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PRIVACY NOTICE


PURPOSE OF THIS NOTICE

This Privacy Notice (“Notice”) applies to information JBO Holding Company d/b/a/
Unison Risk Advisors (“Unison”, “URA”, “we”, “us”, or “our”) may collect and
otherwise process electronically, through our websites, including
unisonriskadvisors.com, oswaldcompanies.com, rcmd.com, including any mobile
website, mobile application, related or connected media form, or media channel,
including other sites that link to this Notice, or by any other means
(collectively, the “Platforms”) obtain about individuals who inquire about or
obtain products or services from us for personal, family or household purposes,
or other legitimate business purposes (such as business contact information).
This Notice is designed to help you understand how we collect, use, and protect
the information we obtain through the Platforms and to assist you in making
informed decisions when using our Platforms.

California residents can learn more about their rights and choices under
California law in our California Privacy Notice here: California Privacy Notice

Individuals can learn more about their rights and choices under the
Gramm-Leach-Bliley Act here: Financial Privacy Notice


WHAT INFORMATION WE COLLECT AND FROM WHOM WE COLLECT IT

“Personal Data” includes Nonpublic Personal Information and Personal
Information:

 * “Nonpublic Personal Information” is nonpublic information about you that we
   obtain in connection with providing a financial product or service to you
   pursuant to the Gramm-Leach-Bliley Act (“GLBA”). 
 * “Personal Information” means information that identifies, relates to, or
   could reasonably be linked with you or your household. Personal Data does not
   include: publicly available information; de-identified or aggregated consumer
   information; or information excluded from the scope of applicable state
   privacy law, such as health or medical information covered by the Health
   Information Portability and Accountability Act (HIPAA) or information covered
   by certain sector-specific privacy laws, such as the Fair Credit Reporting
   Act (FCRA), or the GLBA.

We may collect Personal Data about you, your family members, or members of your
household (collectively “you”) from the following sources:

 * Directly from you, such as from applications, forms, our Platforms, personal
   interviews or otherwise
 * Automatically about your interaction with the Platforms when you visit us
 * Clients and partners, insurance carriers, (re)insurers, network partners,
   employers, benefit plan sponsors, benefit plan administrators, premium
   finance companies, health service providers, data/marketing list providers
   and third-party service providers
 * Publicly available sources such as social media platforms, property and
   assets registers, and claims and convictions records
 * Affiliate companies
 * Government authorities, such as police and regulators
 * Background check providers and screening tools
 * Medical records or medical professionals
 * Individuals who assist in handling claims
 * Non-affiliated third parties such as HR Departments, employers, and insurance
   carriers
 * Non-affiliated service providers, such as web analytics service providers and
   cookies

Personal Data we may collect (depending on the nature of your interaction with
us (e.g., as a business contact, customer, claimant, insured, etc.) includes:

 * Identifying and demographic information, such as your name, date of birth,
   age, gender, marital status
 * Contact information, such as your address, telephone number and email address
 * Unique identifiers, such as identification numbers issued by government
   bodies or agencies (e.g., your national identifier number or social security
   number, passport number, ID number, tax identification number or driver’s
   license number) and web identifiers (e.g. IP address). 
 * Employment information, such as your job title, employer, employment status,
   salary information, employment benefits, employment history and professional
   certifications
 * Financial information, such as your bank account numbers, credit card
   numbers, brokerage account numbers, transaction information, tax information,
   details of your income, property, assets, investments, pension and benefits,
   debts and creditworthiness
 * Policy information, such as your policy number, policy start and end dates,
   premiums, individual terms, claims history and claims data, mid-term
   adjustments, premium audit information, reasons for cancellation, risk
   profile and details of policy coverage
 * Claim information, such as claimant’s relationship to a policyholder/insured,
   and the date and particulars of such claim, including causes of death, injury
   or disability and claim number
 * Commercial information, such as records of your personal property, products
   or services purchased, obtained, or considered, or other purchasing or
   consuming histories or tendencies
 * Events or meeting information, such as details about your visits to our
   offices, your interest in and attendance at events or meetings, audio
   recordings, photographs or videos captured during meetings, events or calls
   with you
 * Special category data and sensitive personal data, such as data relating to
   your health (including protected health information), genetic or biometric
   data, sexual orientation, sexual activity, gender identity, racial or ethnic
   origins
 * Criminal records information, such as criminal charges or convictions,
   including driving offenses, or confirmation of clean criminal records
 * Professional disciplinary information
 * Personal information received from background checks and sanctions screenings
 * Marketing information, such as your consent to or opt out from receiving
   marketing communications from us and/or third parties, your marketing
   preferences, or your interactions with our marketing campaigns and surveys,
   including whether you open or click links in emails from us or complete
   surveys
 * Platforms and communication usage information, such as your username, your
   password, other information collected by visiting our sites or collected
   through cookies and other tracking technologies, including your IP address,
   domain name, your browser version and operating system, traffic data,
   location data, browsing time, pages you viewed, links you clicked, referring
   links, usage preferences, and social media information, such as with our
   social media presence


