COMMENCEMENT BAY RISK MANAGEMENT PRIVACY NOTICE Effective Date: July 24, 2019 Last Updated: June 29, 2020 At Commencement Bay Risk Management (“CBRM” or “Company”), protecting an individual’s personal information is important to us. That is why we are committed to the confidentiality and security of the personal information of our customers’ members or other individuals whose personal information we have or receive. References to “you” and “your” in this privacy notice refers to our customers, whose members’ personal information we receive. We maintain physical, administrative and technical safeguards to protect against unauthorized access, use, or disclosure of your members’ personal information, including information we share internally either orally, electronically, or in writing. However, we recognize, and want you to recognize, that while electronic communications have many benefits, they may not be as secure as other means of communication. Read the following information carefully to better understand the type of information we collect, how we use information, and our commitment to maintaining the privacy and security of information. ONLINE SECURITY AND PRIVACY Security Practices CBRM attempts to protect online and electronic information according to applicable laws and established company security standards and practices. We have security measures in place to protect against the loss, misuse, or alteration of information under our control, and we continually evaluate new technologies for safeguarding your information. However, we cannot guarantee the confidentiality or security of electronic transmissions via the Internet or unsecured emails because they may potentially use unsecure computers and links, and data may be lost or intercepted by unauthorized parties during such transmission. If you wish to submit personal or confidential information by a more secure means of communication, contact us. Use of Email Use your own best judgment when sending information via the Internet to an email address. Email sent via the Internet may pass through private and public networks with varying levels of security. Some networks may have taken steps to secure email transmissions while others have not, thereby compromising the privacy and integrity of an email. An email may be copied, altered or destroyed. CBRM will respect your request regarding how to transfer your members’ data to us securely. After your email is received, CBRM may preserve the content of your email, your email address and our response so we can efficiently respond to questions you might have. We also may do this in an effort to meet legal and regulatory requirements. Updates to this Statement Evolving technology will continue to provide CBRM with new and better ways to safeguard your members’ information. We may update this statement in the future to reflect these technological advances, and we encourage you to return to this page from time to time for any updates. PRIVACY PRACTICES Data we collect We may collect personal information about your members, such as names, contact information, date of birth, dependent data, and other personal identifiers; medical and other claims information; insurance information; and health information, from you, brokers, Third Party Administrators (“TPAs”), and short-form health applications. How we use your members’ data We use the information we collect to determine whether we can provide products and services to our customers, and to maintain and service those accounts. Once we obtain personal information, we do not disclose it to anyone except as permitted or required by law. All information submitted to us may be retained to provide a record of communication and to comply with any application legal and/or regulatory requirements and may also be verified for accuracy. We may use your members’ personal information to: Provide services to our customers or customers’ brokers Communicate with our customers Support company operations, (e.g., quality control, fraud detection, training) Develop and improve new and current products and services Personal Information may also be anonymized by CBRM (i.e. stripped of individual identifiers), aggregated with other data, and used for general research, classifications, reports, or other purposes without permission. How we share your data Once we obtain members’ personal information, we do not disclose it to anyone except as permitted or required by law. We do not sell members’ personal information. We may share members’ information with third party vendors who may use it only as permitted or required by law for the limited purposes of: Helping us to provide services to customers Supporting our company operations (e.g., quality control, fraud detection, training) Helping us to develop and improve our products and services There may also be times when we are required to disclose members’ information, such as when complying with federal, state or local laws, when responding to a subpoena, or when complying with an inquiry by a governmental agency or regulator. Security of your data We maintain physical, electronic and procedural safeguards that comply with federal and state regulations to safeguard members’ information from unauthorized use or improper access. Employee access to your Information We restrict access to members’ information to those employees who have a business need to know it in order to provide products or services to you or to maintain your accounts. Our employees are governed by a code of conduct and are required to maintain the confidentiality of customer information. CALIFORNIA CITIZEN RIGHTS Individuals who reside in the state of California, a “consumer,” as that term is defined under California law, have additional rights reserved under the California Consumer Privacy Act (CCPA) and the California Shine the Light law: Right to Opt-Out. We do not sell personal information. Right