ProAccess, L.L.C.
Privacy Policy Notice
as of February 5, 2003

PURPOSE OF THIS NOTICE

Title V of the Gramm-Leach-Bliley Act (GLBA) and the laws of the State of New Jersey generally prohibit us from sharing nonpublic personal information about you and your clients with a third party unless we provide you with this notice of our privacy policies and practices, such as the type of information that we collect about you and the categories of persons or entities to show that information may be disclosed. In compliance with the GLBA and the laws of this state, we are providing you with this document, which notifies you of the privacy policies and practices of ProAccess, L.L.C.

OUR PRIVACY POLICIES AND PRACTICES

Information we collect:

ProAccess, L.L.C. may collect personal information about you and your clients to conduct business operations, provide customer service, offer new products, and satisfy legal and regulatory requirements. We may collect the following categories of information about you from these sources:

• information we receive from you on applications or other forms;
• information about your transactions with us, our affiliates or others;
• information we receive from a consumer reporting agency (such as, but not limited to motor vehicle reports)
• information from other non-ProAccess sources (such as prior loss information and demographic information)
  Information we may disclose to third parties:

In the course of our general business practices, we may disclose the information that we collect (as described above) about you or others without your permission to the following types of institutions for the reasons described:

• to a third party if the disclosure will enable that party to perform a business, professional or insurance function for us;
• to an insurance institution, agent, or credit reporting agency in order to detect or prevent criminal activity, fraud or misrepresentation in connection with an insurance transaction;
• to an insurance institution, agent, credit reporting agency for either this agency or the entity to whom we disclose the information to perform a function in connection with an insurance transaction involving you;
• to an insurance regulatory authority, law enforcement, or other governmental authority in order to protect our interest in preventing or prosecuting fraud, or if we believe that you have conducted illegal activities;
• to a group policyholder for the purpose of reporting claims experience or conducting an audit of our operations or services; and
• to an actuarial or research organizations for the purpose of conducting actuarial research studies.

PALLC (2/03)

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 and your clients. 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. The procedures that you must follow to request access to, or an amendment of, your information are as follow:

To obtain access to your information:

You should submit a request in writing to ProAccess,100 Executive Drive, West Orange, NJ 07052. The request should include your name, address, Social Security number, telephone number, and recorded information to which you would like access. The request should state whether you would like access in person or a copy of the information sent to you by mail. Upon receipt of your request, we will contact you within 30 business days to arrange providing you with access in person or the copies that you have requested.

To correct, amend, or delete any of your information:

You should submit a request in writing to ProAccess, 100 Executive Drive, West Orange, NJ 07052. The request should include your name, address, Social Security number, telephone number, the specific information in dispute, and the identity of document or record that contains the disputed information. Upon receipt of your request, we will contact you within 30 business days to notify you either that we have made the correction, amendment or deletion, or that we refuse to do so and the reasons for the refusal, which you will have an opportunity to challenge.

Our practices regarding information confidentiality and security:

We restrict access to nonpublic personal information about you to those employees who need to know that information in order to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with regulations to guard your nonpublic personal information.

Our policy regarding dispute resolution:

Any controversy or claim arising out of or relating to our privacy policy, or the breach thereof, shall be settled by arbitration in accordance with the rules of the American Arbitration Association, and judgment upon the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof.

Reservation of the right to disclose information in unforeseen circumstances:

In connection with the potential sale or transfer of its interest, ProAccess, L.L.C. reserves the right to sell or transfer your information (including but not limited to your address, name, age, sex, zip code, state and country of residency and other information that you provide through other communications) to a third party entity that 1) concentrates its business in a similar practice or service; 2) agrees to be ProAccess L.L.C.'s successor in interest with regard to maintenance and protection of the information collected; and 3) agrees to the obligations of this privacy statement.