Stroz Friedberg, LLC, Gotham Digital Science, LLC, Lightbox Technologies, Inc., Stroz Friedberg Electronic Discovery, Inc., Stroz Friedberg Investigations, LLC, WT Government Services, LLC, Aon Global Risk Consulting, a dba of Aon Risk Consultants, Inc.; and Financial & Professional Risk Solutions, each an Aon company and collectively hereafter “Aon’s Cyber Solutions” or “Aon’s Cyber Solutions Group”, is a risk management firm specializing in cyber security risk and response, investigations, electronic discovery and disclosure, cyber insurance broking, and due diligence and strategic research. Aon Cyber Solutions is committed to protecting your privacy. This commitment reflects the value we place on earning and keeping the trust of our clients, business partners, and others who share their personal information with us.
What does this Privacy Notice do?
This Privacy Notice (“Notice”) explains Aon’s Cyber Solutions’ information processing practices. It applies to any personal information you provide to us and also personal information we collect from other sources. This Notice 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 Notice does not apply to your use of any third party site which may be linked from this website.
If you have a disability and require an alternative format to this privacy notice, please email us at: firstname.lastname@example.org so that we may provide you with a more suitable format.
Who is responsible for your information?
Throughout this Notice, “Aon’s Cyber Solutions” refers to Stroz Friedberg, LLC; Aon Global Risk Consulting, a dba of Aon Risk Consultants, Inc.; and Financial & Professional Risk Solutions, including its affiliated companies and subsidiaries (also referred to as “we”, “us”, or “our”). Aon’s Cyber Solutions is responsible for your personal information (and in some instances the controller for the purposes of data protection laws) that we collect from or about you.
Stroz Friedberg has certified to the EU-U.S. Privacy Shield Framework, as well as the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively.
When and how do we collect your information?
We collect personal information in the following ways:
- When we perform services for our clients.
- When you request a service from us.
- When you use any of our websites or applications.
- When you attend an Aon’s Cyber Solutions event.
- When you apply for a position at Aon’s Cyber Solutions.
- If you contact us with a complaint or query.
- When you engage with us over social media.
For specific information on the source for each category of personal information collected, please see the section titled “Categories of personal information we may collected, disclose, and “sell” (as defined under applicable law” below.
What information do we collect?
In general, we collect personal information about you that you provide to us, that we receive from third parties or that we indirectly collect or infer about your activities or usage of our websites, apps or services. The actual personal information we collect about you varies depending upon the nature of the services and our interactions for you.
Information you provide to us
When you contact us to request information about Aon’s Cyber Solutions or our services, we ask that you provide accurate and necessary information that enables us to respond to your request. Whenever you provide personal information to us, we use it for the purposes for which it was provided to us as stated at the point of collection or as obvious from the context of collection, for example: information required for payment or invoicing, applying for a position with us, updating you regarding the services you have requested from us or creating a profile on our website or application.
More information about the categories of personal information collected for each of our services, together with the purpose and legal basis for collecting the information is provided below.
We will not knowingly collect any sensitive personal information unless this is required. Sensitive personal information includes a number of types of data relating to: race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life.
If you provide us with sensitive personal information, you understand and give your explicit consent that we may collect, use and disclose this information to appropriate third parties for the purposes described in this Notice. If you provide personal information about other individuals such as employees or dependents, you must obtain their consent prior to your disclosure to us.
Information we collect over Aon websites, mobile applications and social media.
We may ask you for personal information, such as name and contact information, when you register for events, request services, manage accounts, access various content and features or directly visit our websites. (For purposes of this Notice, “website” includes our mobile applications.)
Social media. You can engage with us through social media websites or through features such as plug-ins or applications on our websites that integrate with social media sites. You may also choose to link your account with us to third party social media sites. When you link your account or engage with us on or through third party social media sites, plug-ins, or applications, you may allow us to have ongoing access to certain information from your social media account (e.g., name, e-mail address, photo, gender, birthday, the posts or the ‘likes’ you make).
Mobile devices. If you access our websites on your mobile telephone or mobile device, we may also collect your unique device identifier and mobile device IP address, as well as information about your device’s operating system, mobile carrier and your location information. We may also ask you to consent to providing your mobile phone number (for example, so that we can send you push notifications).
Categories of personal information we may collect, disclose, and “sell” (as defined under applicable law).
The types and categories of personal information we collect about you depends on the nature of the services we provide to you and our interactions with you. Additionally, we may disclose personal information to third parties and services providers for the purposes identified below.
In general, we do not disclose or share personal information to third parties in exchange for their monetary payment to us. However, certain laws including the California Consumer Privacy Act (“CCPA”) define “sale” broadly to include disclosing or making available personal information to third parties in exchange for monetary payment or some other thing of value. For purposes of the CCPA, we may disclose or make available personal information in order to receive some benefit or value (i.e., a “sale” under the CCPA).
