Privacy Shield Notice

Milliman is committed to handling Personal Data in accordance with its Privacy Policy, the jurisdiction-specific privacy policies and the EU-U.S. Privacy Shield Framework (or the Swiss-U.S. Privacy Shield Framework, as the case may be), as administered by the U.S. Department of Commerce. There have been recent changes to the EU’s acceptance of the EU-U.S. Privacy Shield Framework’s terms. The European Court of Justice declared the Privacy Shield invalid as a legal mechanism of transfer. However, as of August 20, 2020, the U.S. Department of Commerce’s position is that this European Court of Justice decision does not relieve participants of their obligations under the Framework, and it continues to administer the Privacy Shield program while EU-US discussions on the issue continue. Milliman, as a part of our commitment to privacy and obligations as a privacy shield participant, continues to maintain its commitment to the EU-U.S. Privacy Shield and to adhering to a set of privacy principles that offer strong data privacy protections and recourse for EU residents. A link to the U.S. Department of Commerce’s position on the current state of the Privacy Shield Program can be found here: https://www.privacyshield.gov/article?id=EU-U-S-Privacy-Shield-Program-Update.

If there is any conflict between the terms of the Privacy Policy, the jurisdiction-specific privacy policies and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and to view Milliman’s certification, please visit https://www.privacyshield.gov/list.

Milliman’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Milliman remains responsible and liable under the Privacy Shield 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 where required.

You have certain rights to your Personal Data, including 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 or choose to limit the use and disclosure of your Personal Data. As a reminder, Milliman may 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.

In compliance with the Privacy Shield Principles, Milliman commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Milliman’s European Data Protection Officer at [email protected].

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 EU-U.S. or Swiss-U.S. Privacy Shield Framework and your efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the American Arbitration Association (http://go.adr.org/privacyshield.html), 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. The services of the American Arbitration Association are provided at no cost to you. Under certain conditions, you may be entitled to invoke binding arbitration through the Privacy Shield Panel 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).

As further explained in the "How to Contact Us" section in the Privacy Policy and the jurisdiction-specific privacy policies, Milliman encourages any individual to contact us should they have a Privacy Shield-related (or general privacy-related) complaint.