Milliman Personal Data Privacy Policy - Argentina

Last updated August 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 Milliman’s and the Argentinian affiliate’s (Fernando Mesquida y Asociados S.A.) use and protect Personal Data that individuals share with us (“Personal Data”), hereafter “you”. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, the Law No. 25,326 the Personal Data Protection Law (“PDPL”), Regulatory Decree No. 1558/2001, as well as any other applicable legal or regulatory provision on the matter issued by the National Secretary for the Protection of Personal Data and/or the Agency for Access to Public Information, and other data protection and privacy laws, as applicable.

Milliman, Inc. and Fernando Mesquida y Asociados S.A. are joint-controllers with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Fernando Mesquida y Asociados S.A. are both responsible for the compliance with applicable data protection laws and therefore fully liable for any Personal Data under the terms of the PDPL and applicable laws of the land on privacy.

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: (i) the website; (ii) each web page; and (iii) 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 you. All processing (i.e., use) of your personal information is justified by a "lawful basis" for processing. In most cases, processing will be justified on the basis that:

• the processing is necessary for the performance of a contract or service to which you are a party, or to take steps (at your request) to enter into them (e.g., where you request certain services as an individual client, or where we help advise your employer or service provider on fulfilling an obligation to you under a contract);
• 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, where we are required to make disclosures to courts or regulators or confirm background checks for anti-money laundering and terrorist financing purposes).

In the context of the collection of data through this website, as well as through Milliman’s marketing activities and contract administration, we may collect, store and otherwise process Personal Data relating to:

• visitors to our websites who request information about products or services. This may include (but is not limited to) your first name, last name, title, company, phone number, location, email address, subject of the request and message given. We collect and process this information because you gave your consent to do so when filling in the applicable consent form (Art. 5.1 of PDPL).
• client representatives, officers, agents and employees, business partners, providers, parties to a contract for contract administration purposes. This may include (but is not limited to) your name, professional address, title, email and other professional contact details. The professional contact details of clients’ representatives, their employees and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to enquiries about our products or services and to provide offers and other information about our products, services, and events that we think may be of interest to you. We collect and process this information because we have a contractual relationship with you (Art. 5.2.d of the PDPL). Milliman may also rely on your consent (Art. 5.1 of the PDPL) for the sending of marketing communications when so required by applicable data privacy legislation, in which case we will ask your consent prior to our sending the communication to you. Milliman may also use the professional contact details of its clients’ employees for the purpose of sending surveys or questionnaires. In all instances, we collect and process this information because we have to manage our relationship with you (Art. 5.2.d of the PDPL) and for the proper administration of our business. We may also collect and process limited Personal Data about you which is collected from public resources including your name, email address, telephone number, organisation, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes (Art. 5.2.a and 5.2.d of the PDPL).

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 those individuals have already consented to or are appropriately informed about the processing of their Personal Data by Milliman, in accordance with the terms of this Privacy Policy.

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 products and services you have requested.

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

In all instances, where the basis for processing your Personal Data is based on consent, you may withdraw your consent at any time.

Affiliates and Authorised 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 Fernando Mesquida y Asociados S.A. 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 centralization 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 privacy protections as may be afforded in Argentina.

However, Milliman ensures that where we do so, for such transfers we obtain contractual commitments (such as the Standard Contractual Clauses) from them in order to protect your personal information or put in place other adequate safeguards to protect your Personal Data.

Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman, located in and outside Argentina. 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.

In all cases, any transfers of Personal Data out of Argentina are subject to appropriate safeguards that are compliant with the PDPL and the local applicable  personal data protection laws.

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 to investigate or to 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 organizational measures in place to protect against unauthorized 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 organizational measures in place to comply with this Privacy Policy and applicable data protection 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 as directed by law. Milliman will delete your Personal Data once the purpose of the collection and processing 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 as for the purposes of complying with a legal obligation). 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 to ensure that such marketing communications are no longer sent to you in the future.

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

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

We do not disclose your Personal Data to these Third-Party Websites without your consent. Note that any information you disclose to Third Party Websites is no longer under our control and no longer subject to this 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. 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 the terms of this 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.

Rights

You have a number of rights under the PDPL in relation to your Personal Data, namely:

1. the right of access pursuant to Art. 14 of the PDPL: 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 and update pursuant to Art. 16 of the PDPL: you may ask us to correct inaccurate Personal Data concerning you and may ask us to update or amend any incomplete Personal Data completed. You can do this by providing a supplementary statement.
3. the right to erasure pursuant to Art. 16 of the PDPL: : you may ask us to delete your Personal Data 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 processing that we may rely on); (c) you object to the processing of your Personal Data and we have no overriding legitimate grounds to continue to process it; or (d) where your Personal Data has been unlawfully processed.

Please note that any processing of your Personal Data which occurs 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 within the legally applicable period.

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.