Aon has collected the following categories of personal information from consumers within the last twelve (12) months:
|Category||Examples||Collected||Disclosed for Business Purposes||Sold|
|A. Contact Information and Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES||YES||NO|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, health insurance information, or benefits information. Some personal information included in this category may overlap with other categories.||YES||YES||NO|
|C. Protected classification characteristics under California or federal law.||Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES||YES||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES||YES||NO|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||YES||YES||NO|
|F. Internet or other similar network usage activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES||YES||NO|
|G. Geolocation data.||Precise physical location or movement. Data about a particular individual or device.||YES||YES||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||YES||YES||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES||YES||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||YES||YES||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES||NO||NO|
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- opersonal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
How do we use your personal information?
The following is a summary of the purposes for which we use personal information. More information about the personal information collected for each of our services, together with the purpose and legal basis for collecting the information will be provided to you below.
Performing services for our clients
We process personal information which may be in data sets our clients provide to us in order to perform our professional consultancy and risk based advisory services. This may impact you, for example, where you are the employee of our client, or the legal representative of a client. The precise purposes for which your personal information is processed will be determined by the scope and specification of our client engagement, and by applicable laws, regulatory guidance and professional standards. It is the obligation of our client to ensure that you understand that your personal information will be disclosed to Aon’s Cyber Solutions (or to service providers such as Aon’s Cyber Solutions).
The categories of information we use to perform our services include: name, contact and identifiers, customer records, protected classifications, purchase history and tendencies, usage data, audio/visual data, employment history, educational information, profiles and inferences, or sensitive data.
Administering our client engagements
We process personal information about our clients and the individual representatives of our corporate clients in order to:
- carry out “Know Your Client” checks and screening prior to starting a new engagement;
- carry out client communication, service, billing and administration;
- deal with client complaints;
- manage workflow internally.
The categories of information we use to administer our client engagements include: name, contact and identifiers, customer records, protected classifications, purchase history and tendencies, usage data, audio/visual data, employment history, educational information, profiles and inferences, or sensitive data.
Contacting and marketing our clients and prospective clients
We process personal information about our clients and the individual representatives of our corporate clients in order to:
- contact our clients in relation to current, future and proposed engagements;
- send our clients newsletters, know-how, promotional material and other marketing communications;
- invite our clients to events (and arrange and administer those events);
- improve the content of our website to ensure it is suitable to your needs; and
- measure the effectiveness of our marketing activities.
The categories of information we use to contact and market to our clients and prospective clients include: name, contact and identifiers, customer records, purchase history and tendencies, usage data, employment history, profiles and inferences, or sensitive data.
Conducting data analytics
We are an innovative business, which relies on developing sophisticated products and services by drawing on our experience from prior engagements. We are not concerned with an analysis of identifiable individuals, and we take steps to ensure that your rights and the legitimacy of our activities are ensured through the use of aggregated or otherwise de-identified data. The categories of information we use to conduct data analytics include customer Records, Purchase History and tendencies, Usage data, Geolocation Data, or Profiles and Inferences,
If we wish to use your personal information for a purpose which is not compatible with the purpose for which it was collected for, we will request your consent. In all cases, we balance our legal use of your personal information with your interests, rights, and freedoms in accordance with applicable laws and regulations to make sure that your personal information is not subject to unnecessary risk.
All processing (i.e. use) of your personal information is justified by a “lawful basis” for processing. In the majority of cases, processing will be justified on the basis that:
- the processing is necessary for the performance of a contract to which you are a party, or to take steps (at your request) to enter into a contract (e.g. where we use personal information to generate user credentials for you or your legal representative to access and review your data on our electronic discovery and disclosure platform);
- the processing is necessary for us to comply with a relevant legal obligation (e.g. where we are required to collect certain information about our clients for tax or accounting purposes, or where we are required to make disclosures to courts or regulators); or
- the processing is in our legitimate commercial interests, subject to your interests and fundamental rights (e.g. where we use personal information provided to us by our clients to deliver our services, and that processing is not necessary in relation to a contract to which you are a party).
In limited circumstances, we will use your consent as the basis for processing your personal information, for example, where we are required to obtain your prior consent in order to send you marketing communications.
Before collecting and/or using any personal information, or criminal record data, we will establish a lawful basis which will allow us to use that information. This basis will typically be:
- your explicit consent;
- the establishment, exercise or defense by us or third parties of legal claims; or
- a context specific exemption provided for under local laws of EU Member States and other countries implementing the GDPR, such as in relation to the processing of personal data for insurance purposes, or for determining benefits under an occupational pension scheme.
Do we collect information from children?
We do not directly provide services to children, and we do not knowingly collect personal information from children.
How long do we retain your personal information?
How long we retain your personal information depends on the purpose for which it was obtained and its nature. We will keep your personal information for no more than the time required to fulfil the purposes described in this privacy notice unless a longer retention period is permitted by law. We have implemented appropriate measures to ensure your personal information is securely destroyed in a timely and consistent manner when no longer required.
In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
Do we disclose your personal information?
We may share your personal information with other Aon entities, brands, divisions, and subsidiaries to serve you, including for the activities listed above.
We do not rent, sell or otherwise disclose personal information 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.
