EMPLOYEE POOLING PRIVACY POLICY

1. Privacy Policy Highlights.

• Effective Date: May 25, 2018.
• Employee Pooling, LLC is a business processing outsourcing center and back-office support company.
• This Privacy Policy applies only to our website, services, and products. It does not apply to other companies or subcontractors that we do not own.
• We collect information in 3 ways. This information is collectively referred to as “Personal Information” in this Privacy Policy:
• Certain information we get automatically when You visit our website;
• Certain information You provide to us voluntarily;
• Certain information You must provide if You want us to provide our services to You.
• Some of the Personal Information that we need to provide services to You includes “Confidential Information”. This could include You, Your agents’, or Your clients’ personally identifiable information; protected health information; personal financial and insurance policy information; credit card details; personal medical history; computer system information; etc.
• We do not sell, share, disseminate, or communicate any of Your Personal Information to any third party. Nevertheless, by consenting and agreeing to this Privacy Policy and the Terms of Service, You acknowledge in advance that we may:
• Communicate Your Personal Information to authorized contractors, agents, or entities with whom we work that allow us to deliver our services to You;
• Use information that may identify You or Your business, but is not Confidential Information or sensitive in nature, for our marketing or advertising purposes; and
• Otherwise communicate Your Personal Information with Your consent as necessary to complete any other transaction or provide any other service You request or authorize.
• If You choose not to provide us with certain Personal Information, You may not be able to take advantage of some or all of the services that we offer. It is impossible to provide many of our services without Your information. You should not use our services if You do not want us to have access to Your Personal Information.
• Our company and security policies maintain ISO/IEC 27001:2013 information security standards, and we can demonstrate our dedication to information security by providing You a copy of our ISO/IEC 20071:2013 certificate upon request.
• About this Document.

Employee Pooling, LLC (“EP”) is a business processing outsourcing center and back-office support company. At EP (“we”, “us”, or “our”), we are committed to maintaining the confidence and trust of all our users and visitors (“You” or “Your”) and safeguarding Your information and privacy. “You” and “Your” may apply where applicable to You as a person; Your business, firm, or agency; and Your customers and agents or anyone in connection with Your customers or agents.

This Privacy Policy explains how we collect, use, and disclose Your Personal Information when You use our website, use our products and services, and interact with us. This document also explains our Terms of Service (called our “Administrative Services Agreement” under certain arrangements), which You agree to when You become our client or begin using our services or products. This online Privacy Policy is provided by the following entities in the Employee Pooling, LLC family of companies:

• Employee Pooling, LLC
• EP Insurance Services
• EP Mortgage Services
• EP Healthcare Services
• EP Legal Services
• Employee Pooling Resources Pvt. Ltd.

This Privacy Policy applies only to our website, services, and products. This document does not apply to the practices of companies or subcontractors that we do not own, or to individuals that we do not employ, manage, or work with, including operators of websites that You may visit before, during, or after visiting our website. We recommend that You view privacy policy statements of any other companies, individuals, or organizations that may interface with EP in order to understand how they may collect, use, and share Your information. If You integrate, or get our assistance with integrating any other online or offline service or software, then You are solely responsible for understanding, abiding by and agreeing to their respective privacy policy statements, terms and conditions.

If You have questions or concerns about anything mentioned in this document or in our Terms of Service, please contact us at the information in Section 13 (“Contact Us”) below.

• About Employee Pooling, LLC.

EP has been organized and doing business since February 2011 as a round-the-clock processing center and back-office support company. As an offshoring business, EP is made up of two offices. The home, administrative office is in Nashville, Tennessee, United States of America. The service office, Employee Pooling Resources, Pvt. Ltd., is a separate legal entity located in Delhi, India that is owned and controlled by Employee Pooling, LLC. These businesses, and any other business in the Employee Pooling, LLC family of companies, are hereby together referred to as “EP” in this document unless stated otherwise.

1. Information We Collect.

The below information from subsections (a), (b), and (c) is collectively referred to as “Personal Information” for the purposes of this Privacy Policy.

• Information We Collect Automatically (Non-personally identifiable information).

When You use our website, You are considered anonymous; we do not engage in any activity that will personally identify You as a website visitors. We collect the following non-personally identifiable information automatically when You use our website.

• The Internet Protocol (“IP”) address of Your computer
• Cookies
• Your location
• Your browser
• Your computer operating system
• Information You Provide to Us (Could include personally identifiable information).

We collect and store any information that You voluntarily provide to us when You directly communicate with us. This information may include, but is not limited to, the items on the following list.

• Your name
• Your e-mail address
• Your phone number(s)
• Your business or home address
• Your credit card information (which we do not store - we use PayPal for credit card transactions)
• Your business team member names and their contact information
• Any other information that you provide
• Information You Provide when You Begin Using Our Services or Products.

