...a Frenkel & Co., Inc. Company

Frenkel Privacy Policy

Frenkel and its affiliated companies (collectively, the “Company”) understand the importance of protecting the privacy of visitors to this website (the “Site”). This Privacy Policy discloses the Company’s practices relating to collection, use and disclosure of information that you may provide through this Site. Before you submit any personal information to the Company through this Site, please thoroughly review this Privacy Policy, and contact us if you have any questions.

Intended Audience of this Site
This Site is primarily intended for business use by: (i) clients and potential clients seeking information in order to satisfy their insurance and related needs; and (ii) individuals or entities which may be interested in learning about the Company and/or career opportunities and applying for employment with the Company.

This Site is not intended to attract or be used by children under the age of 13 without verifiable parental consent, and the Company will not knowingly collect personal information from such visitors.

Your Consent
By using this Site, you agree with and accept the terms of this Privacy Policy. Whenever you submit personal information through this Site, you consent to the collection, disclosure, use and retention of that information in accordance with this Privacy Policy.

Collection of Information About You
The Company collects information primarily from its clients and prospective clients to procure and modify insurance coverage or process claims and from prospective employees. We may collect such information directly from you through this Site, in responses to our specific requests and/or via e-mail and web input screens and forms, and through traditional applications and other paper forms, correspondence and communications. The types of personal information we may collect includes, among other things, your name, address, e-mail address, telephone number, Social Security or other identification number, income, assets, and financial goals. With the exception of any personal information that may be submitted for human resources purposes by prospective employees, you should carefully limit the personal information you voluntarily provide to strictly that which is necessary for the Company to respond to your inquiry or otherwise address your insurance needs.

The Company also obtain personal information about our clients from other sources. We gather such information in connection with client transactions with or through us (such as coverages purchased, premiums paid, payment history and methods of payment).In some instances, we receive personal information in communications with insurance companies that have issued or are considering issuing insurance policies to our clients. We also may receive personal information about our clients, including medical information, through processing claims.Personal information about clients likewise may be obtained from consumer reporting agencies, such as through credit reports or motor vehicle reports.

Automatic Collection of Information
As you navigate this Site, certain limited information can and may be collected automatically from you without your active involvement, using methods known as cookies and navigational data collection. Some of the information (e.g., type of web browser) does not identify who you are. Other information, such as your Internet Protocol (“IP”) address, may identify you indirectly, when supplemented with other commercially available sources of information.

When you visit this Site, we may send to your computer one or more cookies, which are small text files containing a string of characters. These cookies uniquely identify your computer to the Site. We may use cookies to improve the quality of our service by storing user preferences and tracking user trends. Most web browsers are set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of this Site may not function properly if your cookies are disabled.

Furthermore, our computer servers automatically record information that your browser sends whenever you visit a website. These server logs may include information, such as the portions of the Site accessed, the IP address assigned to your computer, the type of browser used by your computer, the date and time of your access to the Site, and one or more cookies that may uniquely identify your computer.

Collection, Disclosure, Use and Retention of Information Other Than Employee Data
Except as otherwise stated at the point of collection, we may use your information for improving the content of the Site, customizing this Site to your preferences, communicating information to you and subsequently updating such information, internal marketing and research purposes, and as further specified in this Privacy Policy. We may combine such information with other passively or actively collected information unless we specify otherwise at the point of collection.

The Company may transfer certain of your information, including personally identifiable information to unaffiliated third parties, including (i) carriers and/or other financial institutions to secure or facilitate quotations for coverage, obtain changes in or renewals of existing insurance coverage and to assist in the submission or processing claims; (ii) claims representatives and adjusters involved with processing claims; and (iii) contractors we use to support our business (e.g., marketing services, fulfillment services, technical support, and delivery services). In such cases, we will ask these third parties to agree to treat your information in accordance with this Privacy Policy or as you may otherwise have previously consented. We do not share your personal information with third parties for their direct marketing purposes unless you have affirmatively agreed in advance to such disclosure.

The Company also may transfer such information: (i) in connection with the sale, assignment or other transfer of the business function of the Company to which the information relates, in which case we will ask any such buyer, assignee or transferee to agree to treat it in accordance with this Privacy Policy; or (ii) in compliance with subpoenas or other court orders, in response to inquiries and requests from regulatory authorities, in connection with the prevention or detection of fraud, or as otherwise permitted or required by law. In addition, we will make full use of all information acquired through this Site or otherwise that is not identifiable to you.

Collection, Disclosure, Use and Retention of Employee Data
This Site also may collect personal information from prospective employees for human resources purposes. The Company also may collect personal information for human resources purposes from current, prospective and past employees through internal sources that are unrelated to this Site. All such information, regardless of the source, is collectively referred to in this Privacy Policy as “Employee Data.” Employee Data may be collected, disclosed and used to:

The Company will not use Employee Data for any other purposes and will not disclose it to any person except for these stated purposes, unless authorized or permitted by applicable law. The Company adheres to a self-regulatory program that complies with the Safe Harbor privacy principles set forth in the July 2000 agreement between the European Union (“EU”) and the U.S. Department of Commerce. For more information about the Safe Harbor Program, see http://www.export.gov/safeharbor.