WHAT INFORMATION WE DISCLOSE AND TO WHOM WE DISCLOSE IT

In the course of our general business practices, we use the Personal Data that
we collect (as described above) to provide products or services to you, as well
as to facilitate internal business functions such as managing business
operations, communicating and marking to you, complying with legal obligations,
monitoring and preventing fraud, improving our services, and mergers and
acquisitions.

We may also disclose the information that we collect (as described above) about
you or others to:

 * Third parties if the disclosure will enable that party to perform a business,
   professional, sales, marketing, or insurance function for us or to you or
   your household
 * Insurance institutions, agents, credit reporting agencies, TPAs, and
   financial services companies for either URA and its affiliates, or the entity
   to whom we disclose the information to perform a function in connection with
   an insurance or financial service or transaction involving you or your
   household
 * Insurance institutions, agents, credit reporting agencies, TPAs, and
   financial services companies in order to detect or prevent criminal activity,
   fraud or misrepresentation in connection with an insurance transaction
 * Third parties in order to assist in the resolution of claims
 * Medical care institutions to medical professional in order to verify coverage
   and/or benefits, or to conduct an audit that would enable us to verify
   treatment
 * Insurance regulatory authorities, law enforcement, or other governmental
   authorities in order to protect our interests in preventing or prosecuting
   fraud
 * Group policyholders for the purpose of reporting claims experience or
   conducting an audit of our operations or services
 * Actuarial or research organizations for the purpose of conducting actuarial
   or research studies
 * Insurance carriers for the purpose of securing competing quotes prior to the
   renewal of an existing insurance policy
 * Your employer and/or the employer of the primary insured or primary
   participant on the policy
 * Third party analytics providers to customize the Platforms and improve your
   experience
 * To communicate with third-parties in possession of Personal Data when you
   exercise a right (e.g. right of deletion request)  


OUR USE OF COOKIES

We may use cookies, web beacons, tracking pixels, and other tracking
technologies (collectively, “Cookies”) when you visit the Platforms to help
customize the Platforms and improve your experience.


USE OF COOKIES

We use Cookies on the Platforms to, among other things, keep track of services
you have used, record registration information, record your user preferences,
keep you logged into the Platforms, track the pages you visit, and provide
marketing and advertising services. Cookies help us understand how the Platforms
are being used and improve your user experience. Our Platforms do not currently
respond to do not track requests.

We use automatically collected information to improve your user experience. For
example, the information provided through Cookies may be used to recognize you
as a previous user of one of our Platforms. This means you do not have to enter
your Personal Data every time you visit or select the same setting repeatedly.
Using Cookies, we can offer personalized content to you based on your location
or interests. We may combine automatically collected information with other
Personal Data we obtain about you, which may include data we obtain from others.
Cookies on our Platforms may be used to collect Personal Data about your online
activities over time and across different online services.


FIRST-PARTY AND THIRD-PARTY COOKIES

First-party Cookies are set by URA on our Platforms and are commonly required
for the Platforms to function and to be protected and secure. Third-party
Cookies are set by our partners and service providers, including those who
provide analytics, personalization, marketing, advertising, or interactive
content on our Platforms. Third-party Cookies are governed by each third party’s
respective privacy policy.


