NOTICE OF PRIVACY POLICY OF BOLTON & COMPANY

This notice is given in compliance with Title V of the Gramm-Leach-Bliley Act (GLBA) and the laws of the State of California. These laws generally prohibit us from sharing non-public 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 this information may be disclosed. This notice is to give you an opportunity to “opt-out” of the act for insurance marketing and to notify you of the privacy policies and practices of Bolton & Company.

OUR PRIVACY POLICIES AND PRACTICES

1. Information We Collect:

A. Categories of information collected and sources from which we collect it

We collect non-public personal information about you from the following sources:

1. Information that you provide us in communications, on applications or in other forms. (In the case of commercial firms, “you” includes employees.)

2. Information about your transactions with us from the insurance companies we contract to underwrite your insurance.

3. Information we receive from the Department of Motor Vehicles or other consumer reporting agencies.

4. Information contained in medical records or from medical professionals that is related to insurance claims.

5. Information contained in medical records or from medical professionals necessary to establish insurability.

Unless it is specifically stated otherwise in an amended privacy policy notice, no additional information will be collected about you.

B. Persons from whom information is collected:

1. We may collect non-public information from individuals other than those proposed for coverage.

2. Information We May Disclose to Third Parties:

We do not disclose information about you to third parties whose primary use of the information is to market a product or services. We do not sell any information of any type to a third party. 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 described below:

A. To a third party if the disclosure will enable that party to perform a business, professional or insurance function for us or on your behalf.

B. To an insurance company, agent or credit reporting agency, the California Department of Insurance or other governmental agency, in order to detect or prevent criminal activity, fraud or misrepresentation in connection with an insurance transaction.

C. To an insurance company, 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.

D. To a medical care institution or medical professional in order to verify coverage or benefits, inform you of a medical problem of which we may not be aware, or conduct an audit that would enable us to verify treatment or conditions.

E. To a group policyholder for the purposes of reporting claims experience or conducting an audit of our operational services

F. To an insurance company, general agent or agency for the purposes of obtaining price quotations, or insurance coverage on your behalf.

3. Access To 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 type of institutions to whom we have disclosed such information within two years prior to your request. Your right includes the right to view such information, or request that a copy be sent to you by mail for which we are allowed to charge you a reasonable fee to cover our costs. Your right also includes the right to request corrections, amendments or deletions of any information that is 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, or to correct, amend or delete any of your information, please submit a request in writing to Judy Wilson, Bolton & Company, 245 South Los Robles Avenue, Suite 105, Pasadena, CA 91101-2820. For obtaining access to your information, your request should include your name, address, Social Security number or Federal ID 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 access in person or to mail copies that you have requested. For correcting, amending or deleting any of your information, your request should include your name, address, Social Security number or Federal ID number, telephone number, the specific information in dispute and the identity of the 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 non-public 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 non public personal information.

5. Controversy Or Claim

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 arbiter may be entered in any court having jurisdiction thereof. You may object to arbitration by written notice to Ronald C. Wanglin, Chairman, Bolton & Company, 245 South Los Robles Avenue, Suite 105, Pasadena, CA 91101-2820 within 60 days of receipt of this notice.

6. Reservation Of The Right To Disclose Information In Unforeseen Circumstances:

In connection with the potential sale or transfer of its interests, Bolton & Company 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 residence and other information that you provide through other communications) to a third party entity that: (1) concentrates its business in a similar practice of service: (2) agrees to be Bolton & Company’s successor in interest with regard to the maintenance and protection of the information collected: and (3) agrees to the obligation of this privacy statement.

Fees/Commission Disclosure

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