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Your privacy is very important to us.  We believe that privacy is a sensitive issue and your personal information is solely yours to give out.  We have never sold your personal information in the past and do not currently have any plans to do so.  

In November of 1999, the gramm-leach bliley financial services modernization act (glb act) was enacted by the u.s. congress . This act modernizes the financial institutions of the United States by allowing new business combinations between previously unaffiliated financial industries such as banks and insurance companies.  This federal act included a number of changes affecting the financial institutions, including title v, which enacts significant new requirements to protect the privacy of consumer’s and customer’s information starting July 1, 2001. 

The glb act protects the non-public personal information of consumers who seek to obtain a financial product or service for personal or family purposes.  The protections extend not only to people who become AIG Insurance Company - Puerto Rico policyholders (customers), but also to consumers, who apply or ask for information about our products and services but do not become AIG Insurance Company - Puerto Rico customers. 

On September 26, 2002 the insurance commissioner of Puerto Rico enacted regulation no. 75, which ordered insurance companies in Puerto Rico to send privacy notices to each policyholders.  The abovementioned notices will instruct customers regarding their respective insurance company’s privacy policy.  These privacy notices will be sent to current customers at the beginning of the relationship and thereafter. 

These notices will describe what types of consumer information is collected by AIG Insurance Company - Puerto Rico, how AIG Insurance Company - Puerto Rico keeps that information private, under what conditions AIG Insurance Company - Puerto Rico may disclose information and to whom.  Be advised that we will send you copy of our privacy policy, as soon as you request it. 

Consumers
Consumer is defined as an individual who seeks to obtain, obtains or has obtained an insurance product or service from AIG Insurance Company - Puerto Rico that is to be used primarily for personal, family or household purposes. For example: 

1.   An individual who provides nonpublic personal information to AIG Insurance Company - Puerto Rico in connection with obtaining or seeking to obtain financial, investment or economic advisory services relating to an insurance product or service is a consumer regardless of whether AIG Insurance Company - Puerto Rico establishes an ongoing advisory relationship; 

2.   An applicant for insurance prior to the inception of insurance coverage is an AIG Insurance Company - Puerto Rico consumer; 

3.   An individual who is a consumer of another financial institution is not an AIG Insurance Company - Puerto Rico consumer solely because AIG Insurance Company - Puerto Rico is acting as agent for, or provides processing or other services to, that financial institution; and 

4.   An individual is an AIG Insurance Company - Puerto Rico consumer if: 
(i)            1)     the  individual is a beneficiary of an insurance policy underwritten by AIG Insurance Company - Puerto Rico; 
               2)     the  individual is a claimant under an insurance policy issued by AIG Insurance Company - Puerto Rico; 
               3)     the  individual is an insured under an insurance policy, issued by AIG Insurance Company - Puerto Rico; or 
               4)     the  individual is a mortgagor covered under a mortgage insurance policy; and  
  
(ii)    AIG Insurance Company - Puerto Rico discloses nonpublic personal information about the individual to a non-affiliated third party other than the ones that perform services to AIG Insurance Company - Puerto Rico.

Customers
Customer is defined as a consumer who has a customer relationship with AIG Insurance Company - Puerto Rico.  Customer relationship means a continuing relationship between a consumer and AIG Insurance Company - Puerto Rico under which AIG Insurance Company - Puerto Rico provides one or more insurance products or services to the consumer that are to be used primarily for personal, family or household purposes.  For example: 

A.   A consumer has a continuing relationship with AIG Insurance Company - Puerto Rico if: 
(i)     the consumer is a current policyholder of an insurance product issued by or through AIG Insurance Company - Puerto Rico; or 
(ii)    the consumer obtains financial, investment or economic advisory services relating to an insurance product or service from AIG Insurance Company - Puerto Rico for a fee. 

AIG Insurance Company - Puerto Rico’s Privacy Policy
AIG Insurance Company - Puerto Rico has developed a comprehensive privacy policy.  The same is designed to be used  as  a reference guide and information resource for our customers, consumers, employees, affiliates and non affiliated third parties.  The policy describes the responsibility of all AIG Insurance Company - Puerto Rico personnel, affiliates and non-affiliated third parties to safeguard consumer and customer information and the circumstances under which employees, affiliates and non-affiliated third parties may disclose consumer and customer information within the scope of the law. 