to Request Personal Information. As a consumer, you have the “right to know” and request that we disclose what personal information we collect, use, and disclose. See the instructions below for submitting a verifiable request, including through the online request form offered by us. You have the right to request the categories of personal information, as detailed under the CCPA, we have collected and store about you. In addition, you have the right to request categories of sources of personal information we collected about you, the business or commercial purpose for collecting, the categories of third parties with whom we share that personal information, and the specific pieces of personal information we have collected about you. Categories of personal information that we disclosed about you for a business purpose may also be requested, with the appropriate lists provided under the CCPA. Upon receipt of a verifiable consumer request, described below in this Privacy Statement/Notice, from you to access personal information, we will promptly take steps to disclose and deliver, free of charge to you, the personal information required by this section and within the timeframes permitted for responding to exercise of this or other applicable right(s). The information may be delivered by mail or electronically, dependent on portability and technical considerations under the CCPA. We may provide personal information to you at any time following a verified request, but shall not be required to provide personal information to you more than twice in a 12-month period. Right to Delete Personal Information. You have the right to request we delete personal information we, or our service providers, store about you. Please keep in mind our response to such a request, upon verification, may include an explanation of the business purpose under which we may retain your information (for example, we would need to retain copies of a business transaction for financial records) in accordance with the CCPA. Non-Discrimination. If you elect to exercise any right(s) under this section of our Privacy Statement, we will not discriminate or retaliate against you. If you are a California consumer and would like to submit a request based on this section of our Privacy Statement, please use this web form, email us at compliance@cambiahealth.com, or call us toll-free at 877-878-2273. Also, be sure to check this policy for updates as we will review it at least every 12 months and make updates as necessary. Identity Verification Requirement. We are required by law to verify that any data access request submitted under the authority of the CCPA was made by someone with the legal right to access the personal information requested. Therefore, prior to accessing or divulging any information pursuant to a data subject access request, under the terms of the CCPA, we may request that you provide us with additional information in order for us to verify your identity, your request, and legal authority (ex. authorized representative). Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. Please indicate in your request if either of these apply, as additional verification may apply (ex. verify consumer’s identify and confirm with impacted person(s) that the authorized agent has permission to submit the request). A verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. A verifiable request must also include sufficient detail that allows us to properly understand, evaluate, and respond to it. In general, our verification process includes reviewing the information submitted in the request, comparing it to the right(s) requested; the number of verification points/methods required by the CCPA; and the type, sensitivity, and risk of information requested, including to the consumer, from unauthorized disclosure or deletion. An account is not required with us in order to make a request. We will use personal information provided in a verifiable consumer request to verify the requestor’s identity and authority to make the request, or otherwise as permitted by the CCPA (ex. record retention). We will respond to a verifiable consumer request within 45 days of its receipt, and if we require more time (up to 90 total days), we will inform you of the reason of the extension in writing. A response to a consumer request will be provided as required by the CCPA, such as through an account (if one exists), or otherwise by mail or electronically. Access Request Responses. Under the CCPA, there may be certain circumstances where we would deny your request to access, receive, or delete personal information we hold. For example, we would deny requests where any such access or disclosure would interfere with our regulatory or legal obligations, where we cannot verify your identity, and/or where exemptions/exceptions permitted by the CCPA apply. We also have the ability under the CCPA to deny requests if it would result in our disproportionate cost or effort. Further, certain rights granted by the CCPA will not be effective until January 1, 2021. However, even where we will not substantively complete a request made under the CCPA, we will still provide a response and explanation to your request within a reasonable time frame and as required by law. Disclosure of Categories. As defined by the CCPA, categories of personal information collected from consumers by us within the past 12 months include: CATEGORIES EXAMPLES COLLECTED A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Yes B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Yes C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Yes D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Yes F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. No G. Geolocation data. Physical location or movements. No H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No I. Professional or employment-related information. Current or past job