TYPES OF COOKIES

Cookies may be session or persistent Cookies. Session Cookies are deleted from
your device when you close your browser. Persistent Cookies remain stored on
your device until deleted or until they reach their expiration date. We may use:

 * Advertising Cookies, which allow us to deliver advertisements, customize
   advertisements for users, and track advertising campaign efficiency. We may
   use third parties to provide targeted advertising for us. These third-party
   advertising partners may use information from Cookies to help build visitor
   profiles and deliver relevant advertising on other websites and apps.
 * Analytics Cookies, which allow us to understand, improve, and research
   features and content on the Platforms, including how visitors navigate the
   Platforms and our popular content and features.
 * Functional and Performance Cookies, which provide functionality to the
   Platforms, help us deliver our products and services, and monitor Platforms’
   performance. For example, these technologies route traffic between servers,
   retain user preferences, and facilitate account log ins.
 * Security Cookies, which enable security features and allow us to detect
   activity that might violate our rules and Terms and Conditions, such as
   unauthorized access or activity.
 * Location Cookies, which permit us to use your approximate location, including
   using your IP address to derive your location, for purposes such as verifying
   your region and delivering or restricting content based on your location.


CONTROL OF COOKIES

You may manage your Cookie preferences by clicking the opt-out ribbon.

Note that most browsers are set to accept cookies by default and you can remove
or reject cookies in your browser’s settings. Most browsers allow you to review
and delete Cookies stored on your device and to disable or prevent Cookies on
the websites you visit. Cookies are generally easy to disable or delete, but the
method varies depending on your browser. If you typically use more than one
browser, you will need to disable or delete Cookies separately on each browser
you use. If you disable Cookies, you may not be able to use certain features on
our Platforms and disabling Cookies may invalidate your other opt outs that rely
on Cookies to function.

Your browser may have settings that allow you to transmit a “Do Not Track”
signal when you visit a website or use online services. Like many websites, our
Platforms are not designed to respond to “Do Not Track” signals received from
browsers. To learn more about “Do Not Track” signals, visit www.allaboutdnt.com.

Your device settings may allow you to manage Cookies, including by adjusting or
resetting the advertising identifiers on your mobile device. iOS and Android
devices allow you to use your privacy settings to control whether partners can
use information about your app activity for advertising purposes.

Please be aware that disabling Cookies could affect the availability and
functionality of the Platforms. Check your browser or device’s settings for how
you can control or reject cookies. Please be aware that disabling Cookies or
limiting targeted advertising will not stop you from seeing advertisements
online or in apps. The advertisements you see will, however, likely be less
relevant to you.


THIRD-PARTY OPT-OUT MECHANISMS

Some of the vendor we work with offer tools that you can use to limit or opt out
of their Cookies, such as Google Analytics (for more information about how
Google uses data it collects from our Platforms, visit
www.google.com/policies/privacy/partners/ to opt out of Google Analytics, visit
tools.google.com/dlpage/gaoptout to adjust your Google advertising settings,
visit adssettings.google.com).

Some vendors we work with may participate in the Digital Advertising Alliance
(“DAA”) and its AdChoices opt-out program. For more information about the DAA
and its opt out tool, you can visit youradchoices.com/ for web browsers or
aboutads.info/appchoices for mobile apps. Other advertising networks and
exchanges may participate in the Network Advertising Initiative (“NAI”). To
learn more about opting out of targeted advertising or to use the NAI opt-out
tool, visit networkadvertising.org/choices/ for web browsers or
networkadvertising.org/mobile-choice/ for mobile apps.

We are not responsible for the effectiveness of, or compliance with, opt-out
options or tools offered by others or the accuracy of their statements regarding
their programs.


OUR PRACTICES REGARDING INFORMATION SAFEGUARDS

We restrict access to your Personal Data to those employees who need to know
that information in order to provide products or services to you and your
household. We maintain physical, electronic, and procedural safeguards to
protect your Personal Data. Unfortunately, no data stored, and no data
transmitted over or accessible through the internet can be 100% secure. As a
result, while we attempt to protect all Personal Data, we cannot ensure or
warrant that Personal Data will be completely secure from misappropriation by
hackers or from other nefarious or criminal activities, or in the event of a
failure of computer hardware, software, or a telecommunications network. We will
notify you as required by applicable law in the event we become aware of a
security breach involving your Personal Data (as defined by applicable law)
stored by or for us.

