EBenefits Solutions, Inc. ("EBenefits") has created this Privacy Policy for the purpose of communicating our commitment to the privacy of information provided to us by our customers and their employees. We understand the sensitive nature of the information entrusted to us and acknowledge that maintenance of the privacy of such information is of the highest importance to our customers and their employees. The following discloses our practices relative to the gathering and dissemination of information for our web site, www.ebenefits.com ("Web Site"), and our services, as described in our Agreement For Services ("Agreement" or “Services”).

Information Practices
EBenefits generally gathers or receives, uses and discloses the following categories of information in the following ways, subject to the Exceptions section as noted below:

Contact Information
When customers and prospective customers contract for Services or inquire about EBenefits’ Services, we ask them to provide us with company contact information, some examples of which are the company's name, address, number of employees and industry classification. We utilize company contact information to provide information to customers and prospective customers regarding our Services and to maintain a record of inquiries regarding our Services. We will also send customers and prospective customers email messages using company contact information in the following circumstances:

• Welcome new customers to our Service;
• Explain the new features of our Service as our Service develops and grows;
• Notify customers and prospective customers of Service promotions; and
• Communicate with customers about their use of our Service.

Employee Information
When our employer customers utilize our Services to manage and communicate HR, employee benefits, and employee information on behalf of their employees, they provide us with information typically provided by an employee to an employer's human resources and/or payroll departments. Such information often includes, but is not limited to, the following:

• Demographic information, such as the employee's name, address, and social security number; and Job information, such as title, salary, date of hire, benefit elections and information regarding an employee's dependents.

We utilize the information provided to deliver Services to our employer customers and their employees. Unless directed by our customers, we do not share employee information provided by our customers with anyone. When directed by our customers, we communicate company employee information to third party service providers such as payroll service bureaus, insurance companies and third party administrators, among others. We may also aggregate employee information from multiple employer customers to perform analyses.

Examples of analyses performed include, but are not limited to: number of employees enrolled in plans provided by a particular insurance carrier, average number of employees employed by our customers and average number of benefit plans sponsored by our customers. When used to perform such analyses, information provided by an employer customer or its employees is not disclosed in a level of detail sufficient to permit the identification of individual employee records.

Login Identification/Passwords
Our Service requires users to provide us with login identification and a password, which we will use to verify their identities and for our internal use in maintaining each customer account.

Referencing Web Site
If a prospective customer is referred to us from a third party with whom we have a business referral relationship, we collect the name and URL of the referring web site to facilitate the business referral relationship with the referring third party.

IP Address
We gather user IP addresses when customers and their employees use our Service and Web Site. We use IP addresses to help diagnose possible Service interruptions and administer our Service and Web Site.

Cookies
Cookies are small files created by web sites, including our Web Site and Service, identifying the user of the web site. We utilize cookies to manage each user interaction (often referred to as a session) with our Services to ensure proper identification of the user during each use of our Service. We do not store cookies beyond such interaction. If you choose to, you can set your web browser to reject cookies from our Service. However, rejecting cookies from our Service will prevent your use of our Service.

Service Activity
Our application has the capability to monitor all of your actions while using our Service and report those actions to us. We utilize this information to understand the use of our Services to diagnose problems and enhance the features and functionality of our Service. We do not disclose such information to anyone, including our employer customers or their employees.

Exceptions
Except as described above, we will not otherwise use or disclose any personally identifiable customer or employee information, except to the extent reasonably necessary: (i) in the operation of the health and welfare plan or plans administered on behalf of our customers to include the following:

• Arranging for the transmission of healthcare eligibility information for your staff and their family members that have been enrolled as dependents under your healthcare plans to the relevant insurance carriers and or third-party administrators; and
• Receiving information from your HR and/or Payroll information systems regarding the status of your employees including whether they are active, terminated, full-time, part-time, etc. so that eligibility determinations can be made and enrollment options offered to eligible staff by the EBenefits online system; and
• If authorized, utilizing the EBenefits tools and system(s) for the necessary operation of the plans, including the provision of census information to other third-parties such as brokers and insurance carriers for the purpose of monitoring enrollment activity, facilitating such enrollment, planning future enrollment initiatives and/or submission of Requests for Proposal or other bidding processes relating to these plans and programs;

(ii) to correct technical problems and to technically process customer information; (iii) to protect the security and integrity of the EBenefits Web Site and Service, including without limitation to enforce our Agreement For Services with customers; (iv) to protect our rights and property and the rights and property of others; (v) to take precautions against liability; (vi) to respond to claims that customer information violates the rights or interests of third parties; (vii) to the extent required by law or to respond to judicial process; or (viii) to the extent permitted under other provisions of law, to provide information to law enforcement agencies or for an investigation on a matter related to public safety, as applicable.

You understand and agree that technical processing of your information is and may be required (a) to send and receive messages in your use of the Service; (b) to conform to the technical requirements of connecting networks; (c) to conform to the limitations of our Service; and (d) to conform to other, similar technical requirements.

Storage of Information
We store customer and prospective customer information for up to ten (10) years for business purposes. We store employee information during the term of a customer's Agreement For Services and for up to ninety (90) days after termination of such Agreement, after which, all employee information is automatically deleted from our Service.

General Information

Links to Other Web sites
Our Web Site contains links to other Web Sites. We are not responsible for the privacy practices or the content of other Web Sites.

Security
Our Web Site uses firewall technology as a standard Internet security measure to prevent the loss, misuse and alteration of the information under our control. Our web servers are located in a high security and high availability co-location facility professionally managed by a third party vendor.

Notification of Changes
If we decide to change our Privacy Policy, we will post those changes on our Web Site so our users are always aware of what information we collect, use and disclose. If at any point we decide to use or disclose information we have collected in a manner different from that stated at the time it was collected, we will notify our employer customers by way of an e-mail based upon the Contact Information that we have on file for our customers.

If you have any questions about this privacy policy, the practices of this Web Site or our Services, you can contact us at EBenefits Solutions, LLC., Two Chatham Center, Suite 350, 112 Washington Place, Pittsburgh, PA 15219.

Contact Information
If you feel that EBenefits is not abiding by its posted privacy policy, you should contact the Chief Operating Officer at the same address as above or by calling (412) 647-3393.