Basically, AIG Insurance Company - Puerto Rico’s privacy policy is to not share non-public personal information of our consumers and customers, except as the permitted by law. 

Difference between the privacy notice and the privacy policy
AIG Insurance Company - Puerto Rico is required by law to prepare and mail the privacy notice to all AIG Insurance Company - Puerto Rico’s customers every year.  It is designed to describe what kind of consumer and customer information AIG Insurance Company - Puerto Rico collects, how the information is protected and under what circumstances that information may be disclosed.  The AIG Insurance Company - Puerto Rico privacy policy was developed by our company to provide more comprehensive information to our consumers and customers.  Our privacy policy will be published on our internet web site. 

Information We Collect
We collect and may share information about you, which is not publicly available.  We may share this information now, or in the future.  We do this to enable us to serve you and help us to identify you as our customer or our former customer, to process your policy and requests quickly, to pay your claim or develop products we believe you will want to use. 

·   Information from you: when submitting your application or requesting an insurance quote, you may give us information such as your name, address, and social security number. 
·   Information about your transactions: we may keep information about your transactions with us or our family of companies, for example, the products you purchase from us, the amount you paid for the insurance, your account balances, or payment history. 
·   Information from outside our family of companies: we also may collect other information.  This may include information from consumer reporting agencies such as your credit history, credit scores, your driving record, your employment, or we may ask your doctor for more information about your medical history. 

AIG Insurance Company - Puerto Rico only collects information about individuals as permitted by law.  AIG Insurance Company - Puerto Rico uses the information collected about consumers to evaluate their applications for property and casualty; in determining their premiums and processing claims. The information is retained in the customer’s file and is used to administer life property and casualty contracts and settle claims.

Protected Information
Any nonpublic personal information that you or your agent provides to us on applications and other forms (contact information, net worth, income, loss experience, etc.), on our internet web site, or through telephone conversations with our office personnel or personals, is covered by the act.  This does not include anything “public”, which is, for example, information that may be found in a telephone directory, public government records, etc.  AIG Insurance Company - Puerto Rico will keep confidential the fact that the policyholder receives a product or service from us.  Currently, we treat every piece of non-public personal information provided by our customer as private.  We do not sell your information to other third party companies, or provide your information to such parties except as necessary to process underwriting or administer claims. 

Personal Information
Personal information means any information: 

1.   A consumer provides to AIG Insurance Company - Puerto Rico to obtain an insurance product or service; 
2.   About a consumer resulting from a transaction involving an insurance product or service between AIG Insurance Company - Puerto Rico and a consumer; 
3.   AIG Insurance Company - Puerto Rico otherwise obtains about a consumer in connection with providing an insurance product or service to that consumer. 
For example: your name, social security number, account number, account balance, payment history, overdraft history, credit history, assets, and income.

Non-public Personal Financial Information
Non-public personal information is personally identifiable financial information about a consumer or a customer that is; 

1.   Any list, description or other grouping of consumers (and publicly available information pertaining to them) that is derived using any personally identifiable financial information that is not publicly available. 

For example: any lists of individuals’ names and streets addresses that is derived in whole or in part using personally identifiable financial information that is not publicly available, such as account numbers. 

Non-public Personal Health  Information
Means health information: 

1.   That identifies an individual who is the subject of the information; or 
2.   With respect to which there is a reasonable basis to believe that the information could be used to identify an individual. 

Publicity Available Information
Means any information that AIG Insurance Company - Puerto Rico has a reasonable basis to believe is lawfully made available to the general public from: 

1.   Federal, state or local government records; 
2.   Widely distributed media; or 
3.   Disclosures to general public that are required to be made by federal, state or local law. 

Non-Protected Information     
Information that does not personally identify you, such as aggregations of information used for business analysis or actuarial studies, is not “personal” information covered by the act and is not protected.  In addition, public personal information is not protected, because the same is available from public sources, such as the telephone book or public records. 

