Privacy Policy

Purpose

The organization is concerned about the privacy of all of our customers and consumers. Because your privacy is very important to us, we have adopted a strict privacy policy on how information you share with us is used and maintained. We feel it is essential to provide you with the information that outlines our privacy policy and our information sharing practices.

Information We Collect from Customers and Consumers

The Cochlan Group, inc. (“TCG”) may collect nonpublic personal information about customers and consumers from various sources. These include, but may not be limited to, individual information summarizing compensation and benefits, insurance applications, plan participant forms and information related to an individual’s history of transactions with our firm.

Our Practices Regarding the Confidentiality and Security of Consumer and Customer Information

We restrict access to nonpublic personal information about our current or former customers and consumers to those authorized individuals who need to know that information in order to provide them with products or services. We also require outside companies and independent contractors, who provide services on our behalf or with whom we have entered a joint marketing agreement, to enter into agreements that protect the confidentiality of any customer information we provide and restrict the use of such information to those purposes. Finally, we maintain physical, electronic and procedural safeguards that comply with federal regulations to guard customers’ and consumers’ nonpublic personal information.

Physical Safeguards

Certain records are stored in print and are maintained in lockable filing cabinets located within the secure premises of The Cochlan Group offices with access limited to our employees.

Electronic Safeguards

Information is stored on a Local Area Network (“LAN”) accessible to TCG employees. Access to the LAN is password protected. A firewall is maintained preventing access thru the Internet. Remote access to the LAN is permitted to a small group of TCG employees only and is password protected. Information submitted to TCG via our website is encrypted to protect it from interception by a third party. The personal identification numbers and user sign on protocol also ensure that the information provided remains secure.

Procedural Safeguards

All TCG employees have agreements prohibiting them from disclosing nonpublic information to any third party except in furtherance of client and potential client goals on a need-to-know basis. Our standard procedures include sharing information internally only on a need-to-know basis, keeping nonpublic personal information in closed files when not physically working with it and logging off the LAN whenever information is not in use.

Summary

The privacy policy statement describes TCG privacy practices for current clients, former clients and potential clients who submit data and all employees, Directors, and other affiliates of these whose nonpublic personal information is submitted. This policy will remain in effect until further notice.