Benefits Privacy Policy Notice (As of July 1, 2007)

All our employee-owners recognize personal privacy is important to you. Because we are committed to fulfilling your expectations, we have adopted certain safeguards and procedures to assist us in protecting your privacy arising out of your business relationship with us.

Information we collect, retain and use:

We collect nonpublic personal information about you from the following sources:

Applications or other forms you complete;
Your transactions with insurance companies, others; or us
Government agencies and other consumer reporting agencies;
Medical records or medical professionals; and
Personal interviews and inspections

We may collect nonpublic personal information from individuals other than those proposed for coverage. If you authorize us to do so, we may obtain information about you from credit reports or other investigative consumer reports prepared by third parties at our request.

Information we may disclose to third parties:

We may disclose all of the information that we collect about you, as described above, (e.g., we share application information with insurers to whom we apply for insurance on your behalf). Primarily, we disclose such information only to effect, administer or enforce a transaction that you authorize or that is necessary to service your account or your employer’s account. We obtain most of our information directly from you.

We do not provide nonpublic personal information about you to non-affiliated companies for the purpose of independent marketing or for other purposes except as permitted by law.

Your right to access and amend your personal information:

You have the right to request access to the personal information that we record about you. Your right includes the right to know the source of the information and the identity of the persons, institutions, or types of institutions to whom we have disclosed such information within two years prior to your request. Your right includes the right to view such information and copy it in person, or request that a copy of it be sent to you by mail (for which we may charge you a reasonable fee to cover our costs). Your right also includes the right to request corrections, amendments or deletions of any information in our possession. To request access to or an amendment of your information, the following procedures apply:

Submit a request in writing to René Johnson, Corporate Administrator, Thoits Insurance Service, Inc., 444 Castro Street, #200, Mountain View, CA 94041. Or call us, Toll free 1-888-484-6487. The request should include your name, address, social security number, telephone number, and the information to which you would like access. Upon receipt of your request, we will contact you within 30 business days to arrange access. If applicable, we will notify you either that we have made the correction, amendment, or deletion, or that we refuse to do so. The reasons for the refusal and the method to challenge the refusal will be provided where appropriate.

Our practices regarding information confidentiality and security:

We are committed to your personal privacy and use of information about you. We restrict access to nonpublic personal information about you to those employees who need information in order to provide products or services to you or your employer.

Health Clients

THE REMAINDER OF THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW TO OBTAIN ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Statement of Our Duties
We are required by the Health Insurance Portability and Accountability Act of 1996 to maintain the privacy of your personal health information and to provide you with this notice of our privacy practices and legal duties. We are required to abide by the terms of this notice. We reserve the right to change the terms of this notice and to make any new provisions effective to all of the personal health information that we maintain about you. If we revise this notice, we will provide you with a revised notice by mail.
Statement of Your Rights
You have a right to know how we may use or disclose your personal health information. This notice informs you of those uses and disclosures. There are certain uses and disclosures of your personal health information that we are permitted or required to make by law without your permission. For all other uses and disclosures, we first must obtain your permission. In addition, you have the following rights:
1. (beyond what the law requires), but we are not obligated to agree to any such additional restrictions.
2. The right to access, inspect and copy the protected information pertaining to you that we maintain in our files about you, and the right to have us correct or amend any information that we create in error.
3. The right to receive an accounting of the disclosures of your personal health information that we make for purposes other than activities related to your treatment, or our payment functions or other health care operations.
4. The right to request that you receive communications of personal health information in a confidential manner.
5. The right to obtain a paper copy of this notice from us on request.
Permissible Uses and Disclosures of Protected Health Information
1. Payment Functions. We may use or disclose your health information without your permission to carry out activities relating to reimbursing you for the provision of health care, obtaining premiums, determining coverage, and providing benefits under the policy of insurance that you are purchasing. For example, payment functions may include (but are not limited to) reviewing health care services with respect to medical necessity, coverage under the policy, appropriateness of care, or justification of charges.
2. Health Care Operations. We also may use or disclose your protected health information without your permission to carry out certain insurance-related activities. These activities include using your protected information for underwriting, premium rating, or other activities relating to the creation, renewal or replacement of another contract of health insurance, and ceding, securing, or placing a contract for reinsurance of risk relating to claims for health care.
3. Uses Permitted/Required By Law. We also may use or disclose your protected health information without your written permission for purposes permitted or required by law.
4. Authorized Uses. All other uses or disclosures of your protected health information will be made only with your written permission, and any permission that you give us may be revoked by you at any time.
Complaints About Misuse of Health Information
You may complain either directly to us or to the Secretary of Health and Human Services if you believe that your rights with respect to our protection of your health information have been violated. The request should be in writing and include your name, address, social security number, telephone number, and the information concerning your complaint. You will not be retaliated against in any way for filing a complaint.
Contact Person For Filing Complaint or Obtaining Further Information
To file a complaint with us or obtain further information, please submit a request in writing to René Johnson, Corporate Administrator, Thoits Insurance Service, Inc., 444 Castro Street, #200, Mountain View, CA 94041. Or call us, Toll free 1-888-484-6487.

Thoits Insurance Services, Inc.
160 West Santa Clara Street, 12th Floor
San Jose, CA 95113
Phone (408) 792-5400 (Receptionist)
Fax (408) 792-3670
insure@thoits-insurance.com