Patra Web Privacy Policy

This policy applies to information we collect:

• On this Website
• In email, text, and other electronic messages between you and this Website
• From a Third-Party Site to which you have provided information and consented to such information being share with Patra

It does not apply to information collected by:

• Offline or any other means, including any other website operated by Company or any third party, unless you expressly provided consent for the third-party to share your information with Patra
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website and refrain from providing your consent to any third-party that shares your information with Patra. By accessing or using this Website, or providing your consent on a Third-Party site, you agree to this privacy policy. This policy may change from time to time (see “Changes to Our Privacy Policy” below). Your continued use of this Website or consent on a Third-Party Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features, or through any Third-Party Site. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at: compliance@patracorp.com.

We collect several types of information from and about users of our Website, and through select Third-Party Sites including information:

• That identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you, your household or your device (“personal information”). Personal information includes name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline
• That is about you but individually does not identify you
• About your internet connection, the equipment you use to access our Website and usage details

Personal information does not include:

• Publicly available information from government records
• Deidentified or aggregated consumer information
• Information excluded from the scope of the California Consumer Privacy Act (CCPA), like:
  • Health or medical information covered by the Heath Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBC) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

In particular, we have collected the following categories of information from consumers within the last twelve (12) months:

*Descriptions as to the reasons we may collect personal information are included in the enumerated list below under “How We Use Your Personal Information” below.

We collect this information:

• Directly from you when you provide it to us
• From a Third-Party Site where you have directly provided information and consented to having that information shared with Patra
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies
• As exchanged in the course of providing services in a business to business relationship

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website
• Records and copies of your correspondence (including email addresses), if you contact us
• Information contained in applications for employment and / or participation any job placement program that we may offer directly

• Information that you provide by filling in forms on the Third-Party Site and consent to sharing with Patra

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website
• Information about your computer and internet connection, including your IP address, operating system, and browser type

The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Store information about your preferences, allowing us to customize our Website according to your individual interests
• Recognize you when you return to our Website

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website

As we work with insurance brokers, MGAs and carriers (our clients), to provide insurance processing, account management, and technology services to create growth and efficiency in the insurance marketplace, we may receive personal information from or related to your insurance policies and application information. Such information helps us to effectively provide services directly to our clients, and indirectly to you.

Before any information is collected in the course of providing services, we enter into a contractual relationship with the client that describes the limited purpose for which we can collect the information and requires us to keep that personal information confidential.

We use information that we collect about you or that you provide to us, including any personal information:

1. To present our Website and its contents to you
2. To provide you with information, products, or services that you request from us
3. To notify you about changes to our Website or any products or services we offer or provide though it
4. To fulfill or meet the reason you provided the information, even if we receive it indirectly through you due to a business to business relationship. For example, if you share your name and contact information for the purpose of obtaining an insurance policy, then we will use that information to fulfill your request. We may also save your information to help manage your account or fulfill future requests
5. To respond to law enforcement requests as required by applicable law, court order, or government regulations
6. As described to you when collecting your personal information or as otherwise set forth in the CCPA
7. For any other purpose with your consent
8. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a growing concern or as part of bankruptcy, litigation, or similar proceeding, in which personal information help by us about our website users and/or clients is among the assets transferred

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy to the following categories of third parties:

• To our subsidiaries and affiliates
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Patra Corporation’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Patra Corporation about our Website users is among the assets transferred
• To fulfill the purpose for which you provide it
• To run background checks as part of an application for your employment
• For any other purpose disclosed by us when you provide the information
• With your consent

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Patra Corporation, our customers, or others

In the preceding 12 months, we have disclosed the following categories of personal information for a business purposes:

• Category A: Identifiers
• Category B: California Customer Records personal information categories
• Category C: Protected classification characteristics under California or federal law
• Category D: Commercial information
• Category F: Internet or other similar network activity
• Category G: Geolocation data
• Category I: Professional or employment-related information

We disclose your personal information for a business purpose to the following categories of third parties:

• Our subsidiaries or affiliates
• Service Providers
• Insurance Carriers

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You can do this via the alert on that shows up when you visit our website, or to learn more about how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of our site may then be inaccessible or not function properly.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us, or is collected for a business purpose, is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

To request removal of your personal information from our general records and/or from the Patra Insurance Network, please contact compliance@patracorp.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

The California Consumer Privacy Act (CCPA) provides consumer (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you
• The categories of sources for the personal information we collected about you
• Our business or commercial purpose for collecting or selling that personal information
• The categories of third parties with whom we share that personal information
• The specific pieces of personal information we collected about you (also called a data portability request)
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • Sales, identifying the personal information categories that each category of recipient purchased
  • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide the service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty, or otherwise perform our contract with you
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
3. Debug products to identify and repair errors that impair existing intended functionality
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.)
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with u.
8. Comply with a legal obligation
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it

Exercising Access, Data Portability, and Deletion Requests

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• 1-855-200-0454
• Completing this form
• compliance@patracorp.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. When designating an authorized agent, you must i) submit a written permission with the request to know or delete and ii) directly verify your identify with the business. This does not apply if the authorized access is acting under a power of attorney.

You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The 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
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Formant

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

To ask questions or comment about this privacy policy and our privacy practices, contact us at info@patracorp.com. If you have a concern about how we have used your information, please send an email to compliance@patracorp.com.