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FRAUD AND PRIVACY POLICIES

FRAUD POLICY
Revision Date
Last modified:  January 10, 2020

INTRODUCTION
USLI recognizes that fraud exists in the insurance industry. As such, it is the policy and mission of the company to strive to detect and prevent insurance fraud through the employment of an effective and diligent Anti-Fraud Plan. As part of the company’s management process, USLI claim staff will endeavor to thoroughly review each claim with the specific goal of identifying those claims exhibiting fraud related indicators, red flag events and situations or behavior indicative of fraud schemes. Those identified will be directed for specialized handling.

ANTI-FRAUD PLAN
The purpose and goal of our Anti-Fraud Plan is to educate, detect, investigate and deter insurance fraud thereby helping to reducing insurance costs.

FRAUD INVESTIGATION AND TRAINING
The company has a Special Investigations Unit (S.I.U.) that is responsible for the review and disposition of all suspected fraudulent insurance acts. The S.I.U. also provides training to employees and appointed producers in detecting, investigating and referring cases of suspected transactional and claim fraud.  If you are interested in assisting USLI in its anti-fraud efforts and would like to receive more information or training on how to detect and handle cases of suspected fraud, please contact one of the members of our S.I.U. listed below.

S.I.U. REVIEW COMMITTEE
Lauren Reiley
Senior Vice President, General Counsel, Chief Compliance Officer
1190 Devon Park Drive, Wayne, PA 19087-2191
(610) 225-2224
[email protected]

Jim Scalise
Executive Vice President, Chief Claims Officer
1190 Devon Park Drive, Wayne, PA 19087-2191
(610) 225-2551
[email protected]

SPECIAL INVESTIGATION UNIT (S.I.U.)
The company has an S.I.U. composed of a three person Anti-Fraud Review Committee responsible for the review and disposition of all suspected fraudulent insurance acts, a two person Anti-Fraud team responsible for the detection, evaluation, investigation and reporting to state fraud bureaus, and a Legal & Compliance Team to provide assistance in the company’s anti-fraud efforts.

POSITION
Insurance fraud will not be condoned by USLI. Our personnel are dedicated to the prevention of insurance fraud and will aggressively review, analyze, monitor, investigate and seek prosecution of fraudulent insurance acts to the fullest extent of the law. These acts include but are not limited to: Application Fraud, Certificate of Insurance Fraud, Fraudulent Insurance Claims and the Understating Rating Exposures such as Sales, Payroll, etc. Further, we will comply with state statutes with respect to the reporting, investigation, and preparation of Anti-Fraud Plans.

REPORTING
Suspected fraudulent insurance acts must be reported to the respective State Fraud Bureau where applicable. Those acts involving  USLI should be referred to the company using the sample referral form.

REFERRAL FORM

All suspected fraudulent insurance act referrals including supporting documentation should be forwarded to:
Chief Compliance Officer
USLI
1190 Devon Park Drive, Wayne, PA 19087


GENERAL PRIVACY NOTICE

Revision Date
Last modified:  January 10, 2020

INTRODUCTION
USLI and its subsidiaries, affiliates, and related entities (collectively, “USLI," "we," or "us") respect your privacy and are committed to protecting it through compliance with this General Privacy Notice (“Privacy Notice”).  In accordance with that commitment, this Privacy Notice is intended to notify you of our practices for protecting, collecting, using, and disclosing your personal information.

For purposes of this Privacy Notice, “personal information” means any information that identifies or could reasonably be linked, directly or indirectly, with a particular individual or household.  Personal information does not include publicly available information, deidentified data, or aggregate consumer information.

Please carefully read this entire Privacy Notice to understand our policies and practices regarding your personal information.  Your use of our Website as well as our products and services will be deemed acceptance of our privacy policies and practices.

DATA SECURITY
We have implemented measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure.  Such measures involve strict physical, electronic, administrative, and procedural safeguards.    

As part of USLI’s privacy policy, we restrict access to your personal information to those who need it to provide our products and services to you.  Our employees are also trained to safeguard customer information.  Furthermore, a “PRIVACY NOTICE,” is automatically included with all Personal Lines policies issued by USLI, which notifies our consumers of what information we collect about them, what information we disclose, who we disclose it to, and how we protect that information from unauthorized use or disclosure.

PERSONAL INFORMATION COLLECTED
Depending on the particular individual and business purpose, we may collect any of the following from you:

● Identifiers and other personal information, including or regarding your name, characteristics protected under state or federal law, postal address, email address, telephone number, social security number, USLI account information, relevant medical, property and financial information, employment history, and insurance licenses, policy numbers and other coverages. 

