RiverStone International Insurance, Inc

We get most of our information directly from you. We may obtain additional information from outside sources at our own expense. For example, with auto insurance, we routinely obtain a record of accidents, violations and convictions from your State Motor Vehicle Department. Similarly, we may ask a doctor who has treated you to confirm or give us more details about medical information that you have given us.

It is common for an insurance company to ask a consumer-reporting agency to verify and add to information given on an application. Other examples of information gathered from consumer reporting agencies may include: credit scores, current insurer data, previous claims history, undeclared drivers, verification of customer supplied information, registered vehicle owner(s), etc.

Any agency we choose will be discreet and impartial. We may only ask that agency to verify the address, marital status or other information you have given us in your application. If we need more details than you have given us, we may ask the agency to prepare a consumer or investigative report.

The agency may get information by personal or telephone interviews or by writing members of your family, friends, neighbors or other insurance companies with whom you have applied for a policy, and others who you know.

A report may deal with your mode of living, character, general reputation and personal characteristics, such as your health, job and finances. When it is applicable, such a report could also have information on your marital status, driving record, drug or alcohol use, dangerous sport activities or any official record or criminal activity.

If such a report is prepared on you, you have the right to request a personal interview. If you wish to be interviewed, please tell us how the agency can contact you, and every effort will be made to interview you. You have the further right to request a copy of the report by writing to us.

The information we receive about you from a consumer reporting agency may be retained by them and later shared with others to the extent permitted by federal and state law.

For access to personal information about you in our file, send us a written request indicating your full name, address, telephone number, policy number and account number. Within thirty business days after receiving your request, we will contact you and tell you the nature and substance of the recorded personal information in our files. If you wish, we will mail copies of our records to you, or you may visit your RiverStone International Insurance Inc. service office to see and copy the records in person.

Also, we will tell you if we have disclosed items of recorded personal information within the last two years and to whom such information was disclosed during that time or would normally have been disclosed.

We will identify institutional sources of information such as hospitals, clinics, doctors, employers, or insurance-support organizations, but cannot identify sources of information that were obtained from individuals such as friends or neighbors. Also, we are not obligated to provide access to information that we have obtained in connection with or in anticipation of a claim for policy benefits or a civil or criminal proceeding.

In some cases, we may choose to provide medically-related information through a doctor or other medical professional, selected by you, who is licensed to provide medical care relevant to the nature of the information, in order to inform you of a physical condition of which you may not be aware.

Correction, Amendment or Deletion of information

After reviewing information about you in our files, you may request in writing that we correct, amend or delete any item of personal information that you believe is incorrect. Within thirty business days after receipt of your request, we will get back in touch with you.

If we agree that certain items should be corrected, amended or deleted, we will send notification of the change to any person specifically designated by you who may have, within the preceding two years, received such recorded personal information.

We will also notify any insurance-support organization who received the incorrect information or whose primary source of personal information is insurers and has received information within the past 7 years; provided that the organization still maintains personal information about you. We will also notify any insurance-support organization that furnished the personal information that has been corrected, amended or deleted.

If we do not agree to make the correction, amendment or deletion, we will notify you of our refusal, including the reasons. You may file with us a brief statement setting forth what you believe to be the correct, relevant or fair information and the reasons why you disagree with our decision not to correct, amend or delete the original information. Your statement will become a permanent part of our file and will be made part of any future disclosure of the original information. In addition, copies of your statement will be sent to any person or insurance-support organization to which the original information was disclosed.

Information we collect about you will not generally be given to anyone without your consent, except when the disclosure is necessary for us to conduct our business. In that case, we may share information about you without your prior consent to the extent permitted by state privacy laws. Generally, information may be disclosed without your prior consent only to persons or organizations having a business interest in an insurance transaction involving you.

We may disclose information about you without your prior consent:

1. to a person other than an insurance institution, agent or insurance-support organization, provided such disclosure is reasonably necessary to perform a business function. These persons may be involved in processing your application, servicing your policy or processing any claims you may make, such as investigators, appraisers, and attorneys.
2. to an insurance institution, agent or insurance-support organization in order to detect or prevent criminal activity, fraud, material misrepresentation or material nondisclosure in connection with insurance transactions.
3. to a medical-care institution or medical professional for the purpose of verifying insurance coverage or benefits, informing you of a medical problem of which you may not be aware, or when it is reasonably necessary to conduct a company audit of operations and services.
4. to an insurance regulatory authority.
5. to a law enforcement or government authority in order to prevent or prosecute fraud perpetrated against the company or if we reasonably believe that an individual conducted illegal activities.
6. for the purpose of conducting actuarial or research studies.
7. in connection with the marketing of an insurance product or service, provided that no medical record information, privileged information or personal information relating to an individuals’ character, personal habits, mode of living or general reputation is disclosed. In addition, we must afford you the opportunity to indicate that you do not wish us to disclose personal information for marketing purposes. We will not disclose any such information if we receive an indication from you.
8. to an affiliate whose only use of the information will be in connection with an audit of an insurance institution, or agent or the marketing of an insurance product or service.
9. to a group policyholder for the purpose of reporting claims experience or conducting an audit of the company’s or agent’s operations or services.

