Effective Date: August 21, 2025

This U.S. Privacy Policy (“Policy”) describes how Hub International Limited, and its subsidiaries listed here (collectively “Hub”) use your “Personal Information” (as defined below) both during and after our direct business relationship with you. This Policy applies to Personal Information that we may from time to time collect, use, and disclose in the course of Hub’s business operations including (1) performing insurance brokerage or other insurance or financial industry services on your behalf, (2) making available our mobile applications and websites, including hubinternational.com, (3) performing insurance, risk management, or employee benefits work on behalf of our Commercial Clients, and (4) contacting us, visiting a Hub location, registering for or attending a Hub event or using other services that link to this Policy. This Policy may be supplemented by additional privacy policies, terms, and notices relevant to the service and provided to you at or before the collection of your Personal Information. We take very seriously our privacy responsibilities to you, and we are committed to treating your Personal Information in a manner that is consistent with applicable law and this Policy. Please read this Policy carefully.

Table of Contents

  1. Updates to Policy, Accessibility of Policy and Regional Differences
    2.
  2. Definition and Exclusions of Personal Information
    3.
  3. Information Hub Collects
    4.
  4. Use of Cookies and Other Web Tracking Technologies
    5.
  5. Use and Disclosure of Personal Information
    6.
  6. Use of Automation for Insurance Quoting
    7.
  7. Your Privacy Rights and How to Exercise Them
    8.
  8. Cookie Choices
    9.
  9. Global Privacy Control (GPC) Signal
    10.
  10. Sales of Personal Information
    11.
  11. Do Not Share or Sell My Personal Information Notice
    12.
  12. Retention of Your Information
    13.
  13. Other Important Website and Mobile Application Information
    14.
  14. Information Hub Processes When Performing Services for Commercial Clients
    15.
  15. Information Security
    16.

1. Updates to Policy, Accessibility of Policy and Regional Differences

Updates to Policy. From time to time, we may change our privacy practices, which will require changes to this Policy. The latest version of this Policy will be posted on our websites, and the date it is effective will be displayed. We encourage you to look for updates and changes to this Policy when you access our websites. Your continued use of Hub’s websites, mobile applications, and services following the posting of changes constitutes your acceptance of such changes with respect to your use of our websites, mobile applications, and services.

Accessibility. If you have special needs with regard to accessing the content of this Policy, contact us at: privacy.compliance@hubinternational.com. Please include the words “Accessibility Issue” in your subject line and explain steps we can take to help you to review and understand this Policy.

Regional Differences. Certain jurisdictions provide enhanced Personal Information rights to residents depending on the jurisdiction and the reason Hub is processing Personal Information.

  1. Notice to California Residents. If you are a California resident, you may have privacy rights in addition to those outlined in this Policy. Due to the specific requirements under California privacy laws, please review the Hub International Privacy Notice for California Residents to learn more about these additional rights.
  2. As of the publication of this Policy, consumer privacy laws have been passed in Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia. These state-level laws give residents privacy rights such as (a) rights to know, access, correct, port (i.e., transfer), or restrict processing of your Personal Information; (b) the right to opt-out of Hub selling your Personal Information; (c) the right to opt-out of certain automated decision-making based upon your Personal Information; and (d) the right to request that Hub delete your Personal Information. These rights, as well as any other rights described in this Policy, can be asserted by visiting the HUB Privacy Request Portal.
  3. Residents of Colorado, Connecticut, Delaware. Iowa, Oregon, Texas, and Virginia have the right to appeal the outcome of a rights request to access, review, delete, or correct Personal Information. Assertions of these appeal rights can be made to: privacy.compliance@hubinternational.com. Please include “Appeal of Outcome” and your state name in the subject line of your email message to initiate the appeal request.
  4. Certain state-level privacy rights may not apply to Personal Information under Hub’s custody or control that is subject to certain federal and state laws regulating insurance or health or financial information.

