Compensation & Privacy Disclosure

(as of August 1, 2003)

COMPENSATION DISCLOSURE

Agent may enter into arrangements with certain insurance carriers providing for compensation, in addition to commissions, to be paid by such carriers to Agent or its affiliates based on, among other things, the volume of premium and/or underwriting profitability of the insurance coverages written through Agent by such carriers. These payments are not guaranteed and are not client specific. The insurance coverages Client purchases through Agent might be issued by an insurance carrier that has such a relationship with Agent and its affiliates. Agent may also enter into arrangements with premium finance companies that provide compensation to agent or its affiliates. Agent strives to work with insurers and/or premium finance companies that provide you and your business with the insurance coverage you need, with your best interests in mind, and not based on the possibility of additional compensation arrangements. Nevertheless, please let us know if you wish additional information about these arrangements. It has always been, and will continue to be, the practice of Agent to leave the final selection of insurers to our Clients.

PURPOSE OF THIS NOTICE

Title V of the Gramm-Leach-Bliley Act (GLBA) and the laws of the State of California, generally prohibit us from sharing nonpublic personal information about you with a third party unless we provide you with this notice of our privacy policies and practices describing the type of information that we collect about you and the categories of persons or entities to whom 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 Fort Point Insurance Services, Inc.

OUR PRIVACY POLICIES AND PRACTICES

1. Information we collect:

A. Categories of information collected and sources from which we collect it
We collect nonpublic personal information about you from the following 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

2. Information we may disclose to third parties:

We do not disclose information about you to third parties whose only use of the information is to market a product or service. However, 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 describe below:

• 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, or 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 a medical care institution or medical professional in order to verify coverage or benefits, inform you of a medical problem of which you may not be aware, or conduct an audit that would enable us to verify treatment;
• To an insurance regulatory authority, law enforcement, or other governmental authority in order to protect our interests 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;
  

3. 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 2 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 follows:

To obtain access to your information:

You should submit a request in writing to Daniel Glunt, CEO / Fort Point Insurance Services, Inc. / Three Embarcadero Center, Suite 1610 / San Francisco, CA 94111. The request should include your name, address, social security number, telephone number, and the 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 Daniel Glunt, CEO / Fort Point Insurance Services, Inc. / Three Embarcadero Center, Suite 1610 / San Francisco, CA 94111. 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.

4. 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 federal regulations to guard your nonpublic personal information.

5. 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.

6. Reservation of the right to disclose information in unforeseen circumstances:

In connection with the potential sale or transfer of its interests, Fort Point Insurance Services, Inc. and its affiliates (if any) 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 Fort Point Insurance Services, Inc.’s successor in interest with regard to the maintenance and protection of the information collected; and

(3) agrees to the obligations of this privacy statement

7. Website

This website is operated exclusively by Fort Point Insurance Services, Inc. For each visitor to this website, our web server automatically recognizes and records only his/her IP address, and no other information about that visitor. The e-mail addresses of those who communicate with us via e-mail are gathered only if they are volunteered by the consumer, such as via quote submission. The information we collect is used to assess the needs of our clients and prospective clients regarding insurance coverage. We respect your privacy and will not share or sell your e-mail address.

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