WELLABROAD PRIVACY POLICY

WELLABROAD® is a service offered by SEVEN CORNERS, INC., an Indiana corporation (“Seven Corners”). Seven Corners makes this website and all other websites located at the domain names wellabroad.com and mytravelinsurance.com (collectively, the “Site”), including all information, documents, communications, files, text, graphics, software, and products available through the Site (collectively, the “Materials”) and all services operated by Seven Corners and third parties through the Site (collectively, the “Services”), available for your use subject to the terms and conditions set forth in this agreement and any amendments that Seven Corners may publish from time to time (collectively, the “Terms of Use”). Seven Corners may freely revise these Terms of Use at any time without any prior notice, and your use after such change signifies your agreement to the Terms of Use as changed.

Seven Corners is sensitive to individuals’ concerns about their privacy. This Privacy Policy was developed as an extension of Seven Corners’ commitment to combine quality services with integrity in dealing with its users. This Privacy Policy is designed to assist you (“you,” “your” or “User”) in understanding how Seven Corners collects, uses and safeguards the Personal Information (as defined below) you provide to it and to assist you in making informed decisions when using this Site and the Services.

1. Agreement. By using the Site, you signify your agreement to and acceptance of this Privacy Policy. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, YOU ARE NOT AUTHORIZED TO ACCESS OR USE THE SITE.
2. Policy Scope. This Privacy Policy applies to all information collected or gathered through this Site only and does not necessarily reflect practices with respect to information collected or gathered through off-line means or through other websites that the associated divisions or affiliates of Seven Corners operate.
3. Information Seven Corners May Collect or Gather. Seven Corners will only collect Personal Information (as defined below) that you voluntarily provide to us, including the following:
• (a) Personal Information. The term “Personal Information” includes any information that can be used to contact, identify, or locate you. This information may include, without limitation, your name, policy number, social security number, address, phone number, e-mail address, and family member information. Personal Information will not be collected from you without your knowledge. You may browse this Site without revealing or providing any Personal Information. Providing Personal Information is always voluntary. We provide various forms that can be submitted at your discretion to request information and conduct transactions via this Site. On each of the forms, we ask for information necessary to provide you with the information or service provided by the form and possibly certain other information that will assist us in providing better products, services and information to you.
• (b) Non-personal Information. Although Seven Corners does not collect Personal Information from you at this Site unless you provide it voluntarily, Seven Corners does collect information that is compiled in anonymous and aggregate form and is not used to locate, contact, or identify you specifically (“Non-personal Information”). Seven Corners may capture and use Non-personal information regarding, without limitation, site usage, pages viewed, application used, files downloaded, and browser type. Seven Corners uses such Non-personal Information only for the purpose of maintaining and improving the Site.
• (c) Cookies. Seven Corners uses cookies on certain pages of this Site. Cookies are stored on your hard drive, not on our Site. You are always free to decline our cookies if your browser permits, although in that case you may be required to re-enter certain information more frequently during a visit to our Site.
4. Seven Corners’ Use of Your Information. Seven Corners uses your Personal Information to assist in locating service providers around the world. It also uses your Personal Information internally to improve its marketing and promotional efforts, to statistically analyze Site usage, to improve the Site’s content and offerings and to customize the Site’s content and layout.
5. Seven Corners’ Disclosure of Your Information. Seven Corners does not rent or sell its e-mail address list. Seven Corners may share segments of your Personal Information with our affiliated entities as necessary to complete a transaction or service that you specifically request. Seven Corners does not share your telephone number or credit card information for use by other companies.
6. Security. Seven Corners uses industry-standard efforts to safeguard the confidentiality of your Personal Information, such as firewalls and secure socket layers. However, perfect security does not exist on the internet.
7. Links to Other Sites. Seven Corners provides links to affiliated entities and to other sites from which you might receive some benefit. These sites operate independently of Seven Corners and have established their own privacy and security policies. For the best online experience, Seven Corners encourages you to review these policies before submitting any Personal Information through these sites.
8. California Users. If you are a resident of California, you have the right to request information from Seven Corners regarding the manner in which it shares certain categories of your Personal Information with third parties, for the third parties’ direct marketing purposes. California law provides that you have the right to submit a request to Seven Corners at the designated address and receive the following information:
• (a) The categories of information Seven Corners disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year;
• (b) The names and addresses of third parties that received such information; and
• (c) If the nature of a third party’s business cannot be reasonably determined from the third party’s name, examples of the products or services marketed.
  You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. The designated e-mail address for such requests is privacy@sevencorners.com.
9. Canadian Users. Canadian citizens, except under circumstances defined by law, are entitled to access their Personal Information collected by Seven Corners by writing to:  Customer Services Privacy Director, 303 Congressional Blvd., Carmel, Indiana 46032. Seven Corners may charge an administrative fee for accessing or copying your Personal Information, but will inform you of the anticipated charges and confirm that you want Seven Corners to proceed before processing the request.
10. Safe Harbor Data Privacy Notice for Compliance with the European Union Data Privacy Directive.
• (a) Seven Corners adheres to the Safe Harbor Principles published by the U.S. Department of Commerce (the “Safe Harbor Principles”) with respect to personal information (as defined below) it receives from the European Union. This notice outlines our general policy and practices for implementing the Safe Harbor Principles, including the type of information to which this notice applies, how we use Personal Information, and the choices individuals have regarding our use of, and their ability to correct, that personal information. If there is any conflict between the policies in this Privacy Policy and the Safe Harbor Principles, the Safe Harbor Principles will govern.
• (b)This notice applies to all Personal Information we handle, including on-line (except as noted below), off-line, and manually processed data. For purposes of this Section, “Personal Information” means data that:
1. Is transferred from the European Union to the United States;
2. Is recorded in any form; and
3. Is about, or pertains to, a specific individual who is identified in, or is identifiable from, the data.
• (c) Sensitive Information” is a subcategory of Personal Information. Sensitive Information is defined as Personal Information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or the sex life of the individual. Sensitive Information also includes Personal Information received from a third party where the third party treats and identifies it as sensitive.
• (d) Safe Harbor Principles Regarding Personal Information
1. Notice and Choice. Seven Corners notifies individuals about the Personal Information it collects from them, how it uses it, and how to contact them with privacy concerns. Seven Corners obtains Personal Information only as permitted by the Safe Harbor Principles or with the consent of the individual affected. Consent for Personal Information to be collected, used, or disclosed in certain ways may be required in order for an individual to obtain or use the Services. To the extent permitted under the Safe Harbor Principles, Seven Corners reserves the right to process Personal Information in the course of providing professional services to our clients without the knowledge of individuals involved.
2. Disclosures and Transfers. Seven Corners does not disclose Personal Information to third parties, except when one or more of the following conditions is true:
1. We have the individual's permission to make the disclosure;
2. The disclosure is permitted by law or mandatory professional standards;
3. The disclosure is reasonably related to the sale or other disposition of all or part of our business or assets;
4. The Personal Information to be disclosed is publicly available;
5. The party to whom the disclosure is made controls, is controlled by, or is under common control with Seven Corners, Inc.;
6. The disclosure is reasonably necessary for the establishment or maintenance of legal claims; or
7. The disclosure is to persons or entities for whom we are providing services, provided the disclosure is consistent with the purpose for which the Personal Information was obtained.
Seven Corners will comply with the Safe Harbor Principles with respect to disclosures of Sensitive Information, including, when applicable, obtaining the explicit consent of the individual prior to disclosing Sensitive Information to a third party or using Sensitive Information for purposes other than those for which it was originally collected or subsequently authorized by the individual. Transfers of information permitted under this notice, either to third parties or within Seven Corners, include the transfer of data from one jurisdiction to another, such as transfers to and from the United States of America.
3. Data Security, Integrity, and Access. Seven Corners employs physical, electronic, and managerial measures, including education and training of its personnel, designed to provide the Personal Information in our possession with reasonable protection from accidental loss or destruction, improper use, alteration, or disclosure. Personal Information collected or displayed through this Site is protected in transit by industry standard encryption processes. However, we cannot guarantee the security of Personal Information accessible on or transmitted via the Internet.

