Effective date:1/1/2024

This Privacy Policy describes the data protection practices of Association Member Benefits Advisors and members of its corporate family (together referred to as “AMBA,” “we,” “us,” or “our”). This Privacy Policy applies to all websites owned and operated by us that link to this Privacy Policy, and related online and offline services (collectively, the “Services”).

This policy does not apply to the data protection practices of (i) the associations that AMBA serves or (ii) benefits providers, such as insurers. Those entities handle personal information (including personal information received from AMBA) pursuant to their own policies and practices, which may differ from ours. This policy also does not apply to any information that we handle solely on behalf of such entities.

Please read this Privacy Policy carefully to understand how we handle your information. By engaging with our Services, you are expressly and voluntarily accepting the terms and conditions of this Privacy Policy and our Terms of Use.

WHAT INFORMATION DO WE COLLECT?

AMBA may collect information directly from you or another individual submitting a request or application on your behalf, from associations that you are a member of, insurance carriers, government entities, and from analytics providers and data brokers.

INFORMATION YOU PROVIDE TO US

Contact and registration information, including your first, middle, and last name, email address telephone number, email address, and postal address;

Demographic and statistical information including your zip code, county of residence, date of birth, social security number, gender, basic health information, number of dependents and their birth-dates, relationship to you, disability and social security status, economic and financial information, your retirement status,employment information, professional occupation/certification information (e.g. bar/attorney number), and the associations that you are a member of;

Payment information, including credit card, bank account information, including type of account, the owners first and last name, account number and routing number, or CalPERS withdrawal information;

Insurance plan information, including the coverage plans you apply for, select, and enroll in and details about such selections, enrollments, and past coverage plans; and

Other information, including information you provide to us through a questionnaire, application, communication, or customer support inquiry.

INFORMATION WE COLLECT THROUGH AUTOMATED MEANS

We may automatically collect certain information about the computer or devices you use to access the Services. For example, we may collect and analyze information such as IP address of the device you use to access the Services as well as cookies as described below.

We use a variety of online tracking and analytics tools (e.g., cookies, flash cookies, pixel tags, and HTML5) to collect and analyze information as you use the Services. Among other things, these technologies provide faster access to this site's contents, and help us determine the type of content you find of interest and the sites to which you link, the length of time you spend at any particular area of this site, and the particular AMBA services you choose to use, help facilitate advertising, and help us with the other handling of information described in this Privacy Policy.

We may also use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze information collected through these technologies to assist us in auditing, research, or reporting; fraud prevention; and providing certain features to you. To find out more about how your usage information is collected through the practices of, and how you may be able to opt out of certain information by, such third parties, contact compliance@getamba.com

The types of tracking and analytics tools we and our service providers use for these purposes are:

“Cookies” are small data files stored on your computer or device to collect information about your use of the Services. Cookies may enable us to recognize you as the same user who used our Services in the past, and relate your use of the Services to other information we have about you. Cookies may also be used to enhance your experience on the Services (for example, by storing your username) and/or to collect general usage and aggregated statistical information. Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, limit your use of our Services or features. Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.

“Local shared objects,” or “flash cookies,” may be stored on your computer or device using a media player or other software. Local shared objects operate much like cookies, but cannot be managed in the same way. Depending on how local shared objects are enabled on your computer or device, you may be able to manage them using software settings.

A “pixel tag” (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one- pixel – that can be placed on a web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you’ve opened one of our emails or seen one of our web pages.

“HTML5” (the language some websites, such as mobile websites, are coded in) may be used to store information on your computer or device.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for online advertising and analytics purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals.

HOW DO WE USE YOUR INFORMATION?

