, such as a claimant’s relationship to a policyholder/insured, claims history and claims data, and the date and particulars of a claim.

• Plan information, such as contribution levels and benefit options.

• Commercial information, such as records of your personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

• Events or meeting information, such as details about your visits to our offices (including CCTV), your interest in and attendance at events or meetings, audio recordings, photographs or videos captured during meetings, events or calls with you.

• Lifestyle information, such as travel history and plans and general health data.

• Special category data and sensitive personal data, such as data relating to your health (including protected health information), genetic or biometric data, sex life, sexual orientation, gender identity, racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership.

• Criminal records information, such as criminal charges or convictions, including driving offences, or confirmation of clean criminal records.

• Professional disciplinary information.

• Personal information received from background checks and sanctions screenings, including status as a politically exposed person.

• Marketing information, such as your consent to or opt out from receiving marketing communications from us and/or third parties, your marketing preferences, or your interactions with our marketing campaigns and surveys.

• Sites and communication usage information, such as your username, password, information collected by visiting our Sites or through cookies and other tracking technologies, including your IP address, domain name, browser version and operating system, traffic data, location data, browsing time, and social media information.

2.4 How we use your personal data

Depending on the purpose of your interaction with us, we use your personal data to:

• Perform services for you or our clients — provide services and fulfil our contractual obligations, facilitate and enable placement of policies, and assist in the ongoing management of such policies including premium management, renewals, adjustments, cancellations and claims management.

• Manage our business operations — enter into business relationships and perform due diligence, maintain accounting records, analyse financial results, and conduct data analytics, surveys, benchmarking and risk modelling.

• Communicate and market to you — communicate regarding your account or changes to our policies, respond to enquiries, advertise and promote our services, send you newsletters, offers or other information we think may interest you, and monitor usage of our Sites.

• Comply with legal obligations — comply with national security or law enforcement requirements, discovery requests, or where otherwise required or permitted by applicable laws, regulations, court orders or regulatory authorities, and exercise and defend legal rights.

• Monitor and prevent fraud or wrongdoing — maintain the safety, security, quality, integrity and availability of our products, services, systems and data, and detect security incidents.

• Improve our services — develop, enhance, expand or modify our services through research and development, and monitor, review, assess and improve our technology systems.

• Mergers and acquisitions — facilitate commercial transactions, including a reorganisation, merger, sale of all or a portion of our assets, a joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock.

If we intend to use your personal data for any other purpose not described in this Privacy Notice or which is not compatible with the purpose for which your personal data was collected, we will contact you and let you know of that purpose.

2.5 Legal basis for processing personal data

Local law and regulation may require us to have a legal basis to process your personal data. In most cases, our legal basis for processing your personal data will be one of the following:

• Legitimate Business Interest, such as seeking to and entering into or performing our contractual duties, maintaining our business records, keeping records of insurance policies or other products we place, and analysing and improving our business model, services, systems and algorithms.

• For the performance of a contract with you or in order to take steps at your request prior to entering into that contract.

• Compliance with legal obligations, such as when you exercise your rights under data protection laws and make requests, for compliance with legal and regulatory requirements and related disclosures and for the establishment and defence of legal rights.

• Fraud detection or prevention.

• Consent, such as when we have to obtain your consent to process your personal data.

When we process sensitive personal data, sometimes referred to as special category data, in most cases our legal basis will be one of the following:

• As required to establish, exercise or defend legal claims.

• As necessary for insurance operations when it is in the substantial public interest, where applicable under local data protection laws.

• As necessary for the prevention or detection of an unlawful act and/or fraud when it is in the substantial public interest, where applicable under local data protection laws.

• You have given us your explicit consent — where we receive sensitive personal data or special category data indirectly, the third party is responsible for obtaining your explicit consent to enable us to collect and use your data for the purposes described in this Privacy Notice.

2.6 Who we share your personal data with

We share your personal data within Harman Kemp’s Group of Companies for the purpose of your interaction with us, such as for the provision of our services, general business operations and controls, marketing, data analytics, systems and algorithm improvements, surveys, benchmarking, and compliance with applicable laws.

We may also share your personal data with the following third parties for the purpose of your interaction with us:

• Your employer, as part of our provision of the services to you or your employer.

• Professional Advisors, such as underwriters, actuaries, claims handlers and investigators, surveyors, loss adjustors/assessors, accident investigators, specialist risk advisors, pension providers or trustees, banks and other lenders, health professionals, lawyers, accountants, auditors, tax advisors, financial institutions, investment advisors and other fiduciaries and consultants.

