1. PURPOSE OF POLICY. Four Points Benefits & Insurance Solutions, Inc. d.b.a. Four Points Benefits & Insurance Solutions (“us,” “we,” or “Company”) is committed to respecting the privacy rights of its customers, visitors, and other users of the Company Website and services (together, the “Website”). We created this Privacy Policy (this “Policy”) to give you information about our collection, use, and disclosure of information about you, as well as your rights regarding that information. Company adopts this Policy to comply with various local Consumer Protection laws, such as the California Consumer Privacy Act. This Policy is not applicable to any other websites that you may be able to access from the Website, ea which may have data collection and use practices and policies that differ materially from this Policy.

2. INFORMATION WE COLLECT
     2.1 PERSONAL INFORMATION. We collect information that identifies, relates to,describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or device (“Personal Information”). Personal Information categories include those listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). In particular, Company websites have collected the following categories of Personal Information from its consumers within the last twelve (12) months:

a.Identifiers.Examples: A real name, alias, relative location, online identifier, Internet Protocol Address, email address, or similar identifiers.

b. Internet or other similar network activitExamples: Browsing history, search history, information on a user’s interaction with a website, application or advertisement.

c. Geolocation data.Examples: Physical location by IP address for electronic signatures.

2.2 INFORMATION NOT CONSIDERED PERSONAL INFORMATION. Personal Information does not include: publicly available information that is lawfully made available to the general public from federal, state, or local government records; deidentified or aggregated consumer information; health or medical information covered by local and federal regulations such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.

2.3 INFORMATION YOU PROVIDE. In operating the Website, Company may include registration, online surveys, and other online forms that ask users to provide their names, email addresses, and other contact information. Depending on your use of the Website, we may also request financial data (such as your account or credit card number for purchases) and demographic data (such as your zip code, age, and income). If you communicate with us by email, complete online forms, or surveys, any information provided in those communications will be collected from you.

2.4 AUTOMATIC COLLECTION. When you visit the Website, our servers automatically recognize (1) vi ’ domain names; (2) IP addresses (the number assigned to computers on the Internet); (3) device information; and (4) location data. This “traffic data” may be used for marketing purposes or for improving the services we offer, as explained in more detail below.

2.5 TRACKING TECHNOLOGIES. We use “cookies” and other tracking technologies that allow us to store a small piece of data on your computer about your visit to the Website. Cookies help us learn which areas of the Website are useful and which areas need improvement. You can choose whether to accept cookies by changing the settings on your browser. However, if you choose to disable this function, your experience at the Website may be diminished and some features may not work as they were intended. Your browser or extension may allow you to automatically transmit Do Not Track signals, and unless required by law, we do not respond to such signals.

2.6 INFORMATION FROM OTHER SOURCES. We may receive other information indirectly from you, for example, from your employer, plan sponsor, insurance broker or authorized subcontractor of your employer, plan sponsor, or insurance broker.

3. USE AND SHARING OF COLLECTED INFORMATION

3.1 OPERATING OUR WEBSITE AND PERFORMING SERVICES. We may use or disclose your Personal Information we collect for one or more of the following purposes:

3.2 TRAFFIC DATA. We use traffic data to analyze our Website traffic, but we do not examine this information for individually identifying information. In addition, we may use IP addresses to help diagnose problems with our server, to administer the Website, or to display the content according to your preferences. Traffic and transaction information may also be shared with business partners and advertisers on an aggregate basis.

3.3  USE OF COOKIES. We may use cookies and other tracking technologies to deliver content specific to your interests, to save your password so you don’t have to re-enter it each time you visit our Website, or for other purposes.

3.4 DISCLOSURE OF PERSONAL INFORMATION. We may disclose Personal Information that you provide via the Website to the following third parties:

• • Our subsidiaries and affiliates; and
  • Contractors, vendors, and service providers we use to support our business and the Website. These support partners have all agreed to uphold the same standards of security and confidentiality that we provide to you under this Policy, and they have agreed to only use your information to carry out their specific business obligations to Company.