When You take steps to or begin to use our products or services, You may provide us sensitive “Confidential Information”. We do not search or mine for this Confidential Information; rather, we will prompt You for this Confidential Information when we need it. We only begin our services and obtain this Confidential Information from You with Your advance consent and permission when You send it to us. You voluntarily give us this Confidential Information so we can deliver our products and services to You and fulfill any obligations we have to You. The nature of our services largely does not permit us to complete our work without using Your Confidential Information.

1. What is “Confidential Information” for the Purposes this Privacy Policy and EP Services?

Confidential Information could be anything and may be necessary for us to deliver our products and services to You. We use the term “Confidential Information” as a collective definition in this document for information that may include, but is not limited to, the items on the following list.

• Personally Identifiable Information (“PII”) that can be used to identify You, Your agents, or Your customers as individuals and be used to locate and contact You or them (g., name, contact information, social security numbers, driver’s license information, contact information and details);
• Personal financial and insurance policy information of You, Your agents, or Your customers (g., credit/debit card information; financial condition; personal financial history; bank account information; beneficiary details; insurance policy owner information; insurance premium, plan and rider information; employer contact information; annual income and net worth; existing insurance policies and replacement policies; agents relationship to clients; contact details and computer application login information; insurance carrier license and contracting identification numbers; tax records or information, etc.);
• Protected Health Information (“PHI”) as defined in the Health Insurance Portability and Accountability Act (“HIPAA”) of 1996 and its related regulations;
• Personal medical history and health information of You, Your agents, or Your customers (g., personal health records);
• Your, Your agents’, or Your customers’ business practices and procedures, and the identity of and information relating to them, and the nature and extent of Your business relationship with any of them;
• Your computer system information, computer codes, software, data, and supporting technical information (g., the IP address of Your computer, cookies, etc.); and
• Any other sensitive information that You provide to us that may be expressly or impliedly necessary for us to provide services for You.

1. How We Use the Information We Collect.

We use Your Personal Information, including the Confidential Information in Section 3(c)(i), to fulfill a variety of business purposes too numerous to completely list here. We use Your Personal Information for such reasons as responding to Your questions and providing You services (e.g., enter the information into your Case Management System or Agency Management System and submit the information to various insurance carriers); provide You with access to certain areas and features of various platforms that use our products or services; purchase history and Your invoices; verify Your identity; communicate with You about Your account and activities with us; create a remote connection to Your computer with Your permission to complete services contracted for; or communicate with You about various company updates and products or services that we think You may be interested in. We do not intentionally communicate with any of Your clients, customers, or agents; rather, only with You or people internally at Your company or organization. If we do otherwise, You may notify us.

1. Sharing of Information.

We do not sell, share, or communicate any of Your Personal Information to any third party. Our Terms of Service includes nondisclosure provisions.

Nevertheless, by consenting and agreeing to this Privacy Policy and the Terms of Service, You acknowledge in advance that we may:

• Communicate Your Personal Information to authorized contractors, agents, or entities with whom we work that allow us to deliver our services to You;
• Use information that may identify You or Your business, but is not Confidential Information or sensitive in nature, for our marketing or advertising purposes; and
• Otherwise communicate Your Personal Information with Your consent as necessary to complete any other transaction or provide any other service You request or authorize.

Examples of authorized agents or entities that we may need to communicate Your Personal Information to include companies we’ve hired to protect and secure our computer systems and services. These companies may need access to Your Personal Information to provide those functions. Other examples of authorized third parties include banks and other entities that process payment transactions or provide other financial services. When You provide payment data to make a purchase, we may share payment data with these institutions for fraud prevention and credit risk reduction. We may also disclose any Personal Information as part of a corporate transaction such as a merger or sale of assets.

Any authorized third parties that we work with must abide by our data privacy and security requirements and are not allowed to use Your Personal Information for any other purpose.

1. Information We Receive from Third Parties.

We may receive information about You from third parties in the industries where we operate such as insurance carriers, mortgage companies, law firms, or other reporting agencies and medical or healthcare providers. If you attend industry tradeshows or conferences or on another website, for example, and opt-in to receive information from us, then these third parties will submit to us Your e-mail address and other contact information about You so that we may contact You as requested. You may also choose to participate in a third-party application or feature (such as one of our Facebook or LinkedIn pages) through which You allow us to collect information about You, including Your name, location, usage information, and personal information, such as “likes” or comments You share.

1. Your Privacy Rights, Choice, and Access.

You control Your Personal Information that You provide to us. However, keep in mind that delivering our products and services to You would not be possible unless we have access to and use Your Personal Information, including the Confidential Information in Section 3(c)(i). If You choose not to provide us with certain Personal Information, You may not be able to take advantage of some or all of the services that we offer. Except as otherwise provided in Section 5 (“Sharing of Information”), we will not sell, share, or communicate any of Your Personal Information with any third party without your consent. If You wish to modify, verify, correct, or delete any of Your Personal Information collected through our products or services, then You may contact us with Your instructions.

In accordance with our routine record keeping and compliance with certain federal privacy laws, we may also manually delete certain records that contain Personal Information that You have submitted to us and certain records containing Your Personal Information may be deleted automatically. We are under no obligation to store such Personal Information and disclaim any liability arising out of or related to the destruction of such Personal Information. We are under no obligation to notify You if and when Your Personal Information is deleted or removed from our records.

It may not always be possible to completely delete or remove all Your Personal Information from our records or databases without some residual data remaining. The reasons for this are that we may be required to keep backups in certain circumstances, and the nature of technology often does not allow a complete removal of all information without a trace remaining. We will retain most Personal Information for as long as we provide service to You. We will also retain and use any and all information necessary to the extent to comply with our legal obligations; resolve disputes; enforce our agreements; and protect our rights, property, and safety.

We do not control certain privacy settings and preferences maintained by social media, like Facebook, LinkedIn, and Twitter. If You wish to make changes to those settings and preferences, You may do so by visiting the settings page of the appropriate social media website.

If You wish to terminate Your contract for services with us or request that we no longer use Your information to provide You services, You may contact us at the information in this Privacy Policy.

1. Advertising; How to Opt-Out.

You may direct us to stop sending You promotional or marketing materials by following the removal instructions in a communication You receive from us or by notifying us at the contact information in this Privacy Policy.

1. Security of Your Information. We are committed to the security, integrity, and privacy of Your information. We must handle sensitive information, like PII and PHI, as defined in HIPAA and its related regulations, to perform services for our customers. As such, we have in place physical, administrative, and technical safeguards to make the protection of Your information a priority in our business dealings. Under certain arrangements where PHI is involved, we will provide You with the appropriate Terms of Service document that also acts as a “Business Associate Agreement” under HIPAA and its related regulations.

EP security policies cover the management of security for both our internal operations as well as our services and apply to all our employees, agents, and contractors. We provide a brochure describing our basic security procedures as a general reference for our prospective and current customers to demonstrate our dedication to a secure environment to protect information. You may request a copy of this security brochure by contacting us.

Our company and security policies maintain ISO/IEC 27001:2013 information security standards, and we can demonstrate our dedication to information security by providing You a copy of our ISO/IEC 20071:2013 certificate upon request. The International Standards Organization (“ISO”) / International Electrotechnical Commission (“IEC”) is a joint standardization subcommittee of the ISO who publishes the ISO/IEC 27001 information security standard. The ISO/IEC 27001 certification demonstrates standards for information technology, security techniques, and information security management systems. The last revision of ISO/IEC 27001 standards were in 2013; hence, the latest standard is titled “ISO/IEC 20071:2013”.

While we take every step to ensure the security of Your information, please note that no electronic data transmission or storage of information is infallible and 100% secure. Therefore, we cannot ensure or warrant the absolute security of any information You transmit to us, and You consent to our services and provide us with Your information with that risk in mind.

1. Dispute Resolution

If You have any complaints regarding our compliance with this Privacy Policy, You should first contact us. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with this Privacy Policy.

1. Changes to this Privacy Policy.

We often evaluate our current security and information processes and may update or change the scope of this Privacy Policy and our Terms of Service to reflect changes to our information practices and evolving technology, laws, and business practices. If we make any material changes, we will notify You by e-mail (sent to the e-mail address specified in your account) or by means of a notice on our website. We reserve the right to amend this Privacy Policy with non-material changes without giving any notice to You, so we encourage you encourage You to periodically review this page for the latest information on our privacy practices.

1. About Our Terms of Service.

Our Terms of Service (called an “Administrative Services Agreement” under certain arrangements) generally includes various provisions that describe in detail the extent and nature of our relationship with You; the term of our relationship; what happens in event of termination of our relationship; nondisclosure provisions; details on dispute settlement, remedies, and limitation of liability; and other representations.

We have different Terms of Service or Administrative Services Agreements depending on our relationship with You and the type of business, firm, or agency that You operate. Under certain arrangements, our services agreements may also act as a “Business Associate Agreement” under HIPAA and related regulations if PHI is involved in our service arrangement with You. Some agreements may also include a rate schedule or additional exhibits or addenda, that describe or explain how we calculate rates and fees in our particular service arrangement with You.

As a user of EP services or products, You must agree to abide by our Terms of Service and all included exhibits and addenda. If you do not agree with our Privacy Policy or Terms of Service, then You should not use our services or discontinue Your use of our services. Agreeing to this Privacy Policy and the Terms of Service and continuing Your use of our services is an indication that you fully agree to everything outlined in this Privacy Policy, the Terms of Service, and any other accompanying documentation.

1. Contact Us.

If You have any questions or concerns about this Privacy Policy, our Terms of Service, or Your experiences with our services, please contact us with the below information:

Employee Pooling, LLC

2000 Glen Echo Road

Suite 111

Nashville, TN 37215

Attn: Matthew Johnson, Associate Counsel

matthew@employeepooling.com

# 615 610 5585 (ex 204)