We and our service providers use the information described above for the following business purposes:

to operate, maintain, and provide to you the features and functionality of our Services; to process and respond to your registration, inquiries, requests, and applications;

to communicate with you and notify you of your application/order status and important changes to our Services; to personalize your experience and our communications with you;

to send you information and promotional materials about our company, our products and services, that we think you may find interesting;

to improve our products and services, including the design and layout of our Services; to provide customer support; and

to secure our Services, prevent fraud, enforce the legal terms that govern your use of the services, provide customer service support, monitor, investigate, and protect the integrity and security of our Services, and serve other legal purposes.

For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

HOW DOES AMBA PROTECT CUSTOMER INFORMATION?

Although we take certain measures to protect your information, no method of security is perfect. By using our Services, you acknowledge and accept that we cannot guarantee the security of your information, and that you provide information to us at your own risk.

WILL AMBA DISCLOSE THE INFORMATION IT COLLECTS TO OUTSIDE PARTIES?

We may disclose information as follows:

With Service Providers, including providers of data storage, web hosting, customer service, security, analytics, advertising, and fraud prevention, we may share all categories of information identified above;

With Affiliates, such as other members of our corporate family, including subsidiaries and affiliated companies, we may share contact and registration information;

With Insurance Carriers and Associations, such as the benefits providers to whom you apply and the associations to which you belong, we may share contact and registration information, demographic and statistical information, and insurance plan information;

In relation to Legal Proceedings, such as when we believe disclosure is appropriate to respond to court orders, judicial or other official government requests, subpoenas, or warrants in the manner legally required; to defend against legal claims; or as otherwise required by law, we may share all categories of information identified above; For the Protection of AMBA and Others, such as when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; to establish or exercise our legal rights; or to enforce this Privacy Policy, our Terms of Use, or any other agreement, we may share all categories of information identified above;

In Connection with Corporate Transactions, such as in the event that AMBA is involved in (or is contemplating) a merger, acquisition, sale, bankruptcy, insolvency, reorganization, receivership, assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, or other change of control, we may share all categories of information identified above; and

With Your Consent, such as if you have consented to additional sharing of your information (including as set out in this Privacy Policy), we may share all categories of information identified above.

AMBA does not share or sell the information you provide to us or that we collect through automated means as defined by the California Privacy Rights Act (“CPRA”).

AMBA shares your personal data as disclosed above. The California privacy law defines sharing as “communicating orally, in writing, or by electronic or other means, a consumer's personal information . . . to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.” This occurs when you visit an AMBA website. Cookies or pixels are deployed that then allow us to show you targeted advertisements when you visit other websites or social media platforms. You have the right to opt-out of this type of sharing and may contact privacy@getamba.com to exercise those rights.

This type of sharing is different from disclosing personal information to other entities to perform a service related to providing insurance or processing your claim. How we disclose data to these types of entities is set forth below.

We may also disclose data with other companies that provide marketing services on our behalf or as part of a joint marketing agreement. We will not disclose your personal data with others for their own marketing purposes.

We may also disclose data about our transactions (such as payment history) and experiences (such as claims made) with you to our affiliates.

AGGREGATE/DE-IDENTIFIED INFORMATION

We may aggregate and/or de-identify any information collected through the Services so that such information can no longer reasonably be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De- Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

YOUR CHOICES AND RIGHTS

You have certain rights with respect to your information as further described in this Section, in addition to any rights discussed elsewhere in this Privacy Policy. Please note your rights and choices vary depending upon your location.

Marketing Communications. You may instruct us not to use your information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below. You may do so by: following the instructions located at the bottom of marketing email messages, faxing us at (512) 241-0035, or sending mail to the following postal address: Association Member Benefits

Advisors, Attention Privacy Officer, 6034 W. Courtyard Drive, Suite 300, Austin, TX 78730. Removing your name from the email list may take a reasonable amount of time and it is possible that you could receive marketing materials pre-dated to your request and/or while the request is being processed. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

Correct/Update. AMBA gives users the following options for changing and modifying information previously provided. You may do so by faxing us at (512) 241-0035 or sending mail to the following postal address: Association Member Benefits Advisors, Attention Privacy Officer, 6034 W. Courtyard Drive, Suite 300, Austin, TX 78730.