   Seven Corners processes Personal Information in ways compatible with the purpose for which the personal information was collected, or as otherwise authorized by the individual. To the extent necessary for such purposes, we take reasonable steps to make sure that Personal Information is accurate, complete, current, and otherwise reliable with regard to its intended use.

   If an individual becomes aware that personal information we maintain about that individual is inaccurate, or if an individual would like to update or review his or her personal information, the individual may contact us using the contact information below. As a security precaution, we may request that the individual provide identifying information such as name, address, birth date, and/or social security number. In addition, we may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Agreement. In some circumstances, we may charge a reasonable fee, where warranted, for access to personal information.

4. Accountability and Enforcement. Seven Corners established a program to monitor our adherence to the Safe Harbor Principles and to address questions and concerns regarding our adherence. With respect to any dispute relating to this notice that cannot be resolved through our internal processes, we will cooperate with competent European Union data protection authorities and comply with the advice of such authorities. In the event that we or such authorities determine that we did not comply with this notice, we will take appropriate steps to address any adverse effects and to promote future compliance. 
11. Updates. Seven Corners will update this Privacy Policy from time to time to reflect changes in its business. If Seven Corners changes how it uses your Personal Information or the purposes or entities for and to which it discloses your Personal Information, Seven Corners will post the Privacy Policy change on the Site.