We may, from time to time, transmit your Personal Data across borders, including
between affiliate companies, and certain third-parties, including our partners
and service providers. This sharing of data allows us to provide you with
services as set out in our underlying agreement or as otherwise indicated in
this Privacy Notice. Transfers of personal data will be subject to appropriate
safeguards, level of protection, and compliance with applicable law. 

As indicated in this Privacy Notice, we collect Personal Data about you, and
this information may be disclosed to third-parties for purposes outlined in this
Privacy Notice. If you prefer that we not disclose this information, knowing
that it may restrict our ability to provide services or conduct business, you
may opt-out of such disclosures by contacting us with appropriate instructions
by writing to Privacy Management, c/o Compliance Officer, Unison Risk Advisors;
1100 Superior Ave, Suite 1500, Cleveland, Ohio 44114, via email to
compliance@unisonriskadvisors.com or by calling 1.855.467.9253. You can also use
the webform on the Platform. 

For each category of information, our retention period is determined by the
purposes for which we use the information and any legal obligations that require
or authorize us to retain it.


INFORMATION FOR USERS OUTSIDE THE UNITED STATES

If you are visiting the Platforms from outside the United States, please be
aware that information we obtain about you will be processed in the United
States or other jurisdictions. By using the Platforms, you acknowledge your
Personal Data may be transferred to and processed in jurisdictions outside your
own as described in this Notice. Please be aware that the data protection laws
and regulations that apply to the country where the data is transferred may not
be equivalent to the laws in your country of residence (or in the jurisdiction
in which we provide services).


UPDATES, QUESTIONS, AND CONTACT INFORMATION

We reserve the right to change our privacy policies, practices and this notice
at any time. Updated copies of this notice will be posted at this location. 

If you have a comment, question, or request related to the Privacy Notice or
your Personal Data, please contact us by writing to Privacy Management, c/o
Compliance Officer, Unison Risk Advisors; 1100 Superior Ave, Suite 1500,
Cleveland, Ohio 44114, via email to compliance@unisonriskadvisors.com or by
calling 1.855.467.9253. You can also use the webform on the Platform. 


FINANCIAL PRIVACY NOTICE

The Gramm-Leach-Bliley Act (GLBA) generally prohibits any financial institution,
directly or through its affiliates, from sharing Nonpublic Personal Information
about you with a third party unless the institution provides you with a notice
of its privacy policies and practices, such as the type of information that it
collects about you and the categories of persons or entities to whom it may be
disclosed. In compliance with the GLBA, we are providing you with this document,
which notifies you of the privacy policies and practices of URA.

FactsWhat Does URA do with your Personal Information?Why?Financial companies
choose how they share your personal information. Federal law gives consumers the
right to limit some but not all sharing. Federal law also requires us to tell
you how we collect, share, and protect your personal information. Please read
this notice carefully to understand what we do.What?The types of personal
information we collect and share depend on the product or service you have with
us. This information can include: Social Security number and employment
information account balances and transaction history and medical information and
insurance claim history When you are no longer our customer, we continue to
share your information as described in this notice.How?All financial companies
need to share customers’ personal information to run their everyday business. In
the section below, we list the reasons financial companies can share their
customers’ personal information; the reasons URA chooses to share; and whether
you can limit this sharing.

Reasons we can share your personal informationDoes URA share?Can you limit this
sharing?For our everyday business purposes— such as to process your
transactions, maintain your account(s), respond to court orders and legal
investigations, or report to credit bureausYesNoFor our marketing purposes— to
offer our products and services to youYesNoFor joint marketing with other
financial companiesYesNoFor our affiliates’ everyday business purposes—
information about your transactions and experiencesYesNoFor our affiliates’
everyday business purposes— information about your creditworthinessYesYesFor our
affiliates to market to youYesYesFor nonaffiliates to market to youYesYes

To limit our sharingCall 1.855.467.9253; or Visit us online:
unisonriskadvisors.com   Please note: If you are a new customer, we can begin
sharing your information 30 days after we send this notice. When you are no
longer our customer, we continue to share your information as described in this
notice.   However, you can contact us at any time to limit our
sharingQuestions?Call 1.855.467.9253 or go to unisonriskadvisors.com