At RiverStone Insternational Insurance, Inc., we gather information about our customers only in the interest of providing them with quality services at fair and accurate prices. We’re committed to the careful and confidential handling of personal information. If, after reading this notice, you have any questions, please contact us. If you have any questions, please email us Service@RSinsurance.us, or you may contact us at 800.227.2757, Monday through Friday from 8:00 a.m. to 5:00 p.m. ET.

We may obtain personal information through the Channels. The types of personal information we may obtain include:

• contact information (such as name, phone and fax number, email and postal address) for you or for others (e.g., principals in your business);
• information used to create your online account (such as username, password and security question and answer);
• biographical and demographic information (such as date of birth, age, gender, job title/position, marital status and dependent, spousal and other family information);
• purchase and customer service history;
• financial information (such as payment information, including name, billing address and payment card details (i.e., card number, expiration date and security code); bank account information; financial statements; income; and credit score);
• location data (such as data derived from your IP address, country and zip code) and the precise geolocation of your mobile device where we have provided notice and choice, as appropriate;
• audio, electronic, or visual information;
• contact information you provide about friends or other people you would like us to contact;
• inferences about you, including about your preferences;
• clickstream data and other information about your online activities (such as information about your devices, browsing actions and usage patterns), including across the Online Channels and third-party websites, that we obtain through the use of cookies, web beacons and similar technologies and
• other personal information contained in content you submit to us (such as through our “Contact Us” options as shown below).

In addition, in connection with our insurance and financial services products, we may obtain government-issued ID numbers and Tax ID numbers, such as US Social Security numbers.

We use third-party web analytics services in connection with the Online Channels, including Google Analytics, Adobe Analytics and Marketo, which use cookies and similar technologies to collect data (such as IP addresses) to evaluate use of and interaction with the Online Channels. (Learn about Google’s advertising features, including Google Analytics’ currently available opt-out mechanisms)

Please note that providing personal information to us is voluntary on your part. If you choose not to provide us certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of the Online Channels.

Like most companies, RiverStone International Insurance, Inc. uses cookies and similar technologies (“cookies”) on our websites to personalize and enhance your experience on our sites.

Cookies contain small amounts of information which are downloaded to your device when you visit our website. Cookies are sent back to our website to allow us to recognize your device.

Essential Cookies allow us to recognize your device to help you navigate efficiently to obtain the information and services you have requested.

Analytical and Customization Cookies allow our site to remember your preferences such as language selection, and help you to view information that is most relevant to your interests; these cookies also help us to maintain and improve our websites by providing information on how visitors find and use the sites, and how well the sites are performing.

Advertising Cookies may be used in some cases to make advertising messages more relevant to you.

Unless you disable the cookies on our website, by using our website you agree to our use of those cookies.

Most browsers allow you to manage cookie preferences. If you decide to disable cookies on our site, you may not be able to take full advantage of all our website features once you have done so.

To enhance your experience on our websites, we sometimes embed content and sharing tools from other third-party sites, such as “like” buttons from social networking sites; these third-party sites may also place and access cookies on your device. RiverStone International Insurance, Inc. does not control the placement or access of these third-party cookies. Please review the privacy policies of these third parties to familiarize yourself with their practices.

We may use the personal information we obtain to:

• provide and administer our products and services;
• process and fulfill orders and keep you informed about the status of your order;
• communicate about and administer our products, services, events, programs and promotions (such as by sending alerts, promotional materials, newsletters and other marketing communications);
• conduct and facilitate surveys, sweepstakes, contests, focus groups and market research initiatives;
• perform data analytics (such as market research, trend analysis, financial analysis and customer segmentation);
• engage in ad re-targeting and evaluate the effectiveness of our marketing efforts (including through our participation in ad networks);
• provide customer support;
• process, evaluate and respond to requests, inquiries and applications;
• create, administer and communicate with you about your account (including any purchases and payments);
• administer and register participants in our courses;
• provide investor services;
• conduct marketing and sales activities (including generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
• operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services; developing new products, services and Online Channels; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);
• verify your identity and protect against and prevent fraud and other unlawful activity, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;
• conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms (such as this Privacy Policy and other Online Channels terms of use); and
• maintain and enhance the safety and security of our products, services, Online Channels, network services, information resources and employees.

