CBE is an independent insurance agency that specializes in the design, implementation and servicing of all types of employee benefit plans.

Corporate Benefit Enterprises, LLC (CBE) Privacy Policy
 
CBE values our customers’ trust and is committed to the responsible management, use and protection of the information entrusted to us.  The following privacy and disclosure outlines what nonpublic personal information we collect, how we protect nonpublic personal information and how we share nonpublic information.

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 correspondence.
* 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 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 CBE; (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 INFORAMTION
 
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 CBE 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 complies with federal regulations to guard nonpublic 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 be re-enabled after verification of the user by security personnel;
2. Logon identifications area issued only with specific access authorizations;
3. Passwords must be changed every ninety days;
4. Internal systems are regulated to ensure that only authorized CBE 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 CBE website (www.corporate-benefit.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.
 
C. Employees
 
1. Control procedures are in place together with the segregation of duties for employees with access to, or responsibility for, nonpublic personal information;
2. Employees receive training, as part of the orientation process, with respect to CBE’s Privacy Policy and the issuance of the privacy notice; and
3. Employees are required to execute an acknowledgement form following review of CBE’s Privacy Policy.
 
D. Agents
 
1. Individuals, companies and other entities that access products and services from CBE must agree to safeguard nonpublic personal information about customers pursuant to CBE’s Privacy Policy.
 
E. Third Party Service Providers
 
1. Third party service providers must agree to safeguard nonpublic personal information about customers pursuant to CBE’s Privacy Policy.
 
In addition to the specific categories listed above, CBE has implemented physical, electronic and procedural safeguards to protect nonpublic personal information about customers.  These safety mechanisms are regularly tested to assure continued efficacy.  The condition and status, as well as any breaches or violations, or this Privacy Policy are reported to the CBE Board, through the Internal Audit Committee, on an annual basis.  The goal of CBE’s Privacy Policy is to protect nonpublic personal information about customers in a manner that enables customers to continue to receive the highest level of service while at the same time feeling confident that non-public personal information about them is treated with the care and security it deserves.

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Corporate Benefit Enterprises, LLC (CBE) Privacy Notice
 
This Privacy Notice is provided on behalf of CBE.
 
Congress recently passed the Gramm-Leach-Bliley (GLB) Act, which deals in part with how the financial services industry handles nonpublic personal financial information.  CBE recognizes that the foundation of our business is maintaining your trust and confidence.  In order to provide you with the most effective and beneficial service, we must maintain information about you.  Keeping that information secure and private is important to us.  This notice is provided to you so that you may know how we collect information about you, the type of information we collect, what we may disclose to our affiliates and non-affiliated third parties, and the steps we take to protect personal information about you.
 
WHAT WE COLLECT
 
First, we must collect a certain amount of personal information about you in order to provide customer service, offer new products or services, evaluate benefits and claims, administer products, and fulfill legal and regulatory requirements.  Therefore, as part of our servicing of your requests, we may obtain certain nonpublic personal information about you.  This information includes facts and data that we receive from you, your medical providers, medical field examiners, medical information providers, government agencies, current or past employers, credit agencies and/or other authorize persons on applications, company required forms, feedback forms, client/account information forms, needs analyses, telephone calls, service requests, correspondence, process requests, claim forms and other processing forms; facts and data about your transactions with us, our affiliates or others; and facts and data we receive from consumer reporting agencies.
 
The information we collect may include:
 
* Your name, address, telephone number, email address, date of birth, Social Security number, age, gender, marital status, assets, bank account number(s) and financial statistics;
* Your relationship with us, such as products or services purchased, policy values, payment history and claims history;
* Your employment history, such as your occupation(s), your income and your employer(s) and years of service with employer(s);
* Your creditworthiness and credit history;
* Your criminal record;
* Your medical information, such as your health background and health status; and
* Your hobbies.
 
WHAT WE SHARE
 
CBE is committed to maintaining the confidentiality of the personal information we collect.  We welcome this opportunity to clarify our privacy policy for you.
 
We respect to the information we collect about you:
 
* We collect and use the information to the extent needed to conduct our business and to meet our high quality service standards;
* We restrict access to the information to authorized individuals who need to know this information to provide service and products to you;
* We maintain appropriate safeguards to protect information about you;
* We will verify that any persons requesting information about you or your relationship with us is entitled to such information prior to providing it.  For example, we may give information to heirs/beneficiaries concerning the existence and amount of life insurance and annuity contracts following receipt of notice of the death of an insured or an annuitant.
* We do not share nonpublic personal information about outside our company other than to service your request, or as authorized by you, or as required or permitted by applicable law;
We require any organization that provides assistance to us in administering or reinsuring contracts or providing services on our behalf to you to maintain the confidentiality of your nonpublic personal information and not use such information for any other purpose;
* We do not allow non-affiliates to offer their products and services to you without your consent; and
* We only share personally identifiable medical information with affiliates or non-affiliates as may be permitted or required by law, authorized by you, or necessary in connection with the issuance, verification, or administration of the insurance service you requested.
 
The law does permit us to share information about you with our affiliates, including insurance companies and insurance service providers.  The law also permits us to share information about you with companies that perform marketing services for us, or other financial institutions that have joint marketing agreements with us.  The information we share with our affiliates or service providers need not be directly related to our transaction with you.
 
If we change our privacy practices, we will provide you notice of all material changes.  This privacy notice supersedes all previous notices with respect to matters described herein.
 
It is our goal to ensure that all the information we collect is accurate and complete.  Please notify us if you believe information is inaccurate.
 
NO ACTION IS REQUIRED BY YOU
 
You do not need to do anything as a result of this notice.  It is meant to inform you of how we safeguard your nonpublic personal information.  You may wish to file this notice with your insurance papers.
 
Your trust and confidence is important to us and we strive to maintain your continued trust.