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Milliman Personal Data Privacy Policy – Milliman S.R.L., Italy

Last updated May 2024

Where Milliman is Acting as a Data Controller

Milliman, Inc. and its affiliates (“Milliman” or “we”) take data privacy very seriously. This Privacy Policy sets out the principles governing the Italian affiliate’s (Milliman S.R.L.) use and protection of personal data that individuals and clients residing within the European Economic Area, the Isle of Man, Switzerland and the UK, share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the EU General Data Protection Regulation (GDPR) and other data protection and privacy laws, as applicable.

Milliman, Inc. and Milliman S.R.L. are joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Milliman S.R.L. are both responsible for the compliance with applicable data protection laws.

Collection of Data

Aggregate Data

Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Milliman’s website.

Cookies, Third-Party Embedded Content and Do Not Track

For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.

Processing of Personal Data

The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data of:

- visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with visitors and the administration of the website. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR).

- clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract (name, professional address, title, email and other professional contact details) for contract administration purposes. The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, including for billing purposes, due diligence and conflict checks, to facilitate the communication, to fulfill requests or respond to inquiries about Milliman products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. The legal basis for the processing of Personal Data is Milliman’s legitimate interest (Art. 6 (1) letter (f) GDPR). Milliman may rely on your consent (Art. 6 (1) letter (a) GDPR) for the sending of marketing communications when so required by data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication. Milliman S.R.L. may also use professional contact details of its clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests. For those activities, the legal basis for the processing of Personal Data is Milliman S.R.L.’s legitimate interest (Art. 6 (1) letter (f) GDPR), unless data protection and privacy laws require your prior consent. We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.

When we communicate with you regarding the products and services we offer or develop, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect your Personal Data for our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you may fill out the applicable form available under the section “Rights”. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.

If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.

You should also ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.

No automated decision-making is undertaken based on the Personal Data collected from you.

Affiliates and Authorized Third-Party Agents

All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman S.R.L. and Milliman, Inc. or other entities controlled by or under common control with Milliman, Inc., located in the U.S. and/or Europe, for the purposes of the centralisation of Milliman’s General Corporate Services, including: administrative services, contract management, Client Relationship Management (CRM), IT-maintenance  and security, data privacy (management of data subjects’ request) and marketing services (cookie management, inquiry tracking via Milliman’s website form, communication regarding Milliman’s products, services, or events).

We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that itself and its affiliates will process Personal Data in compliance with this Privacy Policy.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.

Any transfers of Personal Data are subject to appropriate safeguards that are compliant with the GDPR, as is described in the section “Transfer of Personal Data Across Borders”.

Other Disclosures

Milliman may also disclose Personal Data and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.

Security

Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.

Data Retention

Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited Personal Data (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.

Children

Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should fill out the applicable form available under the section “Rights”, and Milliman will take steps to delete any such Personal Data.

Third-party Links

Milliman’s website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.

We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third-Party Websites is no longer under our control and no longer subject to Milliman Personal Data Privacy Policy.

You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Data to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third-Party Websites is strictly at your own risk.

Policy Updates

Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.

Transfers of Personal Data across National Borders

Milliman is a global company that transfers Personal Data across national borders in compliance with the laws that apply to such transfers. Milliman has put in place appropriate safeguards to ensure its data transfers are adequately protected. Milliman’s legal bases for respective data transfers are outlined in this Privacy Policy. When Personal Data is transferred from one of our entities in the European Economic Area (“EEA”), Switzerland, the Isle of Man or the United Kingdom to the United States or another country outside of the EEA, or from entities in the EEA to another country outside of the EEA, we rely on one or more of the following legal mechanisms which provide adequate safeguards for the transfers: the adequacy decisions adopted by the European Commission on the basis of Art. 45 GDPR, the European Commission-approved Standard Contractual Clauses, the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF), or any other applicable transfer mechanism deemed as adequate by applicable data protection laws. You can request a copy of any standard contractual clauses relating to your Personal Data that we may have executed by contacting us using the details below. Milliman commits to cooperate with the EU data protection authorities, the Swiss Federal Data Protection Information Commissioner, the Isle of Man Information Commissioner, the UK Information Commissioner’s Office and any other relevant data protection authority, and to comply with the advice given by such authorities, with regard to Personal Data transferred from one of our entities in the EEA, Switzerland, the Isle of Man or the United Kingdom, to countries outside of the EEA. Milliman will conduct any necessary impact assessments, following the rules under applicable data protection laws and thus guaranteeing the safe transfer of your Personal Data.

Data Privacy Framework

Milliman is committed to handling Personal Data in accordance with this Privacy Policy and the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF), as administered by the U.S. Department of Commerce. Milliman has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Milliman has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.

