Privacy Policy and Practices

Privacy Policy and Practices

Your confidence in how we handle your privacy is our utmost concern. Asterisk Financial Group, Inc. (“we”, “us” or “our”) is committed to the responsible handling of Personal Information. This Notice describes how we collect and use Personal Information in the normal course of our underwriting business, the Personal Information we retain and the measures we take to protect Personal Information.

Effective Date of Notice:

We will give You a copy of our current Notice at the start of our business relationship, and at least once a year during our business relationship. We may change our policies and practices with respect to privacy as summarized in this Notice at any time. We will notify You about material changes to this Notice by mailing You an updated Notice, through an e-mail or by placing prominent notice on our Web site. This Notice is effective as of June 1, 2010.

We will continue to follow the policy and practices set out in the Notice with respect to Personal Information even when a business relationship no longer exists between us.

Personal Information We Collect:

We may obtain Personal Information from You, Transactions with us, and third parties. We will gather Your name, address, social security number, drivers license number, income, business name, address, employer identification number, business loan information, and business and personal credit histories from Applications, Transactions and reports from third parties, such as loan information from Your business lender, and credit reports from credit reporting agencies.

The Way We Use Personal Information:

We collect Personal Information to service your Transactions with us and to support our insurance underwriting and related business functions and to comply with Federal Regulations (OFAC).

Personal Information We Share:

We do not sell Personal Information or share Personal Information with anyone except as permitted by law, and we limit the types and amount of Personal Information we share. We will share Personal Information when You authorize us to release Personal Information.

To the extent permitted by law, we may share Personal Information with third parties that help us serve You, provide services to us, or process or service Transactions. When allowed by law, we may share Personal Information with third parties to assist us by taking surveys, marketing our products and services or offering financial products or services under a joint agreement between a financial institution and us.

Disclosure Required by Law:

To the extent permitted by law, we will share Personal Information with our regulators, auditors and other professional service providers to comply with applicable law and service our business. From time to time, we may be required to provide Personal Information in response to a court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. We also may share certain Personal Information when we believe that such sharing is reasonably necessary to protect the rights, property, and safety of others and ourselves.

Disclosure as a part of a Business Transaction:

We may disclose Personal Information to third parties in relation to planned or potential sales of our assets or securities, mergers, reorganizations, dissolutions or similar events. As a part of any such transaction, we will treat Personal Information as an asset and we will transfer it to the purchaser or successor, as the case may be.

Opt In/Opt Out of Certain Types of Information Sharing:

We will not sell or share Personal Information for purposes unrelated to our business functions without offering You the opportunity to opt in to or opt out of the sale or sharing of Personal Information.

Our Commitment to Data Security:

We maintain physical, electronic, and procedural safeguards that comply with or exceed applicable law to maintain the secrecy of Personal Information. We promptly dispose of all unnecessary Personal Information. We restrict access to Personal Information to only those employees who need to know Personal Information to provide our products or services to You or complete a Transaction. We train our employees about the importance of maintaining the confidentiality of Personal Information, and we take appropriate disciplinary action to enforce our employee’s privacy responsibilities. In addition, the third parties to whom we disclose Personal Information are required to keep the Personal Information confidential and use the Personal Information only to provide the services we request.

E-mail, text messaging, and similar forms of unencrypted electronic communication are inherently insecure. Please do not submit Personal Information to us through e-mail, text message or similar forms of unencrypted electronic communication.

Correcting or Removing Personal Information:

We are committed to maintaining complete and accurate information about You. If You believe any of the Personal Information we have is incorrect, or if you wish to have Personal Information removed from our records, please notify us immediately at 1.888.643.8744.

Definitions:

Application” means your request for personal guaranty insurance coverage from us.

Notice” means this notice of privacy policy and practices.

Personal Information” means financial or other non-public information about You or your business, such as Trade Secrets, credit history, income, financial benefits, business records, financial or accounting information involving your business, contracts to which You or your business are a party, transactions with previous insurers, policy information, and claim information.

Trade Secrets” means non-public information about your business that You disclose to us through a Transaction that (i) derives economic value, actual or potential, from not being generally known to, and not being readily ascertainable by proper means, by unrelated individuals or entities who could obtain economic value from its disclosure or use, and (ii) is the subject of efforts by You that are reasonable under the circumstances to maintain its secrecy.

Transaction” means your business dealings with us, such as submitting an Application, making a request to pay a claim or making a request that we take an action on your account.

You” means an individual who has given us Personal Information in conjunction with asking about, applying for, obtaining and maintaining an insurance policy from us.


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