• Business partners, such as customers, (re)insurance companies, MGAs, brokers, other insurance intermediaries, claims handlers or other companies who act as insurance distributors and premium financing companies.

• Providers of insurance broking and other platforms we use.

• Service providers, such as IT software, security and cloud suppliers, finance and payment providers, marketing agencies, external venue providers, address tracers, printers, document management providers, telephony providers, debt collection agencies, background check and credit reference agencies.

• Fraud detection agencies and credit bureaus which operate and maintain fraud detection or credit registers.

• Industry bodies.

• Insurers who provide you with insurance and us with our own insurance.

• Regulators, public authorities and law enforcement agencies, such as police, judicial bodies, governments, quasi-governmental authorities, financial and pension regulators and workers’ compensation boards, where we are required or requested to do so by law.

• Asset purchasers, such as those who may purchase or to whom we may transfer, our assets and business.

• Other third parties, where we have your consent or are required by law.

When required by applicable law, we will obtain your explicit consent before sharing your data with any third parties. We will also require third parties (where applicable) to maintain a comparable level of protection of personal data as set out in this Privacy Notice by the use of contractual requirements or other means.

2.7 Children

Our Sites are not intended for children and we do not knowingly collect, use, or disclose information about children. If you are a minor, please do not provide any personal data even if prompted to do so. If you believe that you have inadvertently provided personal data, please ask your parent(s) or legal guardian(s) to notify us. In the event that we learn that we have inadvertently collected personal data via our Sites from a child, we will delete that information as quickly as possible.

3. How we protect your personal data

We use a range of organisational and technical security measures to protect your personal data, including, but not limited to, the following:

• Restricted access to those who need to know for the purposes set out in our underlying agreement or this Privacy Notice, and who are subject to confidentiality obligations.

• Firewalls to block unauthorised traffic to servers.

• Physical servers located in secure locations and accessible only by authorised personnel.

• Internal procedures governing the storage, access and disclosure of your personal data.

• Additional safeguards as may be required by applicable laws in the country where we process your personal data.

Please note that where we have given you (or you have chosen) a password, you are responsible for keeping the password confidential. Please do not share your password with anyone.

4. How we protect your personal data when sending it internationally

We operate as a global business and may transmit your personal data across borders, including within Harman Kemp’s Group of Companies and to certain third parties, including our partners and service providers. This sharing of data allows us to provide you services as set out in our underlying agreement or as otherwise indicated in this Privacy Notice. When required by applicable law, we will obtain your explicit consent before transferring your data.

The laws that apply to the country where the data is transferred may not be equivalent to that in your local country (or in the country in which we provide the services). Transfers of personal data will comply with applicable law and be subject to suitable safeguards to ensure an adequate level of protection, including, where required, the use of standard contractual clauses approved by the local data protection regulator. Please contact us using the details provided under the Contact Us section if you would like further information regarding our international transfers and the steps we take to protect your personal data when sending it internationally.

5. Marketing activities

From time to time, we may provide you with information about our products or services or those of our partners that we think will be of interest to you. We may send you this information by email, LinkedIn, SMS, text, post or we may contact you by telephone. We may also share your personal data with the Harman Kemp Group of Companies so that they can provide you with information about their products and services we believe will be of interest to you. We ensure that our marketing activities comply with all applicable legal requirements. In some cases, this may mean that we ask for your consent in advance of sending you marketing materials.

You can opt out of receiving marketing communications from us at any time. Please use the “unsubscribe” link in our marketing emails to opt out of receiving those emails. Alternatively, please contact us using the details provided under the Contact Us section. In such circumstances, we will continue to send you service-related communications where necessary.

6. Profiling and automated decision-making

Insurance market participants benchmark insured, beneficiary and claimant attributes and risk factors, and insured event likelihoods in order to determine insurance limits, insurance premiums and fraud patterns. This means that we compile and analyse data in respect of insureds, beneficiaries and claimants to model such likelihoods. In doing so, we use personal and commercial data in order to create the models and/or match that data against the models (profiling) to determine both the risk and the premium price based on similar exposures and risks. We also use this information to help us advise insurance companies about the typical levels of insurance coverage that our clients may have in place.

We will only make automated decisions about you where:

• Such decisions are necessary for entering into a contract (e.g., we may decide not to offer services to you, the types or amount of services that are suitable for you, or how much to charge you for services based on your credit history or financial or related information we have collected about you);

• Such decisions are required or authorised by law (e.g., fraud prevention purposes); or

• You give your consent for us to carry out automated decision-making. You may withdraw your consent at any time by contacting us.