history or performance evaluations. Yes J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes Personal information may also be collected in the course of a natural person acting as a current or former job applicant, employee, director, officer, or contractor within the context of that natural person’s role. Additional information collected may include emergency contact and information to administer benefits, including to another person. “Personal information” does not include publicly available information, meaning information that is lawfully made available from federal, state, or local government records. “Publicly available” does not mean biometric information collected by a business about a consumer without the consumer’s knowledge. “Personal information” also does not include consumer information that is deidentified or aggregate consumer information. This Notice addresses online and offline practices by us. Information excluded from the CCPA’s scope includes health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Other information excluded includes those covered by the California Confidentiality of Medical Information Act (CMIA) or clinical trial data, and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. Personal information is collected and may be used to provide the services to you, to perform obligations under agreements, to provide information and notifications to you or an authorized representative, to protect the rights and safety of you and/or others, to comply with court and other legal requirements, for business purposes and as otherwise set forth in the CCPA, to conduct organizational and operational needs, and as otherwise described when collecting personal information or within this page. A request for personal information collected and/or deletion, noted above, may involve categories and/or specific pieces of information. However, certain exemptions and exceptions may apply in responding to a request. This business has not sold categories of personal information within the meaning of the CCPA, including minors under 16 years of age. Categories of personal information from our consumers disclosed for a business purpose within the past 12 months include: (A) Identifiers such as real name, alias, postal address, unique identifiers, online identifiers, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or similar identifiers; (B) Categories of personal information as described in California Civil Code 1798.80(e); (C) Characteristics of protected classifications under California or federal law; (E) Biometric information; (I) Professional or employment-related information; and (K) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Business purposes may include auditing (ex. auditing and legal/regulatory compliance), security (ex. detecting security breaches), debugging (ex. identifying and fixing technical errors), short-term uses (ex. ad customization), performing services (ex. processing transactions), internal research (ex. product development), and testing/improvement (ex. improvement of technology). Categories of sources from which personal information was directly and indirectly collected in the past 12 months include from you and/or authorized agents (ex. documents provided to us related to the services for which you/they engage us, and information we collect in the course of providing services to you/them); interaction with our platforms and services (ex. website portal); and third parties (ex. those that provide services such as purchased information, advertising networks, internet service providers, operating systems and platforms, social networks, and data brokers). This could include information obtained on websites and services from third parties that interact with us in connection with the services we perform or are linked to. Categories of third parties with whom the business shared personal information in the past 12 months include authorized agents, affiliates, service providers (such as those described previously), contractors, and authorized third parties. Annual reporting. As required by the CCPA, for the prior calendar year the following information is provided. Number of Requests to Know that we received (0), complied with in whole (0) or in part (0), and denied (0). Number of Requests to Delete that we received (0), complied with in whole (0) or in part (0), and denied (0). Number of Requests to Opt-Out that we received (0), complied with in whole (0) or in part (0), and denied (0). The mean number of days within which we substantively responded to Requests to Know (0 calendar days), Requests to Delete (0 calendar days), and Requests to Opt-out (0 calendar days). Finally, you may be able to request information contained in the California Citizen Rights section in another language where we provide such notices in the ordinary course of business or in an alternative format if you have a disability. Please see our contact information contained within our Privacy Policy. Year: 2020 REQUEST TO KNOW REQUEST TO DELETE REQUEST TO OPT OUT AVERAGE DAYS TO RESPOND Denied 0 0 0 N/A Complied in part 0 0 0 N/A Complied in whole 0 0 0 N/A Total 0 0 0 Average days to respond N/A N/A N/A N/A Contact Us. To make a request please contact us at please contact the us at compliance@cambiahealth.com with “CCPA Personal Information Request” in the subject line, and provide us with full details in relation to your request, including your contact information, the specific name of this business, and any other detail you feel is relevant. You can also use the other contact methods mentioned previously. If you are from another area (ex. state) and believe you are entitled to exercise applicable right(s), please use the email address and/or phone number given and include relevant details. California Consumer Privacy Act Copyright © 2021 Commencement Bay Risk Management Insurance Company™. All rights reserved.