2. Definition and Exclusions of Personal Information

“Personal Information” means any information that identifies you or can reasonably be linked to you or your household and includes data such as your name, postal address, email address, and telephone number. Due to the nature of our business as described further in the Section called “Information Hub Collects” below, Personal Information handled by Hub about you may also include:

  • your name, Social Security Number, driver’s license, or other government-issued identification;
  • assets and income, occupation, and employment status, dependent information, and other relevant financial information;
  • information relating to any of your past claims, driving history, certifications, license details, previous insurance policy details, previous accident and claims history including any driving convictions;
  • information from reporting agencies and state and federal government agencies, such as state motor vehicle departments;
  • information from other sources, such as medical or health care providers and other third parties with which you or we maintain a relationship including credit reference agencies, vetting and data validation agencies, advisory service providers, insurers, underwriters, reinsurers, business partners;
  • your account activity and premium payment history;
  • benefits information such as benefits elections, pension entitlement information, date of retirement and any relevant matters impacting your benefits;
  • information about your interest in and attendance at Hub sponsored events, including feedback responses;
  • information from social media interactions with Hub’s social media presence, feedback forms or surveys;
  • credit card, bank account or other account information as may be required to facilitate your payment of insurance premium or similar amounts, which payment generally is made through systems maintained by third parties, such as insurance carriers;
  • passive tracking information from our website or the Internet, including information obtained through the use of internet “cookies” as detailed in the “Cookie Choices” section below; and
  • inferences drawn from other Personal Information, precise geolocation data, and sensory data such as audio or visual information.

Personal Information does not include aggregated or anonymous information which does not identify and cannot reasonably be used to identify you or your household. It also does not include other categories of information excluded by state or federal law.

3. Information Hub Collects

We are generally unable to perform insurance brokerage or other insurance or financial industry services on your behalf without collecting, using, or disclosing your Personal Information, including sensitive Personal Information. Typically, you will provide your Personal Information directly to us as your broker, as part of a written application for insurance coverage. Other times, we may receive this and other Personal Information from third parties, including insurance carriers and other industry service providers, and other third parties with which you maintain a relationship (for example, your employer and providers of financial or medical services). We may also develop this information over time based on your direct or indirect interactions with us, such as through the use of cookies on our websites.

Please keep in mind that when you provide information to us on a third-party site or platform, the information you provide may be separately collected by the third-party site or platform. We encourage you to read the privacy policies of other sites and mobile applications that may collect your Personal Information.

When you hire Hub to broker insurance or advise you directly, we collect the amount and types of Personal Information that are required for us to perform or support services you requested. This includes information that may be required by an insurance carrier or an industry service provider in the course of providing you with insurance coverage or related services. If you use our websites, we may collect information about your device, browser and other information regarding your web usage using tracking tools described in this Policy. This information collection could include relevant market research designed to make our products and services better; this and other information may include the Personal Information as defined above. Hub also offers its products and services to organizations that act in the performance of their business or profession (“Commercial Clients”). For instance, if Hub performs insurance-related services for your employer (such as employee benefits, retirement, or risk management services), then Hub may need to collect and handle some of your Personal Information to perform those services. Hub refers to this work as our Commercial Business and in that situation, your employer would be a Commercial Client. In these cases, (1) Hub requires Commercial Clients (such your employer or retirement plan) to have appropriate authorization to provide your Personal Information to Hub, (2) Hub requires the client to provide the minimum amount of your Personal Information necessary for Hub to provide the requested services, and (3) Hub Processes the information pursuant to directions and security safeguards required by Hub’s contract with the client. Please see “Information Hub Processes When Performing Services for Commercial Clients” below for more details.

4. Use of Cookies and Other Web Tracking Technologies

When you visit any website, it may store or retrieve information on your browser, often in the form of cookies. Cookies are files which can store information in your computer hard drive or other devices and help us and our partners to better understand user behavior. We may use cookies and other web tracking technologies such as pixels, web beacons and session recording tools (collectively, “Web Tracking Technologies”) on our websites and mobile applications. Information collected in this manner might be about you, your preferences, or your device; it is primarily used to allow the website to work as you expect it to and to provide a more personalized web experience. This information is also used for security and fraud prevention purposes, to identify which parts of our websites people have visited, to facilitate and measure the effectiveness of advertisements and web searches, and to improve user experiences. We may combine information derived from Web Tracking Technologies with information provided directly by you.

Hub uses different categories of cookies:

  • Strictly Necessary Cookies. These cookies are necessary for the website or application to function and cannot be disabled. They are used where required to provide a specific feature or service that you have accessed or requested and that cannot be provided without the use of such cookies (e.g., actions like setting privacy preferences, logging into your account, or filing form fields). If you set your browser to block these cookies, then some parts of the website may not work.
  • Performance or Analytical Cookies. These cookies allow measurement of website activity by tracking user visits, the geographic location of users, and the volume of users. We use these cookies to help us analyze and count visits and traffic sources so we can measure and improve the performance of our site. For instance, these cookies help us learn which pages are the most and least popular and understand how visitors move around the site. If you do not allow these cookies, Hub will not know when you have visited its website and will be unable to fully monitor the website’s performance.
  • Functional Cookies. These cookies enable the website to provide enhanced functionality and personalization. Some functional cookies may be developed by third party service providers whose services are incorporated into the website. Disabling these cookies may (i) disable third-party services and (ii) impact the overall ease of use of the website or application functionality.
  • Targeting Cookies. These cookies collect information used to understand how visitors interact with our websites and online services. This information helps us: (a) to assess the effectiveness of web searches, (b) to provide you with a more customized experience, and (c) to provide personalized and relevant product offerings and advertisements. Social media cookies are a subset of Targeting Cookies that may share Personal Information you generate on Hub’s website with social network websites and subject your data to those websites’ privacy policies and user terms of service. These cookies may be developed by our advertising partners and collect information that may be used by Hub and its advertising partners to build a profile of your interests and to show you relevant advertisements on other websites. If you do not allow these cookies, you will experience less advertising that is curated to your interests.

5. Use and Disclosure of Personal Information

We generally only disclose your Personal Information to perform services on your behalf and provide you with the insurance products and services you expect from us. In addition, in order to operate our business and provide you with the services you request from us, information technology and other support service providers with which we maintain an arrangement may also have access to your Personal Information. Your Personal Information may be disclosed to third parties in connection with a merger, sale, or other transfer of organizational assets where Personal Information held by us about our clients is among the assets transferred.

We may from time to time disclose your Personal Information for the following reasons:

  • to fulfill or meet the reason you provided the information and for our everyday business purposes, such as to obtain initial and renewal quotations for insurance or other insurance or financial industry services (including those procured proactively and/or in connection with the movement of a book of business from one provider to another) on your behalf; to obtain insurance (or similar products) on your behalf or to facilitate the performance of related services by other industry service providers; to maintain or service your account or insurance, including by reporting claims of loss to other industry service providers, such as insurance carriers and adjusters; to evaluate our performance or offerings; to allow risk management or actuarial evaluation of prospective or existing placements; to confer with medical professionals if necessary regarding a relevant claim; and to make reports to credit bureaus. We may also save your information to facilitate new quotations or placements.
  • for legal reasons, such as to make required or advisable reports to insurance regulatory, law enforcement or other similarly situated authorities including government authorities; to respond to and comply with court orders, applicable law, and other legal requirements; and to defend ourselves against claims and to enforce our rights or protect our employees or property.
  • for our own marketing purposes so that we may offer you our products and services, including using targeted or similar advertising on the internet. You will be given the opportunity to opt out of direct marketing from Hub, and you can change your marketing preferences by contacting Hub as set forth in this Policy.
  • for joint marketing purposes so that we and any third-party product or service provider may together offer you products and services.
  • for our affiliates’ everyday business purposes, such as to process or service transactions or to provide or receive shared organizational services.
  • for our affiliates’ marketing purposes so that they may offer you their products and services using Personal Information, including eligibility information.
  • for our and our affiliates’ fraud prevention purposes where necessary to prevent and detect fraud.
  • for non-affiliated third parties whenever you consent to such sharing, when the information cannot reasonably identify you, when business partners or third-party companies play a related or expected role in an insurance transaction, or as needed for Hub to participate in insurance support organizations. Hub may disclose to its referral partners with whom you already have a relationship certain Personal Information, including (i) campaign performance information such as the e-mail open rates, click rates, unsubscribe rates, and (ii) information about insurance coverage obtained because of the partner’s referral to Hub. This information is disclosed to measure the impact of marketing and outreach campaigns and to calculate commissions.
  • for our internal and external auditors, where necessary for company audits, complaint investigation or investigation of a security threat.
  • for other purposes as may be permitted by law.
  • to evaluate, negotiate or effect a business transaction (e.g., a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets) in which Personal Information held by us about our consumers or website users is among the assets evaluated or transferred.

6. Use of Automation for Insurance Quoting

HUB’s online formats may utilize certain types of automation which assist insurance carrier partners (“insurers”) with their underwriting of insurance. Such automation may result in the use of your Personal Information by the insurer to create predictions about insurance products and premium pricing, and information about insurance carrier market categories that would be appropriate for you. The goal of such an interaction would be for you to receive one or more insurance quotations or estimations of premium and coverage details. Each insurer will have methodologies, including underwriting algorithms, to help with making underwriting decisions. Insurers’ underwriting decisions for insurance coverage, and the use of data for making those decisions, are each subject to the applicable privacy policy and privacy rights request process of that insurer. Your Personal Information is protected and is utilized consistently with the purposes and categories of this Policy, and the intention of our use of this technology is that it operates without improper biases. Based on applicable law, you may have the rights to: (a) opt-out of the processing of your Personal Information by automated decision-making technology that produces a legal or consequential effect, (b) correct inaccurate Personal Information used by automated decision-making technology to make a consequential decision about you, and/or (c) appeal, via human review if technically feasible, an adverse consequential decision concerning you arising from the use of automated decision-making technology. If available in your area, these rights can be exercised through the HUB Privacy Request Portal.

7. Your Privacy Rights and How to Exercise Them

Governments are increasingly granting consumers certain rights regarding their Personal Information. Hub honors requests in accordance with and to the extent required by applicable consumer privacy laws, which may vary depending on where you live. Depending on your state of residence, your rights may include:

  1. Right to Know: You have the right to request that we provide you (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which we collected your Personal Information; (iii) the business or commercial purposes for which we collected, sold, or shared your Personal Information; (iv) the categories of Personal Information we disclosed to Service Providers or third parties for a business purpose and the categories of Service Providers and third parties to whom we disclosed it; and (v) the categories of third parties to whom we sold/shared your Personal Information and the categories of Personal Information sold/shared to each category of third party.
  2. Right to Access: You have the right to access and inspect Personal Information about you or be provided with a copy of the information we hold about you. Hub may take additional steps to verify your identity before it provides access to Personal Information that is sensitive, or the unauthorized disclosure of which could create a substantial risk of potential harm to the subject of the data.
  3. Right to Correct: If you believe that Personal Information about you is inaccurate, then you may request that Hub correct the information. When you make this request, please (i) identify the specific information that you believe is inaccurate, (ii) provide the information that should replace the inaccurate data, and (iii) provide documentation related to your proposed correction. We will correct the information if we determine, based on the totality of the circumstances, that the correction you requested is more likely than not accurate. Hub may decide to delete the allegedly inaccurate information instead of correcting it.
  4. Right to Deletion: You have the right to request that we delete Personal Information we collected about you. Under applicable consumer privacy laws, Hub is not required to honor a deletion request in certain situations, such as where Hub needs to maintain the information to: (i) complete a requested or reasonably anticipated transaction, (ii) prevent security incidents or fraud, (iii) comply with litigation holds and establish, exercise, or defend legal claims, and (iv) comply with Hub’s regulatory and licensing obligations.
  5. Data Portability: You have the right under the laws of certain jurisdictions to request that Personal Information about you be provided in an electronic format to you or a third party of your choice.
  6. Disclosing the Recipients of Personal Information: Consumers in certain jurisdictions have the right to request that Hub disclose to them the categories of third parties to whom Hub has disclosed their Personal Information. In limited jurisdictions, Hub may be required to provide you with a list of specific third parties that have received Personal Information about you.
  7. Right to Restrict Processing/Right to Limit Use and Disclosure of Sensitive Personal Information: Some jurisdictions allow you to request that Hub limit the use of your Sensitive Personal Information to only certain specified purposes such as (i) providing to you the goods and services you reasonably expect, (ii) complying with legal obligations, exercising legal claims or rights, and defending legal claims, (iii) preventing security incidents or fraud, or (iv) verifying or maintaining the quality or safety of goods or services we provide. Other jurisdictions require Hub to obtain your consent to process Sensitive Personal Information about you; the definitions of Sensitive Personal Information vary by jurisdiction. Hub processes these types of requests subject to any exceptions permitted by law. If you reside in a jurisdiction that requires us to obtain your consent before processing Sensitive Personal Information on your behalf, Hub may take additional steps to contact you before treating your request as a revocation of consent to avoid unintended consequences, such as the cessation of processing your Personal Information for a Hub product or service that you requested. You may choose to withdraw your consent at any time; however, we may be unable to provide the product or service you requested without the necessary information.
  8. Right to Opt-Out from the Sale or Sharing of Personal Information/Do Not Sell or Share My Personal Information Request: You have the right to direct us to not sell or share for marketing and/or targeted advertising purposes your Personal Information with affiliates or non-affiliates. We will process requests subject to any applicable exceptions and extensions permitted by law.
  9. Right to Opt-Out of Automated Decision-Making and Profiling: Consumers in certain jurisdictions have the right to direct Hub to not process their Personal Information for automated decision-making or profiling that produces legal or other consequential effects. For instance, Hub and its insurance carrier partners may conduct assessments using models and information technology solutions: (i) to determine whether you are eligible to receive the insurance-related product or service you requested and (ii) to calculate your premiums. This process may involve information about your behaviors or making calculated predictions about you which are related to the product or service you requested. If you exercise this right prior to the application process, Hub may not be able to process your application for a product or service.
  10. Opt-Out of Hub Sharing Creditworthiness Information with Hub Affiliates: You may request that Hub not share with its affiliates information that bears on your eligibility for credit or insurance, including information about your credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living. This opt-out right does not extend to the sharing of (i) information about first-hand transactions or experiences between you and Hub, or (ii) opinions based solely upon those first-hand transactions or experiences.
  11. Opt-Out of Receiving Marketing Communications from Hub via Email: You have the right to unsubscribe from receiving communications of a marketing nature from Hub via email.
  12. Opt-Out of Receiving Automated Phone Calls and Text Messages from Hub: You have the right to request that Hub refrain from calling you or sending text messages to you using automated dialing systems.
  13. Right to Appeal: If we deny, in full or in part, your request to exercise a privacy right, and if you live in a jurisdiction that affords you the right, you may appeal Hub’s decision. To initiate an appeal, send an email to privacy.compliance@hubinternational.com that includes in the subject line the phrase “Privacy Appeal” and your state of residence; in the body of the email, please identify the decision you are appealing and the grounds of your appeal. If Hub denies your appeal, you may contact your state Attorney General to inquire about additional appeal rights.
  14. Right of Non-Discrimination: You have the right to not be discriminated against for exercising your privacy rights.