These automated decisions may have a legal or similar effect on you, namely, your eligibility for or access to products or services.

We may also make automated decisions based on your personal data or browsing history to send you personalised offers, discounts or recommendations, subject to any applicable local laws and regulations. These automated decisions will not have legal or similar effects for you.

Subject to local laws and regulations, you can contact us to request further information about our automated decision-making, object to our use of automated decision-making, or request that an automated decision be reviewed by a human being.

7. How long we keep your personal data

We keep your personal data for as long as reasonably necessary to fulfil the purposes set out in this Privacy Notice based on our business needs and legal requirements.

When we no longer need your personal data, we de-identify or aggregate the data or securely destroy it based on our retention policy. Please note that de-identified or aggregated data is not treated as personal data under this Privacy Notice and may be used for analytics purposes.

We have a detailed retention policy that governs how long we hold different types of information. Please contact us using the details provided under the Contact Us section for further information regarding how long we keep your personal data.

8. Your personal data rights

Based on the country in which you reside, and subject to permitted exemptions, you may have certain rights in relation to your personal data. We are committed to respecting your personal data rights. Please refer to your country-specific addendum for information on the rights that apply to individuals in your country.

You can exercise your rights by contacting us using the details provided in the Contact Us section. We will usually not charge you for processing these requests. There may be cases where we are unable to comply with your request (e.g., via a permitted exemption or where the request would conflict with our obligation to comply with other legal requirements). We will tell you the reason if we cannot comply with your request and we will always respond to any request you make.

9. Contact us

Please contact us if you have any questions about how we collect and process your personal data. You may contact us by writing to GlobalPrivacyOffice@ajg.com. To assist in providing you with an accurate response, please let us know that your question relates to Harman Kemp and the applicable country.

10. Updates to this Privacy Notice

We may update this Privacy Notice from time to time. When we make updates, we will post the current version on our Sites and will revise the version date located at the beginning of the Privacy Notice. We encourage you to review this Privacy Notice periodically so that you will be aware of our current privacy practices.

11. United Kingdom Addendum to the Harman Kemp Privacy Notice

Updated: 01 September 2025

This Addendum supplements Harman Kemp’s Privacy Notice and applies to personal data collected and/or processed in the United Kingdom (“UK”).

Purposes and legal grounds of processing

The table below sets out the purposes for which we process your personal data in the UK and the legal grounds on which we rely:

• To perform services for you or our clients: For the performance of contracts to which you will be a party and in order to take steps at your request prior to you entering into those contracts; or for the purposes of legitimate interests pursued by us (to perform and enter into services for our clients).

• To manage our business operations: For the purposes of legitimate interests pursued by us or third parties (to manage and operate our business efficiently and effectively and prevent fraud, financial crime and money laundering).

• To communicate and market to you: For the purposes of legitimate interests pursued by us (to market our products and services to prospective and existing clients). We will ask for your consent where required by applicable law.

• To comply with legal obligations: For compliance with a legal obligation to which we are subject; or for the purposes of legitimate interests pursued by us or third parties (to protect and enforce legal rights).

• To monitor and prevent fraud or wrongdoing: For the purposes of legitimate interests pursued by us or third parties (to detect, prevent and investigate fraud, financial crime, money laundering and other illegal activity).

• To improve our services: For the purposes of legitimate interests pursued by us (to improve our services and maintain quality standards).

• Mergers and acquisitions: For the purposes of legitimate interests pursued by us (to reorganise or restructure our business).

Your rights in the UK

Under UK data protection law, you have the following rights:

• Right of access — to obtain a copy of your personal data.

• Right to rectification — to have inaccurate personal data corrected.

• Right to erasure — to have your personal data deleted in certain circumstances.

• Right to restriction of processing — to restrict how we use your personal data.

• Right to data portability — to receive your personal data in a structured, commonly used and machine-readable format.

• Right to object — to object to the processing of your personal data in certain circumstances, including for direct marketing.

• Rights related to automated decision-making — to not be subject to a decision based solely on automated processing.

You also have the right to lodge a complaint with the UK supervisory authority, the Information Commissioner’s Office (ICO), at www.ico.org.uk.

Data controller

Harman Kemp Limited is the data controller for personal data processed in connection with the services we provide. Harman Kemp Limited is registered with the Information Commissioner’s Office.