We may combine personal information we obtain through Online Channels with information we obtain through Offline Channels, as well as other information, for the purposes described above. We may anonymize or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we identify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.

Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes. The legal basis for processing your personal information as described above will typically be one of the following:

Your consent;

• Performance of a contract with you or a relevant party;
• Our legitimate business interests; or
• Compliance with our legal obligations.

We do not sell or otherwise disclose personal information about you except as described here or at the time of collection.

We may share personal information within RiverStone International for the purposes described in this Privacy Policy.

We may share personal information with service providers we have retained to perform services on our behalf (such as payment processing, order fulfillment, customer support and data analytics). These service providers are contractually required to safeguard the information provided to them and are restricted from using or disclosing such information except as necessary to perform services on our behalf or to comply with legal requirements.

We may share personal information with our joint marketing partners and other business partners for the purposes described in this Privacy Policy.

We may disclose personal information about you (1) if we are required or permitted to do so by applicable law or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent.

We reserve the right to transfer to relevant third-parties any information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business combination. In such case, we will require the relevant third parties to provide comparable levels of protection as RiverStone International Insurance, Inc provides with respect to the information we share.

We may transfer the personal information we collect through the Channels to, and store such data in, other countries, including the U.S., which may have different data protection laws than the country in which the information was provided. If we do so, we will transfer the personal information only for the purposes described in this Privacy Policy. To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information.

RiverStone International Insurance, Inc’ s privacy practices, described in this Privacy Policy, comply with the APEC Cross Border Privacy Rules (CBPR) system. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies.

We offer you certain choices in connection with the personal information we obtain about you. To update your preferences, limit the communications you receive from us or submit a request, please contact us as specified in the How To Contact Us section of this Privacy Policy. You also may exercise choice over how information about your interests is used by ad networks to deliver you relevant advertising. To learn how to opt out of ad network interest-based advertising in the United States, please visit Digital Advertising Alliance, the Network Advertising Initiative, and TrustArc. In the European Union, please visit European Interactive Digital Advertising Alliance. The Online Channels are not designed to respond to “do not track” signals received from web browsers.

To the extent provided by the law of your jurisdiction, you may have the right to (1) access certain personal information we maintain about you; (2) request that we update, correct, amend, erase or restrict your personal information; or (3) exercise your right to data portability. Where provided by law, you may withdraw consent you previously provided to us or object at any time to the processing of your personal information on legitimate grounds relating to your particular situation, and we will apply your preferences going forward as appropriate. To request to exercise these rights, please contact us as indicated in the How To Contact Us section of this Privacy Policy.

To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response. RiverStone International Insurance, Inc endeavors to respond to complaints within thirty days of receipt.

Transmission We maintain administrative, technical and physical safeguards, consistent with legal requirements where the personal information was obtained, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us through the Channels. Retention of Personal Information To the extent permitted by applicable law, we retain personal information we obtain about you as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Privacy Policy or (2) we have another lawful basis, stated in this Privacy Policy or at the point of collection, for retaining that information beyond the period for which it is necessary to serve the original purpose for obtaining the personal information.

See Notice to CA residents below Children’s Personal Information

The Online Channels are designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13 through the Online Channels. If we become aware that we have collected personal information from a child under the age of 13, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information, please contact us as specified in the How To Contact Us section of this Privacy Policy.

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices. We will indicate at the top of this Privacy Policy when it was most recently updated.

If you have any questions or comments about this Privacy Policy or if you would like us to update information we have about you or your preferences, please contact us:

Attn: Chief Compliance Officer RiverStone International Insurance,
75 Sam Fonzo Drive
Beverly, MA 01915
United States
800.227.2757
rs.privacy.inquiry@rsinsurance.us

RiverStone International obtains consent to the collection, use and disclosure of personal information, except where inappropriate.

In obtaining consent to the collection, use and disclosure of personal information, the purpose for which information is collected, used or disclosed is either obvious by the very nature of the transaction or if not, we state the purpose, either at or before the time the information is collected. When we do collect personal information, we collect only that personal information which is necessary to such obvious or stated purpose.

Personal information is typically collected and used by us for insurance purposes such as, assessing risk, processing applications for insurance coverage, providing and administering insurance products and related services and to determine the status of insurance coverage, to investigate and handle claims, administer insurance benefits and to prevent or deter fraud. Such information will be used solely to facilitate the products and services requested or as provided or permitted by law.

We consult our existing files for these purposes. An individual may decline to consent, or revoke consent, to the collection and use of personal information for these insurance purposes but in that case insurance products and related services and benefits and the assessment of claims may be limited or terminated.