To exercise any of these privacy rights, to make a related request, or to ask any question concerning this Privacy Policy, please contact us via any of the following methods:

Please include your name, address, telephone number, and email address whenever you contact us. Depending upon the nature of your request, Hub may require you to provide additional information to verify your identity and authority to access or direct the processing of the Personal Information that is the subject of the request. Hub may deny certain privacy requests with respect to your Personal Information if we cannot verify your identity. You may also use an authorized agent to submit a request to exercise your privacy rights on your behalf. If you have an authorized agent submit a request on your behalf, Hub will require (i) you to provide the authorized agent with written permission to act on your behalf, and (ii) your agent to verify their identity directly with Hub. Hub may deny a privacy-related request from an agent that does not meet these requirements.

Situations Where Rights Cannot Be Granted. There may be situations where we cannot grant a particular request — for example, if you ask us to delete your transaction data but we are legally obligated to keep a record of that transaction to comply with law or if we are unable to verify your identity through standard and reasonable means. We may also decline to grant a request where doing so would undermine our legitimate use of data for antifraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied could be that granting the request would jeopardize the privacy of others; that the request is substantively frivolous or vexatious; or that granting the request would be highly impractical in the context of our legitimate business purposes. If we are unable to fulfill your privacy request to access, review, delete or correct your Personal Information, we will provide you with an explanation

8. Cookie Choices

Hub gives you the ability to opt-out of cookies that are not essential to the services of the Hub-controlled websites and applications you use. This option is presented by Hub’s Cookie Preference Center when you visit our websites (i) for the first time and (ii) after you clear your browser cache.

Your computers or devices also have tools within their browsers that allow you to manage your acceptance of cookies. These can include the ability to disable or block non-essential cookies, remove cookies, automatically accept cookies, or notify you when a cookie is received. Refer to “https://allaboutcookies.org/how-to-manage-cookies” for detailed explanations by browser (e.g., Google Chrome). Generally, disabling or rejecting cookies can negatively impact your user experience (e.g., because certain features of our website may not be available).

Hub uses both Adobe and Google as website service providers. To learn about Adobe Analytics privacy practices or to opt-out of Adobe cookies which are used to facilitate reporting, visit Adobe Privacy Center. To learn more about Google’s privacy practices, visit the Google Privacy Center. To access and use the Google Analytics Opt-out Browser Add-on, visit Google Opt-out.

9. Global Privacy Control (GPC) Signal

In certain jurisdictions, you have the right to opt-out of the use, sharing, and sale of your Personal Information for targeted advertising purposes by broadcasting an opt-out preference signal, such as the Global Privacy Control (“GPC”), on browsers or extensions that support the GPC signal. A list of GPC-enabled available browsers or extensions is available here: https://globalprivacycontrol.org/#download. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use. Your request to opt-out will be linked to your browser identifier only. For more information about how to opt-out of the sale or sharing of your Personal Information, see the “Do Not Share or Sell My Personal Information Notice” below.

10. Sales of Personal Information

In the preceding twelve (12) months, we have shared information for cross-contextual behavioral advertising or targeted advertising purposes which might be considered a “sale” of Personal Information as defined by the laws of some jurisdictions. Hub does not knowingly sell the Personal Information of minors.

11. Do Not Share or Sell My Personal Information Notice

Notice of Right to Opt-out of Sharing: In an increasing number of jurisdictions, you can request that Hub not: (a) sell your Personal Information, (b) share it with third parties for cross-context behavioral advertising purposes, or (c) process it for targeted advertising purposes.

To exercise your rights to opt-out of Hub selling or sharing your Personal Information for cross-context behavioral advertising purposes and/or processing it for targeted or personalized advertising purposes, take the following steps:

  1. You can opt-out of certain forms of online sale, sharing, or targeted advertising by turning off non-essential cookies and tracking tools. To do so, interact with Hub’s cookie consent tool (upon your first visit or by clicking the cookie settings icon) and disable non-essential cookies. Alternatively, you can utilize the GPC Signal; Hub’s websites respond to universal opt-out preference signals, including the GPC, to the extent required by law.
  2. To opt out of other kinds of sale, sharing, or targeted advertising, such as “offline” uses of Personal Information to support marketing campaigns, you must also complete and submit an opt-out request via the Hub Privacy Request Portal