What we doHow does URA protect my personal information?To protect your personal
information from unauthorized access and use, we use security measures that
comply with federal law. These measures include computer safeguards and secured
files and buildings.How does URA collect my personal information?We collect your
personal information, for example, when you give us your contact information or
open an account apply for insurance or pay insurance premiums use your credit or
debit card   We also collect your personal information from others, such as
credit bureaus, affiliates, or other companies.Why can’t I limit all
sharing?Federal law gives you the right to limit only sharing for affiliates’
everyday business purposes—information about your creditworthiness affiliates
from using your information to market to you sharing for nonaffiliates to market
to youWhat happens when I limit sharing for an account I hold jointly with
someone else?Your choices will apply to everyone on your account unless you tell
us otherwise.

DefinitionsAffiliatesCompanies related by common ownership or control. They can
be financial and nonfinancial companies. Our affiliates include entities that
controls, are controlled by, or are under common control with JBO Holding
Company d/b/a Unison Risk Advisors, including The James B. Oswald Company,
Riggs, Counselman, Michaels & Downes, Inc., and their respective subsidiaries.
Taylor Oswald LLC is also considered an affiliate for the purposes of this
Privacy Notice. NonaffiliatesCompanies not related by common ownership or
control. They can be financial and nonfinancial companies. Nonaffiliates we
share with include categories of companies such as insurance carriers,
retirement plan services partners, claims handling partners, and vendors, among
others.Joint marketingA formal agreement between nonaffiliated financial
companies that together market financial products or services to you. Our joint
marketing partners include insurance carriers, and employee benefit providers
among others.


CALIFORNIA PRIVACY NOTICE

This section applies to Personal Information that is not covered by the GLBA or
other applicable law for residents of California. This California Privacy Notice
(“CA Notice”) is provided pursuant to the California Consumer Privacy Act
(“CCPA”) and describes how URA processes Personal Information of California
consumers. This CA Notice supplements our other privacy policies and notices,
including our main Privacy Notice above.

In the event of a conflict between any other policy, statement, or notice and
this CA Notice, this CA Notice will prevail as to California residents.

Unless otherwise noted, the disclosures that describe how and why we collect,
use, and disclose your Personal Information also describe how and why we
collected, used, and disclosed your Personal Information within the past twelve
(12) months.


YOUR PRIVACY RIGHTS

If you are a resident of California, you have the right to submit certain
requests relating to your Personal Information as described below. You have the
following rights:

Know:  You have the right to know what Personal Information that we hold about
you, upon receipt of a verified request, which includes:

 * the categories of Personal Information we collected about you;

 * the specific pieces of Personal Information we collected about you; 

 * our business or commercial purposes for collecting, selling, sharing, or
   disclosing Personal Information;

 * the categories of recipients to which we disclose Personal Information;

 * the categories of sources from which we collected Personal Information;

 * the categories of Personal Information that we sold or shared and, for each
   identified category, the third persons with whom we sold or shared Personal
   Information;



Accuracy:  You have the right to request that we correct any inaccurate or out
of date Personal Information. 

Deletion:  You have the right to request that we delete your Personal
Information, with some exceptions.

Non-Discrimination:  You have the right to equal treatment regardless of your
exercise of your privacy rights.

Sensitive Personal Information:  You have the right to direct us to limit, with
some exceptions, our use and disclosure of your Sensitive Personal Information,
as defined below, to uses or disclosures of your Sensitive Personal Information
to those uses or disclosures that are reasonably necessary to provide our goods
and services, or as needed to perform certain other services.

Opt Out:  You have the right to opt out of the sale of your Personal Information
and the sharing of your Personal Information for cross-context behavioral
advertising.  We do not presently sell, use for profiling, or share Personal
Information for targeted or cross-context behavioral advertising.

You, or a person authorized by you under the laws of your state to act on your
behalf, may request the following information or exercise any of the above
rights by writing to Privacy Management, c/o Compliance Officer, Unison Risk
Advisors; 1100 Superior Ave, Suite 1500, Cleveland, Ohio 44114, via email to
compliance@unisonriskadvisors.com or by calling 1.855.467.9253. You can also use
the webform on the Platform. 

