NOTICE OF PRIVACY POLICY

We value our relationship with you, our customer. We understand that you trust us to protect your personal information. We respect and share your concerns. Be assured that your privacy is protected. The following privacy policy describes our practices concerning the types of personal information we collect and what we do with it. These practices meet all federal and state laws governing privacy and our own high standards of customer confidentiality.

PRIVACY POLICY

WAWANESA GENERAL INSURANCE COMPANY

Our Pledge to You

We will adhere to the following ten interrelated principles, which form the basis of this policy:

1. Accountability. We are responsible for your personal information under our control and have designated an individual who is accountable for our compliance with these principles.
2. Identifying Purposes. We will identify the purposes for which we collect your personal information at or before the time we collect the information.
3. Consent. We will collect, use, and disclose your personal information only with your knowledge and consent, except where it would be inappropriate to do so. Your consent may reasonably be inferred from your action or inaction.
4. Limiting Collection. We will collect only the personal information necessary for the purposes we have identified. We will collect your personal information only by fair and lawful means.
5. Limiting Use, Disclosure and Retention. We will not use or disclose your personal information for purposes other than those for which we have collected it, except with your consent or as required by law. We will retain your personal information only for as long as is necessary to fulfill those purposes.
6. Accuracy. We will keep your personal information as accurate, complete, and up-to-date as is necessary for the identified purposes.
7. Safeguards. We will protect your personal information by security safeguards appropriate to the sensitivity of the information.
8. Openness. We are open about our practices relating to the management of personal information, which are described in this policy.
9. Customer Access. Upon request, you will be informed of the existence, use, and disclosure of your personal information and will be given access to the information. You will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
10. Challenging Compliance. You will be able to address a challenge to our compliance with these principles to the designated individual accountable for our compliance.

What We Collect

All the personal information we collect about you is needed to accurately process your request for rates or insurance, service your policy or adjust any claim you may have.

We collect personal information about you (such as your name, address, date of birth, social security number, and driver's license number) from

• the application forms you submit for a rate quote or policy;
• other policy service or claim forms you submit; and
• your dealings with us in person, on the telephone, through our website or through the mail.

We collect personal information about you (such as your claim history, motor vehicle record and in some cases your credit history) from consumer reporting agencies. These agencies may retain your personal information and disclose it to other persons as allowed by law.

What We May Disclose

In order to process your application, service your policy or adjust any claims you may have, we may disclose the following personal information about you:

• personal information you provide, such as your name, address and social security number;
• personal information about your dealings with us, such as your policy coverage, premiums, and payment record; and
• personal information from consumer reporting agencies, such as your driving record and in some cases your credit history.

We only disclose the personal information of former customers for the purposes of

• investigating an ongoing claim; or
• reporting, investigating or preventing actual or potential fraud or material misrepresentation.

To Whom Personal Information Is Disclosed

We will disclose your personal information only as allowed or required by law and as needed to provide or service your insurance policy or settle your claim.

We may disclose personal information about you to the following:

• insurance rate advisory organizations;
• companies processing insurance claims;
• consumer reporting agencies, in accordance with the Fair Credit Reporting Act; and
• companies or agencies dealing with fraud investigation or prevention.

Confidentiality and Security

We protect your personal information:

• we do not sell it to anyone;
• we do not share it with other companies for their marketing purposes;
• we require companies performing services on our behalf to protect it;
• we provide only those employees who need it to provide insurance products or services to you with access to it;
• we restrict access to it through physical, electronic and procedural safeguards;
• we monitor our safeguards regularly; and
• we revise our procedures when needed to meet new concerns.

You have the right to access the personal information we have collected about you and request a correction to the personal information should it be necessary. More details about your rights are available by sending a written request to Wawanesa Insurance, 9050 Friars Rd., San Diego, CA 92108.

We will protect your personal information as if it were our own. This is our pledge to you.

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