We collect nonpublic personal information about our individual clients and about the employees and members of our corporate and association clients (and in certain cases their family members) (collectively, “Participants”) from the following sources:
- Information we receive from Participants on paper and online applications or other forms, or in connection with providing services to Participants.
- Information we receive as a result of processing and verifying the information provided to us about our Participants.
- Information we receive from affiliates, insurers, intermediaries, third party providers and others about our Participants.
- Information we receive from consumer reporting agencies.
- Information available from external sources (such as publicly available records).
We do not disclose any nonpublic personal information, including financial information, about our Participants or former Participants to any third parties, except as stated in this policy, as otherwise required by law or as otherwise may be authorized by you from time to time. We may share this information outside Steamboat IS or its affiliate OSC in order to process or complete, or otherwise in connection with, the transaction for which the information was provided or as otherwise authorized by our Participants. The law permits us to share this information with our affiliates. We also may disclose any of the information we collect to companies that perform marketing services on our behalf or to companies with which we have joint marketing agreements.
Confidentiality and Security of Information
We restrict access to nonpublic personal information about Participants to those employees of Steamboat IS and OSC who need to know that information in order to provide products or services to our Participants. We have in place physical, electronic, and procedural safeguards in order to protect any nonpublic personal information we maintain regarding our Participants.
Whatever the legal environment, we have constantly held ourselves to the highest of professional standards. At Steamboat IS and OSC, we strive always to maintain the highest level of confidentiality for our Participants.