Non-Affiliated Third Party 
Is classified as any other outside/non-affiliated company (i.e., one that is not subsidiary or affiliate of AIG Insurance Company - Puerto Rico or its holding company that does business with AIG Insurance Company - Puerto Rico.)    A third party company is not affiliated with AIG Insurance Company - Puerto Rico.  Examples of “third party” companies would be credit card companies, mutual fund companies, banks, service, providers, or vendors that are not owned by AIG Insurance Company - Puerto Rico.  

Some non-affiliated third party companies assist AIG Insurance Company - Puerto Rico in investigating claims, administering policies and underwriting.  AIG Insurance Company - Puerto Rico may disclose non-public personal information with the non-affiliated third parties that assist AIG Insurance Company - Puerto Rico in investigating claims in order to provide the customer with a better service. 

Affiliated Party
Is any company that controls, is controlled by or is under common control with AIG Insurance Company - Puerto Rico. 

Information We May Disclose  
We are allowed to share any information given to us within our AIG family of companies.  We often do this so as to provide you, the customer, with better access to and more information regarding products offered by AIG Insurance Company - Puerto Rico which may be of interest to you.  

AIG Insurance Company - Puerto Rico only discloses information to other companies as allowed by law, under the exceptions provided by the gramm-leach bliley and regulation 75.  AIG Insurance Company - Puerto Rico may disclose individuals’ non-public information to non-affiliated third party companies that assist AIG Insurance Company - Puerto Rico in investigating claims, administering policies and underwriting. 

We will share your non-public information with law enforcement authorities or courts of law if they direct us to do so as part of a pending civil or criminal investigation.  We may also share personal information to protect against fraud. AIG Insurance Company - Puerto Rico is allowed by law to disclose policyholder’s non-public personal information with other entities, such as state departments of insurance, persons authorized by subpoena or court order and reinsurance companies.  

AIG Insurance Company - Puerto Rico does not share customer non-public personal information with non-affiliated third parties for marketing purposes. 

Beneficiaries
Our privacy policy assures the policyholder and the beneficiary that their personal information has not been shared with any non affiliated third party company, except the companies that assist AIG Insurance Company - Puerto Rico in investigating claims.  AIG Insurance Company - Puerto Rico does not send privacy notices to beneficiaries, only policyholders.  Therefore, we recommend that you share this policy with your named beneficiary. 

Opt-Out Notices 
Under the law, if a financial institution or insurance company shares customer’s non-public personal information with non-affiliated third parties for marketing purposes, then a customer can use the opt-out feature to instruct a bank, financial institution or insurance company not to use their customer non-public personal information for marketing purposes.  Notwithstanding this, there is no need for you to “opt-out” of anything with AIG Insurance Company - Puerto Rico at this time since we do not share information with third parties for marketing purposes.  We are only required by law to send out this notice to all of our current customers. 

The insurance commissioner regulation no. 75 provides an exception to opt-out requirements for disclosure of non-public personal information for service providers, such as adjusters, attorneys, etc. 

Protection Security Measures 
At AIG Insurance Company - Puerto Rico we take privacy protection very seriously.  To assure that your personal information is safe we have through security measures.  We will generally require your written approval before we disclose any of your policy information to any non-affiliated third party that is not under the law exceptions. 

AIG Insurance Company - Puerto Rico entered into contractual agreements with non-affiliated third parties that prohibits the third parties from disclosing or using the information other than to carry out the purposes for which AIG Insurance Company - Puerto Rico disclosed the information.We will notify you on an annual basis if the privacy policy changes as long as you are still a customer of AIG Insurance Company - Puerto Rico.  

In addition, AIG Insurance Company - Puerto Rico has several safeguards in place to protect policyholder information.  They include: 
1.   Physical security: building and office security; 
2.   Procedural security: all personnel are on a strict need-to-know basis with respect to customer non-public personal information, and; 
3.   Electronic security: electronic safeguards for e-mail, fax, telephone  and  web site. 
  
We hope you found this notice helpful.  If you have any questions or would like more information, please do not hesitate to contact us. Thank you for choosing AIG Insurance Company - Puerto Rico. We value you as a customer and appreciate the opportunity to serve you. 

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