We may also disclose Personal Information that you provide via the Website in the event of a merger, acquisition, or any form of sale of some or all of our assets, in which case Personal Information we collect via the Website will be among the assets transferred to the buyer. Further, we may disclose your Personal Information to third parties in order to:

• Comply with any court order or other legal obligation;
• Enforce or apply our terms of use and other agreements; and
• Protect the rights, property, or safety of our business, our clients, customers, employees, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, information security, and other related matters.

3.5 RETENTION OF PERSONAL INFORMATION. Company will retain Personal Information for as long as reasonably necessary to fulfil the purposes for which it was provided or collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you, to comply with law enforcement requests, maintain security, prevent fraud and abuse, resolve disputes, enforce our legal agreements, or fulfil your request to “unsubscribe” from further messages from us. To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. We will retain some anonymized information (so that it can no longer be associated with you) and we may use this for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

4. USER CHOICES REGARDING COLLECTION, USE, AND DISTRIBUTION OF INFORMATION.

4.1 COMMUNICATIONS. If you do not wish to receive information and promotional material from us or from some of our partners, you may select the appropriate “opt-out” option each time we ask you for information. You can opt-out of emails from us by clicking on the unsubscribe link in each message or emailing us with UNSUBSCRIBE in the subject field of the email.

5. FOR RESIDENTS OF CALIFORNIA.
5.1 SHINE THE LIGHT.

1. Under California’s “Shine the Light” law, California residents who provide Personal Information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, once each calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately preceding calendar year.
2. To obtain this information, please send an email message to info@bscinc.com with “Request for California Privacy Information” in the subject line and in the body of your message. We will provide in response the requested information to you at your email address.
3. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only required information will be included in our response.

5.2 The California Consumer Privacy Act as amended by the California Privacy Rights Act (the “CPRA”) provides additional rights to residents of California regarding our information collection and use practices. For more detail on the information we collect, including the sources we receive information from, please refer to our Information We Collect section above. In the preceding twelve (12) months, Company has disclosed the following categories of Personal Information for a business purpose:
Identifiers. Geolocation data. We disclose your Personal Information for a business purpose to the following categories of third parties: Service providers. Company does not sell Personal Information as defined under the CPRA.

5.3 RIGHTS OF CALIFORNIA RESIDENTS
a. Right to Know. You have the right to know certain details about our data practices.
In particular, you may request the following from us:

• The Personal Information we have collected about you;
• The categories of sources from which the Personal Information was collected;
• The categories of Personal Information about you we disclosed for a business purposeor sold or shared;
• The categories of third parties to whom the Personal Information was disclosed for abusiness purpose or sold or shared;
• The business or commercial purpose for collecting or selling or sharing the PersonalInformation; and
• The specific pieces of Personal Information we have collected about you.

To exercise the Right to Know, please submit a request via email to info@bscinc.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know.

1. Right to Correct or Delete. You have the right to request that we correct or delete the Personal Information we have collected from you. To exercise the right to correct or delete, please submit a request via email to info@bscinc.com. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request to delete. If we deny your request, we will explain the reason why in our response.
2. Right to Opt-Out of Shares. You have the right to tell us not to share your information at any time. You may submit a request to opt-out by emailing info@bscinc.com
3. Right to Limit the Use of Sensitive Personal Information. You have the right to tell us to limit the use or disclosure of your information at any time. You may exercise this right by emailing info@bscinc.com
4. Right to Non-discrimination. You have the right to not receive discriminatory treatment by us for exercising any of your rights.
5. Authorized Agent. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

6. SECURITY. The Website has security measures in place designed to prevent the loss, misuse, and alteration of the information that we obtain from you, but we make no assurances about our ability to prevent any such loss, misuse, or alteration to you or to any third party arising out of any such loss, misuse, or alteration.

7. ACCESS TO OTHER WEBSITES. The Website may contain links to other websites. If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.

8. CONTACT INFORMATION AND POLICY UPDATES.

8.1 CONTACTING US. If you have any questions about this Policy, our practices related to this Website, or if you experience any difficulty accessing any of the information in this Policy, please feel contact us at the following: