Tower Insurance Services, Inc.

Corporate Privacy Policy

Due to the nature of the business, Tower Insurance Services, Inc. may deal in privileged customer information, including personal health information. When customers establish a relationship with us, we collect their personal private information to administer their account. It is our policy to protect private information, to comply with privacy laws and to provide the best services possible to our customers while maintaining the integrity of our businesses.

Disclosure of Information

Disclosure of private information will be as necessary to effect, administer, or enforce a transaction or service requested or authorized by the consumer, or in connection with servicing or processing a product or service requested or authorized by the consumer. The disclosure is required or is a usual, appropriate or acceptable method to carry out the transaction or service business, such as for insurance underwriting at the consumer’s request or for reinsurance purposes, or for any of the following purposes as they relate to a consumer’s insurance: Account administration, reporting, investigating, or preventing fraud or material misrepresentation, processing premium payments, processing insurance claims, administering insurance benefits, participation in research projects, or as otherwise required or specifically permitted by Federal or State law.

To continue to offer products and services to our customers we may share information that is not protected health information with affiliated companies of Tower Insurance Services, Inc. or to credit reporting or collections to the extent allowed under the law. We will honor a customer’s request not to receive marketing materials.

Disclosing Information to Other Outside Companies Periodically, we will need to share our customer's private information with outside companies; for example, companies that we hire to maintain our computer systems.

We will communicate our privacy commitment to these companies and ask that these companies agree to safeguard customer information, use the information only for its intended purpose, and not distribute it to other companies unless it is necessary to complete the customer's transaction.

Providing Privacy Information to Customers and Responding to Inquiries

Customers have the right to receive, and we have a responsibility to inform customers of, our privacy policies and practices. At a minimum, this policy will be available at our office, will be sent to all new customers and available at request.

Protecting Private Information

We will diligently protect our customer's private information by establishing operational safeguards that will create standards and procedures for the security of computer systems that house private information to help prevent unauthorized access. For example, any web site where a SSN is posted, will be password protected and encrypted. We will allow access to our customer's private information by only those employees who have a business reason to access such information and will establish operational procedures to safeguard private information from being released accidentally or released to individuals that fraudulently attempt to obtain the information. Also, we will train and educate all employees on the importance of confidentiality and protecting customer privacy. We will take appropriate disciplinary measures to enforce employee privacy responsibilities.

Complaint Procedure

It is the policy of Tower Insurance Services, Inc. that all complaints related to the protection of health information be investigated and resolved in a timely fashion. All complaints should be addressed to Tower Insurance Services, Inc. Privacy Officer, who is duly authorized to investigate complaints and implement resolutions if the complaint stems from a valid area of non-compliance with the HIPAA Privacy and Security Rule