COMMON CENSUS GENERAL POLICY STATEMENT

The policy of Common Census, Inc., (“We”, “Us” or “Common Census”) is to respect and protect the privacy and confidentiality of the information conveyed to Common Census by employers/governments/associations/unions, brokers and agents who use Common Census services, software and Internet tools. We will take such commercially reasonable actions as may be required under the circumstances to preserve the confidentiality of any information a client identifies as being proprietary and confidential in nature.

By its nature, employee/individual benefits administration requires confidential employee/individual data. This includes employee/individual contact information (e.g. name, address, email), unique identifiers (e.g. social security number, employee/individual ID), dependent information (e.g. names and ages of a spouse and children), financial information (e.g. income, insurance limits, account numbers, the cost of benefit elections), and demographic data (e.g. zip code, age, income). Common Census and the employer/government/association/union define the source and update protocol for each data element. Common Census intends to collect, retain, and disclose Personal Information only on a “need to know” basis.

Vendor Privacy Policies

The insurers, financial service providers and other providers and suppliers of goods and services who are represented by Common Census and/or with whom our Producers may transact business using Common Census software and Internet Sites (collectively, the “Vendors”) will have privacy policies in effect from time to time that are applicable to, and intended for the benefit of, the ultimate purchasers of the products and services offered or supported through Common Census and the Producers (“Vendor Privacy Policies”). Common Census will use commercially reasonable efforts to convey the Vendor Privacy Policies to the Producers.

Aggregate Statistics

Common Census gains the consent of the employer/governments/associations/unions or employee/individual prior to using information in any manner other than defined below, and prior to knowingly disclosing Personal Information to a third party. Common Census uses Personal Information to: Administer and / or market the benefits program to providers (e.g. insurance carriers) as authorized by the employer/government/association/union; Aggregate Data; Generate reports authorized by the employer/government/association/union; and Provide services an employee/individual requests.

Data Security

Confidentiality is a major concern with any online system. Accordingly, several precautions have been taken to ensure that information is kept protected at all times. All information sent to and from Common Census Internet applications is encrypted using a combination of 128-bit secured socket layer (SSL) technology, digital certificates, and firewalls. These security features work together to provide users with a mutually authenticated communications path. Mutual authentication helps to ensure that only legitimate users can access the system, and that legitimate users see only the information they are intended to see.

Cookies and IP Addresses

A cookie is a small file, stored on your hard disk, sent to your browser from a web server. Common Census uses cookies to track your web session as you use the site, and the process of logging off deletes the cookie. Common Census uses the cookie to be sure your data goes to your PC, not somewhere else. Common Census does not put extraneous data in a cookie, and does not attempt to read other cookies on your PC. The website may provide erratic results if you choose to disable cookies on your browser. It is your responsibility to log off the Common Census site when you have finished using it, to delete the cookie from the PC after each user session. Employers/governments/associations/unions, Insurance brokers/agents or Employees/individuals may choose to transmit Personal Information to websites controlled, owned, or operated by third parties, including insurance carriers. In this situation, the privacy statements of those third parties govern their use of this information, not this Privacy Statement. Account Access and Passwords Each registered user of Common Census Internet Tools and software will be assigned a password in order to access that user’s account and account information. It is the user’s responsibility to protect and preserve the confidentiality of the user’s password. Common Census will not be responsible for any loss resulting from unauthorized access to a user’s account.

Password

A PASSWORD SHOULD NEVER BE GIVEN TO ANY PERSON WHO THE REGISTERED USER HAS NOT AUTHORIZED TO TRANSACT BUSINESS ON THE USER’S BEHALF USING THE SITE RESOURCES.

ANY PERSON WHO IS GIVEN A USER’S PASSWORD WILL HAVE ACCESS TO ALL OF THE USER’S INFORMATION THAT IS STORED ON THE SITE AND MAY HAVE THE ABILITY TO CHANGE OR DELETE THAT INFORMATION.

No Resale of Information

Common Census never resells, trades, leases or rents the personally identifiable information of our users to other companies.