If there is any conflict between the terms of this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view Milliman’s certification, please visit https://www.dataprivacyframework.gov/.

Milliman’s accountability for Personal Data that it receives under the DPF Principles and subsequently transfers to a third party is described in the DPF Principles. In particular, Milliman remains responsible and liable under the DPF Principles if third parties engaged by Milliman process the Personal Data in a manner inconsistent with the Principles, unless Milliman proves that it is not responsible for the event giving rise to any damage. Additionally, Milliman, Inc. has put in place data protection agreements with its affiliates located in the European Economic Area based on the EU Standard Contractual Clauses issued by the European Commission (the “EU Standard Contractual Clauses”).

As further explained in the "How to Contact Us" section below, Milliman encourages any individual to contact us should they have a DPF-related (or general privacy-related) complaint. Any right of access, rectification, erasure, restriction of the processing as well as the right to data portability of individuals domiciled in the European Economic Area or Switzerland may be exercised under the conditions set forth in the GDPR by filling out the applicable form available under the section “Rights”. Furthermore, these individuals will have the right to lodge a complaint with a competent supervisory authority at any time.

Rights

  1. the right of access pursuant to Art. 15 GDPR: you have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Data and the manner in which, and the purposes for which we process your Personal Data, so that you can verify its accuracy and the lawfulness of the processing.
  2. the right to rectification pursuant to Art. 16 GDPR: you have the right to obtain from us the rectification of inaccurate Personal Data concerning you, and the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  3. the right to erasure pursuant to Art. 17 GDPR: the right to obtain from us the erasure of your Personal Data without undue delay where (a) your Personal Data is no longer necessary for the purpose for which it was collected/processed; (b) you wish to withdraw your consent to processing (except where we have another legal ground for the processing that we may rely on); (c) where processing is based on our legitimate interests and there are no overriding legitimate grounds for processing; (d) where your Personal Data has been unlawfully processed.
  4. the right to restriction of processing pursuant to Art. 18 GDPR: you have the right to obtain from us the restriction of processing of your Personal Data where (a) the accuracy of such Personal Data is contested by you (for such period as will enable us to verify the accuracy of your Personal Data); (b) the processing of your Personal Data is unlawful, but you do object to the deletion of such data and request restriction of its use instead; (c) you consider that we no longer need your Personal Data for the purposes of the processing, but require such Personal Data for the establishment, exercise or defense of legal claims; (d) you have objected to the processing of your Personal Data on grounds of “legitimate interest” as per (iii) above, pending verification by us on whether our legitimate grounds override your own.
  5. the right to objection pursuant to Art. 21 GDPR: you have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data, which is based on our legitimate interests, including profiling based on those provisions. We shall no longer process the Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. You may object to the processing of your Personal Data or direct marketing purposes at any time, without giving reason.
  6. the right to data portability pursuant to Art. 20 GDPR: you have the right to receive Personal Data concerning you, and which you have provided to us, in a structured, commonly used and machine-readable format, and to transmit such data to another data controller (please note this applies only where our processing of your Personal Data is based on your consent, and the processing is carried out by automated means).
  7. the right to appeal to a competent data protection supervisory authority (Art. 77 GDPR): you have the right to appeal to the competent data protection supervisory authority - in Italy, such authority is the “Garante per la Protezione dei Dati Personali” (www.garanteprivacy.it).

Please note that any processing of your Personal Data prior to the deletion of your account with us, or your request that we no longer contact you for direct marketing purposes will remain valid under the legal grounds then prevailing.

You can exercise any of your rights as stated above, by filling out the applicable form available here. For such requests, Milliman uses the Data Subject Access Request platform of the service provider One Trust. One Trust acts as Milliman’s data processor. You may also send a letter to: Milliman Data Protection Officer, 14 Avenue de la Grande Armée, F-75017 Paris. We will endeavor to respond to any such request as soon as possible, and in any event within 30 days.

How to Contact Us

 Milliman can be contacted at [email protected]. Milliman welcomes feedback and questions on this Privacy Policy. If for any reason you wish to contact us, please send an email ([email protected]). Complaints will be resolved internally in accordance with Milliman’s complaints procedures.

If you live in the European Union, European Economic Area, or Switzerland and you have a complaint regarding the handling of your Personal Data in accordance with the DPF Principles and your efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the American Arbitration Association (http://www.adr.org/), which has been selected as the independent recourse mechanism to resolve complaints and disputes relating to treatment of Personal Data originating in the European Union, European Economic Area, or Switzerland and transferred to the U.S. under this Privacy Policy. Under certain conditions, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted. Milliman is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

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