We may provide this information in a standardized format that is not entirely
specific to you. Before we may fulfill a request to access, correct, limit the
use of, or delete your information, we may be required to verify your identity. 
If you submit a request to know, request to delete, or request to correct, we
will ask you to verify your identity, which may include your name, address, date
of birth, and government-issued identification number. You may designate an
authorized agent to make a request on your behalf; however, you will still need
to verify your identity directly with us before your request can be processed.


PERSONAL INFORMATION WE COLLECT AND WHY WE COLLECT IT

We share the following categories of Personal Information from the sources and
for the purposes listed above. We collect the following categories of Personal
Information from our California consumers. The Personal Information we collect
about you may vary depending on the nature of your interactions with us and may
not include all of the examples listed below.

Category / ExamplesCollected?Identifiers such as a real name, alias, postal
address, unique personal identifier, online identifier, Internet Protocol
address, email address, or other similar identifiers.Yes.Identifiers such as
social Security number, driver’s license number, passport number, or other
similar identifiers.Yes.Personal information categories listed in the California
Customer Records statute §1798.80(e) such as a name, address, education,
employment, and employment history.  Some personal information included in this
category may overlap with other categories.Yes.Personal information categories
listed in the California Customer Records statute §1798.80(e) such as Signature,
Social Security number, physical characteristics or description, telephone
number, passport number, driver’s license or state identification card number,
insurance policy number, bank account number, credit card number, debit card
number, or any other financial information, medical information, or health
insurance informationYes.Characteristics of protected classifications under
California or federal law such as age or gender.Yes.Commercial information such
as records of personal property, products or services purchased, obtained, or
considered, or other purchasing or consuming histories or
tendencies.Yes.Biometric information such as genetic, physiological, behavioral,
and biological characteristics, or activity patterns used to extract a template
or other identifier or identifying information, such as, fingerprints, face
prints, and voiceprints, iris or retina scans, keystroke, gait, or other
physical patterns, and sleep, health, or exercise data.Yes.Internet or other
electronic network activity information such as browsing history, search
history, information on a consumer’s interaction with a website, application, or
advertisement.Yes.Audio, electronic, visual, thermal, olfactory, or similar
information such as call recordings, chat transcripts, presentation recordings,
email correspondence, testimonials, pictures, diagrams of your properties and
equipment (including satellite imagery).Yes.Professional or employment-related
information such as current or past job history or performance
evaluations.Yes.Inferences drawn from other Personal Information such as profile
reflecting a person’s preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities, and
aptitudes.Yes.Sensitive Personal Information such as identification numbers
(like Social Security number), financial account and access information,
personal demographic information (like your race, religion, philosophical
beliefs), genetic or biometric information, and information about your health or
sexual activity.Yes.

We do not use or disclose Sensitive Personal Information for purposes to which
the right to limit use and disclosure applies under the CCPA.


HOW LONG WE KEEP YOUR PERSONAL INFORMATION

For each category of information, our retention period is determined by the
purposes for which we use the information and any legal obligations that require
or authorize us to retain it.


HOW WE SELL AND SHARE PERSONAL INFORMATION

We do not, and within the past twelve (12) months, have not, sold or shared
Personal Information of California consumers.


DISCLOSURES FOR A BUSINESS OR COMMERCIAL PURPOSE

We may disclose and, during the last twelve (12) months, have disclosed the
above categories of Personal Information to our service providers, contractors,
vendors, and others for the following business purposes:  

 * Ensuring security and integrity of Personal Information
 * Debugging to identify and repair errors that impair existing intended
   functionality
 * Short-term, transient use
 * Performing services on our behalf
 * Providing advertising and marketing services for us (except for cross-context
   behavioral advertising)
 * Undertaking internal research for technological development and demonstration
 * Undertaking activities to verify or maintain the quality or safety of a
   service or device that is owned, manufactured, manufactured for, or
   controlled by us
 * Processing, maintaining, or collecting Personal Information on our behalf
 * Detecting or protecting against malicious, deceptive, fraudulent or illegal
   activity
 * To communicate with third-parties in possession of Personal Information when
   you exercise a right (e.g. right of deletion request)

Revision date: 6/1/2023


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