Choices for Disclosure and Use of Personal Information
You may choose to prevent the Company from disclosing or using your personal information under certain circumstances (“opt out”). You may opt out of any disclosure or use of your personal information for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization. Furthermore, even where your personal information is to be disclosed and used in accordance with the stated purposes in this Privacy Policy, you may elect to opt out of such disclosure to and use by a third party that is not acting as an agent of the Company. On the other hand, the Company may disclose your personal information to a third party acting as its agent where this third party subscribes to the Safe Harbor Principles (the “Principles”) or agrees in writing to provide at least the same level of privacy protection as is required by the relevant Principles. Opting out of the disclosure and use of your personal information may prevent you from being hired or retained as an employee by the Company or participating in certain employee programs.

In the event that the Company collects sensitive information (i.e., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sexual orientation or activities of the individual), such information will not be disclosed or used by the Company for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization unless you affirmatively consent to such disclosure and use.

Access and Correction
To access your personal information in the possession of the Company and correct inaccuracies of that information in our records, please contact us in the manner specified in the “How to Contact Us” section below. We ask individuals to identify themselves and the information requested to be accessed and amended before processing such requests, and we may decline to process requests in limited circumstances as permitted by applicable privacy legislation.

The Company takes reasonable measures to safeguard your personal information against unauthorized access, disclosure, copying, use or modification, whether or not in electronic format. We use reasonable industry-standard technological precautions, such as Secure Socket Layer technology in an effort to protect your personal information as you transmit it electronically from your computer to this Site and, furthermore, to protect it from loss, misuse and unauthorized access, disclosure, alteration or destruction. Furthermore, the Company requires that employees and third-party administrators/processors access your personal information only on a “need-to-know” basis.

You should keep in mind that no combination of security measures can ever provide guaranteed protection all the time. We caution you that e-mail may be particularly vulnerable to unauthorized interception, eavesdropping, modification and spoofing, and, therefore, you should take special care in deciding what information you send to us via e-mail. Moreover, where you use passwords, ID numbers or other special access features on this Site, it is your responsibility to safeguard them.

This Privacy Policy regarding personal information received from the EU conforms to the Safe Harbor Principles and is accurate, comprehensive, completely implemented and accessible. Any questions, concerns or complaints regarding this Privacy Policy or the Company’s treatment of personal information may be communicated by contacting us through this Site, sending an e-mail message to us at privacy@frenkel.com or by writing to us at Privacy Officer, Frenkel, 350 Hudson Street, 4th Floor, New York, NY 10014 U.S.A. When we receive a formal written complaint, our Privacy Officer will contact the author within a reasonable period of time regarding his or her concerns and attempt to resolve these concerns directly with this individual. In the event that informal resolution of such concerns is not fruitful, a complainant also may be able to seek independent review and resolution of his or her complaint by EU Data Protection Authorities. To learn more about the enforcement role of EU Data Protection Authorities, see http://ec.europa.eu/justice_home/fsj/privacy/index_en.htm.

If a complainant believes that the Company has engaged in possible unfair or deceptive practices and legal or regulatory violations in connection with its privacy obligations, he or she may file a complaint with the Federal Trade Commission through its website http://www.ftc.gov. We will cooperate with the EU Data Protection Authorities and/or the U.S. Federal Trade Commission to resolve any complaint regarding the collection, disclosure, use and retention of personal information that cannot be resolved between the Company and the complainant.

The Company has in place procedures for maintaining the confidentiality of personally identifiable information. A statement verifying the Company’s compliance with EU Safe Harbor Principles is signed by a corporate officer of the Company at least once a year and will be made available upon request from interested individuals or in the context of an investigation or a complaint about non-compliance. Indeed, the Company retains its records on the implementation of its Safe Harbor privacy practices and makes them available upon request in the context of an investigation or a complaint about non-compliance to the EU data protection authorities or to the Federal Trade Commission.

Links to Other Websites
This Site may contain links or references to third-party websites that are not affiliated with the Company. The inclusion of any link does not imply the Company’s endorsement of any other company, its websites, or its products and/or services. Any such linked websites have separate and independent privacy policies which we encourage you to read carefully. Please be aware that the Company has no control over linked third-party websites and, therefore, no responsibility or liability for the manner in which the organizations that operate such websites may collect, disclose, use or otherwise treat your personal information.

Other Terms
Your use of this Site is subject to our Terms and Conditions of Use.

How to Contact Us
To correct or update any personal information previously collected by us, please follow instructions at the original point of collection on this Site, send an e-mail message to us at privacy@frenkel.com, or write to us at Privacy Officer, Frenkel, 350 Hudson Street, 4th Floor, New York, NY 10014 U.S.A.

Changes to This Privacy Policy
We are required to send our clients notice of our Privacy Policy every year as well as when we adopt changes to this policy.Consequently, we will be sending you supplemental notices at least annually by regular mail.In addition, under provisions of the law and implementing regulations, we may have to obtain your written authorization to disclose certain personal information regarding you, and in some instances other members of your household, in connection with the performance of our services on your behalf.

If this Privacy Policy changes, the revised policy also will be posted on this Site. Please check back periodically and especially before you provide any personal information to the Company. This Privacy Policy was last updated on – October 29th, 2007.

Copyright © 2009 Frenkel & Co., Inc.

Hedge Fund Insurance
a division of Frenkel & Co., Inc.
350 Hudson Street, 4th Floor, New York, NY 10014
Phone: 212-488-0270  Fax: 212-488-0432