 Additionally, we may collect commercial information, such as credit and claims history and motor vehicle reports, from consumer reporting companies.

PURPOSES OF COLLECTED PERSONAL INFORMATION
We may use personal information collected about you:

● To process your application and quote
● 
To service your policy and any claims you may make
● To provide you with notices about your policy, including expiration and renewal notices
● For various communications with you, as needed
● To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection
● To comply with applicable laws and regulations
● In any other way we may describe when you provide the information
● For any other purpose for which you provide it and/or consent

THIRD PARTIES/DISCLOSURE OF COLLECTED PERSONAL INFORMATION
We will not sell collected personal information to any third parties whatsoever. Additionally, we will only disclose personal information to third parties when required and permitted by law.  For example, we may disclose collected personal information:

● To agents, investigators, adjusters, appraisers, attorneys, and other individuals or entities involved in processing your application, issuing your quote, and servicing your policy and any claims you may make
● To individuals or entities as necessary to perform transactions you request or authorize
● To enforce or apply our agreements with you, including for billing and collection purposes
● If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of USLI, our customers, and/or others
● With state insurance departments or other governmental or law enforcement authorities if required by law or to protect our legal interests, including in cases of suspected fraud or illegal activities
● If ordered by a subpoena or other court order
● To the subsidiaries, affiliates, and related entities of USLI by virtue of their commonality of employees and systems

We issue a “NOTICE” to all third parties with whom we do business cautioning against the disclosure of personal information in connection with any agreements we may have with them and/or services they may provide to us.

While we have links to third party organizations and companies, a link does not constitute an endorsement of content, viewpoint, policies, products, or services of that website.  Please be aware that USLI is not responsible for the privacy practices of those sites even though USLI’s logo may appear on those sites.  This Privacy Notice applies solely to our website.

COOKIES/AUTOMATIC DATA COLLECTION
Cookies help promote functionality and to personalize your experience. Cookies are small text files automatically sent from a website the user is browsing and stored in the user's web browser. Some cookies are present only for the session, while other cookies persist for a pre-determined time. In some cases, the browser sends the cookie back to the server every time the user loads that website.

Our website uses cookies in a very limited manner. Cookies are used on our website only to collect account information from our agents. This allows our appointed customers to access secure areas of our website. Our website does not collect any other information from our appointed customers, nor does it collect any information whatsoever from other individuals.

Most browsers allow you to manage your cookie preferences with common options such as:

● Enable or disable all cookies indefinitely (i.e., always accepted or always blocked)
● Selectively block cookies
● View and selectively delete cookies
● Wipe all private data, including cookies
● Block third party (tracking) cookies

Some browsers also have extensions or add-on tools for managing cookies and cookie permissions. For more information about managing or disabling cookies, check your browser or mobile device settings, and visit http://www.allaboutcookies.org.

CHANGES TO OUR PRIVACY NOTICE
We will occasionally modify our Privacy Notice as needed. Any changes will be incorporated into this Privacy Notice, and the most recent version of the Privacy Notice will always be posted on our website. The date the Privacy Notice was last revised is identified at the top of the page. You are responsible for periodically reviewing our website and this Privacy Notice for any changes.  Your continued use of this website will be deemed acceptance of any such changes. 

PRIVACY NOTICE APPLICABILITY
This Privacy Notice applies to all subsidiaries, affiliates, and related entities of USLI, specifically including:

● United States Liability Insurance Company
● Mount Vernon Fire Insurance Company
● U.S. Underwriters Insurance Company
● Mount Vernon Specialty Insurance Company
● Radnor Specialty Insurance Company
● Apogee Insurance Group
● Gateway Underwriters Agency, Inc.
● Gateway Specialty Insurance

This Privacy Notice merely supplements, and does not replace, other applicable privacy policies and procedures that relate to your business relationships with USLI.

CONTACT INFORMATION
For questions or comments regarding this Privacy Notice or our privacy practices, please write us at:

Attn:  Legal and Compliance, Cybersecurity and Data Privacy
USLI
1190 Devon Park Drive
Wayne, PA 19087

You may also email us at [email protected].

 

NOTICE TO NONAFILLIATED THIRD PARTY CONTRACTORS  

Available to nonaffiliated third party contractors (prohibiting against disclosure of nonpublic information in connection with agreements we have with them and/or in connection with services they provide for us).