Requesting details about your personal information. You may request details of personal information which we hold about you. Unless you are a California resident and the request is made under the CCPA (explained below), a small fee may be payable for processing. If you would like a copy of the information held on you please contact us at: Association Member Benefits Advisors, Attention Privacy Officer, 6034 W. Courtyard Drive, Suite 300, Austin, TX 78730.

Privacy Rights for California Residents. If you are a California resident, California law requires us to provide you with some additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”).

In many cases, if you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, unless certain exceptions apply, the CCPA allows you to request us to:

Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.

Provide access to and/or a copy of certain personal information we hold about you. Delete certain personal information we have about you.

Provide you with information about certain financial incentives that we offer to you, if any.

You also have certain rights under the CCPA not to be subject to certain negative consequences for exercising CCPA rights.

We reserve the right to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, phone number, or other information. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

Please note that certain information may be exempt from such requests under California law. For example, we may need certain information in order to provide the Services to you or to comply with legal obligations, so we would need to either reject your request to delete the information or, if we are legally permitted to delete it, we would need to terminate our provision of a Service to you after deleting it. We also may need to retain certain information in order to comply with your request not to receive solicitations from AMBA in the future (e.g., so that we can remove you from future mailing lists). In this case, we would retain only the minimum information needed to comply with your request, retain such information in a secure location, and would not share such information with any third party unless required by applicable law. If you would like further information regarding your legal rights under California law or would like to exercise any of them, contact us at compliance@getamba.com or privacy@getamba.com.

If you are seeking to exercise applicable rights with respect to information that we handle solely on behalf of the associations that AMBA serves or benefits providers, such as insurers, you should direct requests to those organizations directly.

Privacy Rights for Nevada Residents. Under Nevada law, certain Nevada residents may opt out of the “sale” of “covered information” (as such term is defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity as of the effective date of this Privacy Policy; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of the sale of your covered information under Nevada law by emailing us at nevadarequest@getamba.com. Please note we may take reasonable steps to verify your identity and the authenticity of the request.How

Long Does AMBA Retain Each Category of Personal Data? We retain your information in accordance with our legal obligations, our records retention policies, or as otherwise permitted by law. For example, we may have a legal obligation to retain information relating to your policies or claims with us. We will delete your data once the legal obligation expires or after the period of time specified in our records retention policies. The period of retention is subject to our review and alteration.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this Privacy Policy at any time. We will make the revised Privacy Policy accessible through the Services, so you should review the Privacy Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” at the beginning of this Privacy Policy. If we make a material change to this Privacy Policy, we will provide you with notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

THIRD-PARTY LINKS AND FEATURES

The Services may contain links to third-party services, websites, or applications. If you choose to use these third-party services, or features, you may disclose your information not just to those third parties but also to their users and the public more generally, depending on how their services function. AMBA is not responsible for the content or practices of such third-party services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

CHILDREN’S PRIVACY

The Services are not intended for children under 13 years of age and we do not knowingly collect, maintain, or use personal information from children under 13 years of age. We will take reasonable steps to delete personal information (as defined by the United States Children’s Online Privacy Protection Act) as soon as reasonably possible if we learn that we have inadvertently collected it from children under the age of 13 without parental consent.

If you learn that your child has provided us with personal information without your consent, you may alert us at privacy@getamba.com. If we learn that we have collected any personal information from children under 13, we will promptly take steps to delete such information.

TELL US WHAT YOU THINK

AMBA welcomes your questions and comments about privacy.

Contacting AMBA

If you have any questions about this Privacy Policy, our practices, or your dealings with our Services, you can contact: Association Member Benefits Advisors, Attention Privacy Officer,

6034 W. Courtyard Drive, Suite 300 Austin, TX 78730 Email: privacy@getamba.com Fax: 512-241-0035

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