Whenever practical, we collect information directly from the individual concerned. In some instances and as is common in the underwriting of insurance and the investigation of insurance claims, we verify information and obtain information from independent sources and organizations.

We use personal information in accordance with the consent provided by the individual to whom the information relates, in accordance with this Privacy Policy, our contractual rights and obligations and the law.
RiverStone International employees and representatives do not use personal information for purposes other than as required in the performance of their employment duties.

RiverStone International maintains procedures to ensure that the information we collect and use is accurate, up-to-date, and as complete as possible. However, we rely on individuals to disclose all material information to us and to inform us of any changes. With proof of entitlement, a request to access and if applicable correct information in our possession may be made by contacting the RiverStone International Privacy Officer for Canada at the address set out below in the section called “Contacting the RiverStone International Privacy Officer for Canada”.

We apply appropriate safeguards to our computer networks and physical files and we restrict access to personal information to those RiverStone International employees, authorized administrators, reinsurers, consultants or insurance representatives who need to know that information in order to underwrite or administer insurance products and services.

Personal information is sought and exchanged with both affiliated and unaffiliated insurance companies, reinsurers, and insurance industry organizations at the time of assessing an application for insurance and any renewal, extension, variation or cancellation of any issued policy, as well as in the event of any claim, to the extent necessary for industry statistical purposes or to assess and rate a specific risk, determine the status of coverage, and investigate claims. We also share information to combat fraud; where permitted or required by law; or, at the request of government regulators.

RiverStone International sometimes retains an affiliated company or an independent third party or reinsurer (“authorized administrator”) to perform RiverStone International’s on behalf, certain functions in support of the products and services RiverStone International provides. Such functions could include the underwriting, offering or administering of RiverStone International ‘s financial products and services or any related claims. Accordingly, in certain instances these affiliates or third parties will be provided with personal information to the extent that it is necessary in the performance of those specific reinsurance, underwriting, marketing, consulting, administrative, rehabilitative, claims, investigation or related services. RiverStone International obligates these affiliates and third parties to use and take steps to protect personal information in accordance with the requirements of this Privacy Policy.

Some authorized administrators may be located in the United States and in those cases personal information will be subject to disclosure pursuant to the laws of the United States, which may include disclosure to government, judicial, law enforcement or regulatory agencies of the United States.

For information about how you may obtain access to written policies about RiverStone International’s policies and practices with respect to service providers outside Canada, please contact the RiverStone
Privacy Officer for Canada, using the contact information set out below in the section called “Contacting the RiverStone International Privacy Officer for Canada”. The RiverStone International Privacy Officer for Canada will be able to answer any questions you have about the collection, use, disclosure or storage of personal information by authorized administrators outside Canada.

We do not sell our customer lists or other personal information.

We retain personal information only for so long as is necessary to fulfill the purpose for which it was collected and to meet our legal and contractual obligations. If personal information is no longer required, it will be destroyed or rendered anonymous. Given the nature of insurance and our on-going exposure to potential claims, where necessary, some of the information we collect for insurance purposes is kept indefinitely.

An individual or a person authorized in writing to act on his/her behalf may, with satisfactory identification and proof of entitlement, request access or, if applicable, request a correction of personal information, which RiverStone International has in its possession.

The right to access is not absolute. For example, there is no right to access and we may decline a request for access, if the information requested is subject to a legal privilege.

We do not provide personal health information directly to individuals unless the individual provided it directly to us. Instead we provide access to personal health information through the individual’s health care professional.

We may charge a reasonable fee in advance for copying and sending information you have requested and to which you have a right of access.

Contact:
The RiverStone International Privacy Officer for Canada
75 Sam Fonzo Drive
Beverly, MA 01915

Toll-Free: 1-800-227-2757

Should you have questions about our privacy practices; or a request to access or correct your personal information, please include your name, address and, if applicable, your policy number.

RiverStone International is sensitive to privacy issues on the Internet. We believe it is important that you know how we treat the information we receive about you online.

In general, you can visit RiverStone International on the World Wide Web without telling us who you are or revealing any information about yourself. Our web servers collect the domain names, not email addresses of visitors. RiverStone International uses this information to measure the use of our site.

RiverStone International shares website usage information about visitors to our website with a reputable third party for the purpose of targeting our Internet banner advertisements on this site and other sites.

To do this, we use clear GIFs, or pixel tags, on this site, which allow us to recognize a browser’s cookie when a browser visits this site. A cookie is a tiny element of data that a website can send to your browser, which may then be stored on your hard drive so we can recognize your RiverStone International website usage when you return. You may set your browser to notify you when you receive a cookie or you have the option to disable the use of cookies altogether.

The information we collect and share through this technology is not personally identifiable.