Effect of Opting-Out: Your cookie selections are specific to the device, website, and browser you’re using, and your selections are deleted whenever you clear your browser’s cache. If you use another device or browser, you will need to opt-out on each device and browser. Blocking or clearing cookies from your browser may remove your opt-out settings, requiring you to opt-out again. After you have opted-out, you may still see advertisements for Hub’s products and services because not all advertisements are placed using cookies or Personal Information. For example, you may see contextual ads online such as those based on the topic and content of a webpage you visit; some advertisements published to third party websites are simply made visible to all visitors to that website.

12. Retention of Your Information

Hub retains certain records of your Personal Information as necessary to operate our business and comply with our legal and regulatory obligations. Such records are retained for legally defined retention periods that may extend beyond the period for which we provide the Services to you or to our Commercial Clients. We have implemented appropriate measures to confirm that Personal Information is securely disposed of when no longer required.

13. Other Important Website and Mobile Application Information

Our website contains links to third party sites. If you click on one of those links, you will be taken to websites we do not control. This Policy does not apply to the information practices of those sites. You should read the privacy policies of those other websites carefully. We are not responsible for those third-party sites. Links to third party sites do not constitute or imply endorsement by us of the linked site or any material displayed on those sites.

To the extent that Hub provides mobile application access for your use, please note that your Personal Information may be collected. In addition to being subject to this Policy, your use of a downloaded application provided by Hub may also be subject to the privacy terms and conditions of the providers and developers of the application. Hub may have access to and utilize certain data collected by such providers or developers. Hub may utilize such data to better service your account, to improve the performance of the application, as well as for the other purposes set forth in this Policy.

Hub websites are not intended for children under 13 years of age. No one under age 13 may provide any information through our websites, and we do not knowingly collect Personal Information from children under thirteen. If you are under thirteen, do not use or provide any information on this website or otherwise provide any information about yourself to us, including your name, address, telephone number, email address, or any screen or username you may use. If we learn we have collected or received Personal Information from a child under thirteen without verification of parental consent, we will use commercially reasonable efforts to delete that information. If you believe we might have any information from or about a child under thirteen without parental consent, please contact us at the mailing address shown beneath the heading “Your Privacy Rights and How to Exercise Them.”

14. Information Hub Processes When Performing Services for Commercial Clients

When Hub provides services to its Commercial Clients, Hub may collect, from the client, information about the client’s business operations and Personal Information about you and your relationship with that client. For example, Hub offers services to employers and retirement plans, among others. During the course of providing these services, Hub (i) is informed that you are the client’s employee or plan’s participant, and (ii) receives Personal Information about you including, your name, contact details, date of birth, gender, marital status, certain financial information (like premiums you paid), employment details, benefit coverage, and other types of data described in the “Definition And Exclusions of Personal Information” and “Information Hub Collects” sections above. Hub may also collect data from public information sources including social media and other websites, government agencies, third-party service providers, and business partners. When Hub processes this information, it does so as the Commercial Client’s data processor and only handles the Personal Information to provide its services to the Commercial Client. Accordingly, if you submit to Hub a Data Subject Access Right (“DSAR”) Request (e.g., if you seek to exercise your privacy rights to access, correct, or delete Personal Information about you) concerning information provided to Hub by a Commercial Client, Hub will notify you that you must submit your DSAR Request directly to the Commercial Client.

15. Information Security

We maintain technical and organizational security measures reasonably designed to protect the security of your Personal Information against loss, misuse, and unauthorized access, disclosure, or alteration. Hub International Limited and its affiliates take steps to secure your Personal Information with appropriate levels of security around storage and use. Despite this, the security of information cannot be guaranteed. If you have reason to believe that your Personal Information maintained by us is no longer secure, please immediately notify us utilizing the contact information set forth above. In the event of a breach impacting your Personal Information, we intend to provide you with notification to the extent required by applicable law.