Privacy Policy Notice (as of May 21, 2009)
PURPOSE OF THIS NOTICE

As provided by law, we are generally prohibited from sharing nonpublic personal information about you
with a third party unless we provide you with this notice of our privacy policies and practices describing
the type of information that we collect about you and the categories of persons or entities to whom
that information may be disclosed.  Accordingly, we are providing you with this document, which notifies
you of the privacy policies and practices of Stephen W. Gersh Insurance Agency, Inc. ("SGI").

Furthermore, we wish inform you that we do not share your personal information with any non-affiliated
third parties for any purpose that is not specifically authorized by law unless we obtain your affirmative
permission.

OUR PRIVACY POLICIES AND PRACTICES

1.  Information we collect:

A.     Categories of Information Collected and Sources From Which We Collect It

We collect nonpublic personal information about you from the following sources:

·  Information we receive from you on applications or other forms you submit to us, from your
dealings with us, and from our website.

·  Information about your transactions with us, our affiliates or others.

·  Information we receive from consumer reporting agencies.

·  Information we receive from medical records or medical professionals.

Unless it is specifically stated otherwise in an amended Privacy Policy Notice, no additional information
will be collected about you.

B.   Persons From Whom Information is Collected

We may collect nonpublic personal information from individuals other than those proposed for
coverage.

C.  Information From Credit Reports or Investigative Consumer Reports

If you authorize us to do so, we may obtain information about you from credit reports or other
investigative consumer reports prepared by third parties at our request.  If you authorize us to request
such information and we request such information, you should be aware that:

·   You have the right to request to be interviewed in connection with the preparation of an
investigative consumer report.

·   Upon request, you are entitled to receive a copy of the consumer reports.

·   The information obtained from the reports prepared by a third party may be retained by the
third party and disclosed to other persons.

2.  Information we may disclose to third parties:

In the course of our general business practices, we may disclose the information that we collect (as
described above) about you or others without your permission to the following types of institutions for
the reasons described:

·  To a third party if the disclosure will enable that party to perform a business, professional or
insurance function for us.

·  To an insurance institution, agent, or credit reporting agency in order to detect or prevent
criminal activity, fraud or misrepresentation in connection with an insurance transaction.

·   To an insurance institution, agent, or credit reporting agency for either this agency or the
entity to whom we disclose the information to perform a function in connection with an
insurance transaction involving you.

·   To a medical care institution or medical professional in order to verify coverage or benefits,
inform you of a medical problem of which you may not be aware, or conduct an audit that
would enable us to verify treatment.

·   To an insurance regulatory authority, law enforcement, or other governmental authority in
order to protect our interests in preventing or prosecuting fraud, or if we believe that you have
conducted illegal activities.

·   To a group policyholder for the purpose of reporting claims experience or conducting an audit
of our operations or services.

·   To an actuarial or research organization for the purpose of conducting actuarial or research
studies.

In addition to those circumstances listed above, and unless you direct us not to by completing the
attached Opt Out Form, we may disclose certain information about you to third parties whose only use
of the information will be for the purpose of marketing a product or service.  Under no circumstances
will we disclose for marketing purposes:

(1) any medical information;

(2) information relating to a claim for a benefit or a civil or criminal proceeding involving you; or

(3) personal information relating to your character, personal habits, mode of living or general
reputation.

3.  Your right to access and amend your personal information:

You have the right to request access to the personal information that we record about you.  Your right
includes the right to know the source of the information and the identity of the persons, institutions or
types of institutions to whom we have disclosed such information within two (2) years prior to your
request.  Your right includes the right to view such information and copy it in person, or request that a
copy of it be sent to you by mail (for which we may charge you a reasonable fee to cover our costs).  
Your right also includes the right to request corrections, amendments or deletions of any information
in our possession.  The procedures that you must follow to request access to or an amendment of your
information are as follows:

To obtain access to your information: You should submit a request in writing to Stephen W. Gersh
Insurance Agency, Inc., 9 Monument Ave., Marlboro, MA 01752.  The request should include your
name, address, social security number, telephone number, and the recorded information to which you
would like access.  The request should state whether you would like access in person or a copy of the
information sent to you by mail.  Upon receipt of your request, we will contact you within 30 business
days to arrange providing you with access in person or the copies that you have requested.

To correct, amend, or delete any of your information: You should submit a request in writing to
Stephen W. Gersh Insurance Agency, Inc., 9 Monument Ave., Marlboro, MA 01752. The request should
include your name, address, social security number, telephone number, the specific information in
dispute, and the identity of the document or record that contains the disputed information. Upon
receipt of your request, we will contact you within 30 business days to notify you either that we have
made the correction, amendment or deletion, or that we refuse to do so and the reasons for the
refusal, which you will have an opportunity to challenge.

4. Our practices regarding information confidentiality and security:

We restrict access to nonpublic personal information about you to those employees who need to know
that information in order to provide products or services to you.  We maintain physical, electronic, and
organizational safeguards to protect information about you.

5.  Internet Policies and Procedures

SGI respects the privacy of the individuals and businesses accessing/using (“Users”) its website
(“Website”).  SGI collects limited information about Users who visit areas of SGI’s Website accessible
to the public (“Public Areas”) of the Website.  This information is automatically collected on an
aggregate basis (“Aggregate Information”) to measure traffic on the Website.  Aggregate Information
is collected through the use of a “cookie” or small text file placed on the User’s hard drive by the User’
s Internet browser.  The cookie allows SGI to track the number of hits or visits to various pages on the
Website.  When SGI’s Website is accessed through a hyperlink on another website, the cookie will
identify and track the Internet Protocol address (“IP”) that linked the User to the Website.  If the User
did not hyperlink to SGI’s Website from the most recently visited IP, then SGI will only identify the User’
s Internet Service Provider (e.g., aol.com, yahoo.com, etc.).  The cookie is used only during a single
connection to the Website, and is not used to track User activity after leaving the Website.  It is
permanently disabled when the User exits the Website, and information about individual Users is not
collected, saved or distributed to others by SGI.  Aggregate information and other information
gathered through voluntary User surveys and forms assists SGI to better understand Users’ needs and
improve the Website, and to enable SGI to demonstrate to vendors and others information about the
volume and nature of its Website traffic.

The Website contain hyperlinks to Internet sites of SGI members and other businesses and resources,
and each Internet site may have its own privacy and data collection policies and practices.  SGI is not
responsible for the privacy and data collection policies and practices of any of its members or other
businesses and resources, or for the content of their Internet sites.  Users interested in the privacy
and data collection policies and practices of SGI members or other businesses and resources should
review their policies.  SGI makes no representations of any kind about the internet sites of its
members or other businesses and resources, and SGI disclaims all warranties and responsibilities of
any kind, including, without limitation, warranties and responsibilities with respect to SGI members’ and
other businesses’ and resources’ Internet sites, content privacy and data collection policies and
practices, and actions.
Copyright      2009 Stephen W. Gersh Insurance Agency, Inc.  All rights reserved.