Edgewood Partners Insurance Center (EPIC) Privacy Notice

Effective Date: May 25, 2018

Edgewood Partners Insurance Center and its affiliates (EPIC) is a unique and innovative retail property & casualty and employee benefits insurance brokerage and consulting firm. EPIC is committed to protecting your privacy and the privacy of its clients. This Privacy Notice describes how EPIC collects personal information. This Notice applies to any personal information you provide and any personal information we collect from other parties, including your employer.

EPIC collects personal information when:

• you contact us or we perform services for you
• we provide services for our clients
• you register on our website or email distribution lists
• you RSVP to or attend our events
• you interact with us through social media
• you apply for a job at EPIC

In the course of interacting with you or providing our products and services, EPIC may collect personal information from you or other sources, including your employer, which may include the following:

Name and contact information (e-mail address, mailing address, phone number, mobile number, etc.)

Insurance policy and claim information

Government-issued identification and record details (social security number, driver’s license number, motor vehicle record, passport information, etc.)

Information you provide on a job application or that is obtained under a position-related background check.

Demographic information (date of birth, gender, employment status, benefit coverages, marital status)

Sensitive personal information (physical or mental health status, criminal record)

If you provide us with sensitive personal information, you expressly consent that we may collect, use and disclose this information to appropriate third parties for the purposes described in this Notice. If you provide personal information about other individuals such as employees or dependents, you agree that you are responsible for obtaining their consent prior to your disclosure to us.

We process personal information that is provided by you or our clients in order to perform services. The processing of your personal information depends on the type of services we provide, applicable laws, regulatory guidance and professional standards. It is the obligation of our client to ensure that you understand that your personal information will be disclosed to EPIC.

All processing of your personal information is justified under a “lawful basis” for processing, including the following:

• your consent
• processing is necessary in order to enter into or perform a contract for you
• processing is necessary for us to comply with legal obligations
• processing is in our legitimate commercial interest, except that our interest may not override your fundamental rights or freedoms

In limited circumstances, we will use your consent as the basis for processing your personal information, for example, where we are required to obtain your prior consent in order to send you marketing communications.

EPIC does not intentionally collect information from children.

We may share your personal information with other EPIC affiliates as part of the process of providing services to you. We may also share your personal information with service providers that you or EPIC has engaged to perform services for you as data processors. These service providers are bound by contracts that prohibit impermissible use or disclosure of your information.

EPIC protects personal information using physical, electronic, and procedural safeguards that are specifically designed to meet or exceed the requirements of applicable laws. All EPIC employees receive training on the importance of protecting personal information, and only authorized employees have access to personal information. Subcontractors and agents are contractually bound to maintain protection of personal information and are not permitted to use the information for any unauthorized purpose.

EPIC is the controller that is responsible for the personal information we collect and process. You have certain rights related to the processing of your personal information, including.

You have the right to unsubscribe from our communications by clicking the “unsubscribe” link in our marketing emails or by contacting us.

You have rights to access, correct, restrict, object to or suppress the processing of your personal information.

You have the right to data portability, which in certain situations, requires us to provide personal information to you or another controller.

You have the right to decline automated decision making.

Please contact us as noted below if you would like to make a request. We will try to comply with your request as soon as reasonably practicable. Depending on the nature of your request, we reserve the right to charge a reasonable fee if we will incur costs relating to your request. Finally, we may not always be able to comply with your request, and in these cases, we will notify you.

Under California’s “Shine the Light” law, you have the right to request and obtain from us once a year an account of your Personal Information we disclosed to third parties for direct marketing purposes. You will receive a notice that will include the categories of Personal Information that was shared (if any) and the names and addresses of all third parties with which the information was shared (if any). Epicbrokers.com does not use technology that accommodates do-not-track signals from your browser. If you are a California Resident and would like to make a request, please contact us using the information found in the “Questions or Complaints” section below.

Epicbrokers.com includes the EPIC Career Portal, which is available for those who wish to search and apply for open job positions at EPIC. Applications and other materials submitted through the Portal are first collected and processed by a third-party vendor. By submitting an application through this Portal, you consent to this processing of your personal information.

This Privacy Notice describes the data privacy and protection policies of EPIC.

In addition, epicbrokers.com may contain links to other websites. This Privacy Notice only addresses your information that is received by EPIC. You are encouraged to review the privacy policies of each website you visit.

This Notice may be changed at any time. Unless stated otherwise, all changes that occur will become effective immediately. By continuing to access EPIC websites, you agree to accept all terms and conditions outlined in this Notice.

If you have any questions or complaints about this Notice, or about our data privacy or security policies in general you may email your comments to privacy@epicbrokers.com or contact us by mail at EPIC Corporate Headquarters, Attention: Privacy Officer, 425 California Street, 24th Floor, San Francisco, CA 94104. You also have the right to contact your local Data Protection Authority.