State of California Privacy Notice – As Prescribed by the California Consumer Privacy Act of 2018

Effective Date: January 1, 2020

Scope of this Privacy Notice

These California Resident Privacy Notice terms and conditions “(Privacy Notice”) are effective January 1, 2020 and supplement the information contained in the Atlas General Insurance Services, LLC.’s governing website Privacy Statement. This Privacy Notice applies solely to consumers who are California residents

Atlas General Insurance Services, LLC. through its operating subsidiaries (“We”) is outlining The California Resident Privacy Notice to inform on the personal information we collect or process about California residents in connection with the services we provide or offer specifically to our customers as a consumer, including through any site, application, or product that links to this Privacy Notice (the “Service”), how we use, share, and protect that personal information, and what your rights are with respect to your personal information that we gather and process.

Information We Collect

Although Atlas business under the CCPA falls under certain exemption that generally is applicable to the insurance industry, but under limited circumstances we are acting as a business and some of your personal information is not otherwise excluded as set forth by the CCPA. Thus, pursuant to California law, some California residents have specific rights regarding how their personal information is collected.

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare an Acord application or insurance application, we will use that information to prepare a quote and may submit it to the applicable insurance carriers.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for underwriting, billing, collections and audits.
• To improve our website and present its contents to you.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental and State Insurance regulations.
• To review applications submitted for agency partner-relationships agreements and contracts, including any appointments that may require background checks if requested by our insurance carriers. (pursuant by the FCRA of 1970)
• To maintain licensing requirements as needed by our carrier agreements and State Insurance Departments.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our Brokers and agents. For example, from documents that our brokers and agents provide to us related to the services for which they engage us.
• Indirectly from our brokers or their agents. For example, through information we collect from our brokers and agents in the course of providing services to them.
• Directly and indirectly from activity on our website (www.atlas.us.com). For example, from submissions through our website portal or website usage details collected automatically.
• Under certain circumstances, we may collect personal information for the Service pursuant to a contract we have with a commercial client (our “Client”) in such instances, we may be acting as a “service provider” and are obligated to process the personal information we collect or are provided in connection with the Service in accordance with instructions from or the contract with our Client, which is the “business” and ultimately responsible for determining how customers personal information will be handled.

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.

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) 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 (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us .

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS information contained in the Privacy Statement of Atlas and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.