MIND PRIVACY PRACTICES

 

Protecting the privacy and confidentiality of information about our customers is very important to Midland Information Network Development of Michigan (collectively, "MIND"). Accordingly, we strive to comply with each of the following practices in everything we do:

 

-          We do not sell, rent, lease or otherwise disclose personal information of our customers for purposes unrelated to our products and services. The personal information of our customers is of paramount importance to us. Therefore, we provide this information only to our employees, agents and third parties as required to allow them to help us develop and provide our insurance and employee benefit products and services.

-          We work to ensure information integrity and security. We use technology tools and design our business practices to help ensure that the personal information of our customers is properly gathered, stored and processed. We also work to maintain the security of, and internal and external access to, the personal information of our customers through the use of technology and our business practices.

-          We expect our agents and employees to respect the personal information of our customers. MIND has business policies and practices in place to help ensure that our employees and agents carry out these practices and otherwise protect personal information about our customers. Both employees and agents are subject to censure, dismissal or termination for violation of these policies.

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These Privacy Practices apply to our US. customers. Due to legal and cultural differences, our practices may vary outside the United States.

 

PRIVACY NOTICE

MIND and our agents provide this notice to let you know about the current privacy practices of MIND and our agents. You do not need to do anything in response to this notice. This notice is merely to inform you about how we safeguard your information.

 

Collection of Information

 

As part of MIND’s normal activity and operating procedures, MIND (and our agents acting on our behalf) need to obtain information to determine an individual’s eligibility for membership and our services, and to perform our internet functions. MIND and our agents may collect nonpublic personal information (which includes both nonpublic personal financial information) about MIND’s customers, including:

• Information from our customers (including names, addresses, financial and education affiliation information);

• Information about the customers’ transactions with MIND or our agents (including payment information);

• Information from consumer reporting agencies (including creditworthiness and credit history) and public institutions (including information regarding general character and participation in illegal activities)

 

Disclosure of Information

 

MIND may disclose the nonpublic personal financial information we collect, as described above, as well as information about your transactions with us (such as spam attacks, viruses and abuse) to our agents or other third parties who perform services for us or functions on our behalf, including in some circumstances the marketing of MIND products. We may also disclose the nonpublic personal financial information we collect to other third parties as authorized by you, or as required or permitted by law.

 

Our agents will make disclosures of our customers' nonpublic personal financial information only while acting on MIND’s behalf and, furthermore, will make such disclosures only as MIND itself is permitted to make.

 

Neither MIND nor our agents will use or share with other parties any nonpublic personal information about MIND customers for any purpose other than the performance of Internet functions by MIND or on our behalf, or to which the customer consents.

 

Neither MIND nor our agents will further disclose any nonpublic personal information about a former customer of MIND other than as may be required or permitted by law.


Confidentiality and Security

 

MIND and our agents will safeguard, according to strict standards of security and confidentiality, any information we collect, receive or maintain about MIND’s customers. MIND maintains administrative, technical and physical safeguards to ensure the security and confidentiality of our customer information and records, to protect against anticipated threats or hazards to such records, and to protect against unauthorized access to or use of such information or records.

 

Internally, MIND limits access to our customers' information to only those employees who need access to the information to perform their job functions. Employees who misuse information are subject to disciplinary actions. Externally, we do not disclose customer information to any third parties unless we have previously informed the customer of the disclosure, have been authorized to do so by the customer, or are required or permitted to make the disclosure by law or our regulators.

 

NOTICE OF INFORMATION PRACTICES

 

MIND may obtain information about you and any other persons proposed for membership. Some of this information will come from you and some may come from other sources. That information and any other subsequent information collected by MIND may, in some circumstances be disclosed to third parties without your specific consent. You have the right to access and correct the information collected about them except as it pertains to a civil or criminal proceeding. They also have the right to receive the specific reason for an denial of service decision in writing. If you wish to have a more detailed explanation of our information practices, please submit a written request to: MIND, ATTN: Client Services, 2250 Old Pine Trail, Midland, Michigan 48642.