I. Collection of Information
We collect nonpublic personal information about you from the following sources:
• Information we receive on applications or other forms;
• Information we receive from consumer reporting agencies;
• Information we receive from our employees, agents, and third party affiliates; and
• Information collected by needs analysis, telephone calls, service requests and other
• Information we receive from physicians, which may include your medical history, current health, and treatments and medications you may be taking; and
• Information we receive from your motor vehicle reports or demographic information.
Please Note: We do not share nonpublic personal health information about you for marketing purposes. That health information is used only for underwriting products you purchase, or administering a claim, or other insurance functions by us or on your behalf, unless you or the law authorizes a distribution of greater breadth.
II. Sharing of Information
We may disclose all of the information, as described in Section I above and subject to the noted limitations, that we collect about our potential, current and former customers.
We may disclose all of the information we collect to: (i) individuals, companies or other entities that market our services; (ii) individuals, companies or other entities that provide products and/or services to Capital Indemnity Group; (iii) individuals, companies or other entities that assist in the administration and servicing of your policies; or (iv) individuals, companies or other entities with whom we have joint marketing agreements.
We may also disclose nonpublic personal information about you to nonaffiliated third parties as permitted by law.
III. Policies and Procedures to Protect Information
We restrict access to nonpublic personal information about you to those employees or service providers who need to know the information to provide products or services to you.
The policies and procedures used by Capital Indemnity Group are designed to: (i)
ensure the security and confidentiality of customer information, (ii) protect against any anticipated threats and or hazards to the security and integrity of customer records and information; and (iii) protect against unauthorized access to, and use of customer records or information that could result in substantial harm or inconvenience to any customer.
A. Physical Records
1. Physical safeguards are in place that comply with federal regulations to guard non-public personal information about you that is maintained in hard copy.
B. Information Systems
1. Electronic files operate under a “lock out” system whereby three failed attempts to log-on results in shutdown; the system will only be re-enabled after verification of the user by security personnel;
2. Logon identifications are issued only with specific access authorizations;
3. Passwords must be changed every ninety days;
4. Internal systems are regulated to ensure that only authorized Capital Indemnity Group associates can access the information contained in the system;
5. Website servers used to gather and transmit personal data are stored in a secure and environmentally controlled locations;
6. The Capital Indemnity Group website (www.capitalindemnitygroup.com and additional content-related websites), and certain other electronic files are encrypted;
7. Monitoring systems and procedures are in place to provide warnings of possible attacks or intrusions into information systems; and
8. Systems are equipped with response mechanisms that take appropriate action when
unauthorized access to protected information is suspected or detected.
1. Control procedures are in place together with the segregation of duties for employees with access to, or responsibility for, non-public personal information;
1. Individuals, companies and other entities that access products and services from Capital Indemnity Group must agree to safeguard nonpublic personal information about customers pursuant to Capital Indemnity Group's PrivacyPolicy.
E. Third Party Service Providers
In addition to the specific categories listed above, Capital Indemnity Group has