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.
- 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
The categories of information shared with our business partners include Name, contact and identifiers, customer Records, Purchase History and tendencies, Usage data, Geolocation Data, Employment History, Educational Information, Profiles and Inferences, or Sensitive data.
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 we use 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. These activities could include any of the processing activities that we carry out as described in the above section, ‘How we use your personal information.’
- IT service providers who manage our IT and back office systems and telecommunications networks;
- marketing automation providers;
- contact center providers.
- subject matter experts retained to support a client engagement.
These third parties appropriately safeguard your data, and their activities are limited to the purposes for which your data was provided.
The categories of information shared with our authorized service providers include Name, contact and identifiers, customer Records, Purchase History and tendencies, Usage data, Geolocation Data, Employment History, Educational Information, Profiles and Inferences, or Sensitive data.
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 we are subject to a merger or acquisition to the new owner of the business, or in the event of the dissolution of our 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 our, 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 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 or by our certification to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks;
- where we transfer your personal information outside of us 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, Canada, India and Switzerland.
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 have security measures in place to protect your information?
The security of your personal information is important to us and we have implemented reasonable physical, technical 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.
What choices do you have about your personal information?
We offer certain choices about how we communicate with our customers and what personal information we obtain about them and share with others. When you provide us with personal details, if we intend to use those details for marketing purposes, we will provide you with the option of whether you wish to receive promotional email, SMS messages, telephone calls and postal mail from us.
You may also choose not to receive marketing communications from us by clicking on the unsubscribe link or other instructions in our marketing emails, visiting the My Account section on our applications, or contacting us as noted below.
In addition, you may have the right to “opt-out” of any sale of your personal information by us, as explained in the “Other rights” section below.
How can you update your communication preferences?
We take reasonable steps to provide you with communication about your information. You can update your communication preferences in the following ways.
If you have created a profile or account on one of our websites or applications, you can update your contact information after you log into your account.
If you request electronic communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in the communication.
If you previously chose to receive push notifications on your mobile device from us but no longer wish to receive them, you can manage your preferences either through your device or the application settings. If you no longer wish to have any information collected by the mobile application, you may uninstall the application by using the uninstall process available on your mobile device.
Contact us by e-mail or postal address as noted below. Please include your current contact information, the information you are interested in accessing and your requested changes.
If we do not provide you with access, we will provide you with the reason for refusal and inform you of any exceptions relied upon.
Other rights regarding your data
Data protection laws vary among countries, with some providing more protection than others. Subject to certain exemptions, and in some cases, particularly if you reside in a jurisdiction with applicable privacy laws, dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information.
Right to Access
You have right to access personal information, and the categories thereof, which we hold about you. If you have created a profile, you can access that information by visiting your account or making a request online or by phone (as provided below).
Right to Rectification
You have a right to request us to correct your personal information where it is inaccurate or out of date.
Right to be Forgotten (Right to Erasure)
You have the right to request under certain circumstances to have your personal information erased. Your information can only be erased if your data is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the data.
Right to Restrict Processing
You have the right to restrict the processing of your personal information, but only where:
- its accuracy is contested, to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want it erased; or
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
Right to Data Portability
You have the right to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party.
Right to Object to Processing
You have the right to object the processing of your personal information at any time, but only where that processing is or has our legitimate interests as its legal basis. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
We do not sell your personal information without your prior consent.
As noted above, you can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.
If applicable, how do you exercise these rights?
You can exercise your rights by contacting us at email@example.com or by calling +1.877.384.4276 (toll free). Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfill your request.
To verify your identity, please be prepared to offer the following information: your name, date of birth, and any other information you have previously provided to Aon. We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You may also be able to designate an authorized agent to make a request regarding these rights on your behalf. If you would like to do so, please have your authorized agent use the contact email or number above and state within their request they are your authorized agent. If needed, Aon will inform the authorized agent of any additional verification data needed to process such request at that time.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Discrimination: If consumers exercise their rights under CCPA, businesses may not discriminate against them, such as by denying or providing a different level or quality of goods or services or charging or suggesting that a business will charge different prices or rates or impose penalties (unless doing so is reasonably related to the value received from the consumer personal information).
Disclosure of Incentives: If businesses offer any financial incentives for the collection, sale or deletion of their personal information, consumers have the rights to be notified of any financial incentives offers and their material terms, as well as the to not be opted into such offers without prior informed opt-in consent and to be able to opt-out of such offers at any time. Businesses may not offer unjust, unreasonable, coercive or usurious financial incentives. We do not offer any incentives at this time.
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 law or this Privacy Notice, please contact the Privacy Officer: firstname.lastname@example.org or call +1.877.384.4276 (toll free). Alternatively, you have the right to contact your local Data Protection Authority.
If you have any questions relating to this Notice, please contact us at the Aon Global Privacy Office, Aon plc, 200 E. Randolph, Chicago, Illinois 60601 or email@example.com.
Changes to this Notice
We may update this Notice 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 Notice so that you will be aware of our privacy practices.
This Notice was last updated on August 20, 2020.