Privacy Policies

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Privacy Policy

Nautilus Insurance Company and Great Divide Insurance Company are member companies of the W. R. Berkley Corporation (“Berkley”) group of companies and each other member of the Berkley group of companies (“Affiliates”) understands our customers’ concern about privacy of their information collected by us. Nautilus Insurance Company and Great Divide Insurance Company are dedicated to protecting the confidentiality and security of nonpublic personal information we collect about our customers in accordance with applicable laws and regulations. This notice refers to the Companies by using the terms “us,” “we,” or “our.” This notice describes our privacy policy and describes how we treat the nonpublic personal information about our customers that we receive from them (“Information”). Why We Collect and How We Use Information. We collect and use Information for business purposes with respect to our insurance products and services and other business relations involving our customers. We gather this Information to evaluate our customer’s request for insurance, to evaluate its insurance claims, to administer, maintain or review its insurance policy, and to process its insurance transactions. We also accumulate certain information about our customers as may be required or permitted by law. Our customers’ insurance agent or broker also collects this Information and may use it to help with a customer’s overall insurance program or to market additional products and services to a customer. We may also use Information to offer a customer other products or services that we or our Affiliates provide. How We Collect Information. Most Information collected by us is provided by a customer or its insurance agent or broker to us. We obtain Information from (i) applications or other forms submitted by a customer, its insurance agent or broker or its authorized representatives to us and our Affiliates, and (ii) a customer’s transactions with us or our Affiliates. We may also obtain Information from other sources such as (i) consumer reporting agencies, (ii) other institutions or information services providers, (iii) employers, or (iv) other insurers. Information We Disclose We disclose any Information which we believe is necessary to conduct our business as permitted by applicable law or where required by applicable law. This disclosure may include (i) Information we receive from a customer on applications or other forms provided to us and our Affiliates, such as names, addresses, social security numbers, assets, employer information, salaries, etc. (ii) Information about a customer’s transactions with us and our Affiliates, such as policy coverages, premiums, payment history, etc., and (iii) Information we receive from a consumer reporting agency, such as credit worthiness and credit history. To Whom We Disclose Information We may, as permitted or required by applicable law, disclose a customer’s Information to nonaffiliated third parties, such as (i) insurance agent or broker, (ii) independent claims adjusters, (iii) insurance support organizations, (iv) processing companies , (v) actuarial organizations, (vi) law firms, (vii) other insurance companies involved in an insurance transaction with a customer, (viii) law enforcement, regulatory, or governmental agencies, (ix) courts or parties therein pursuant to a subpoena or court order, (x) businesses with whom we have a marketing agreement, or (xi) our Affiliates. We may share Information with our Affiliates so that they may offer a customer products and services from the Berkley group of companies or to analyze our book of business and to consolidate necessary information. We do not disclose Information to other companies or organizations not affiliated with us for the purpose of using Information to sell their products or services. For example, we do not sell a customer’s name to unaffiliated mail order or direct marketing companies. How We Protect Information We require our employees to protect the confidentiality of Information as required by applicable law. Access to Information by our employees is limited to administering, offering, servicing, processing or maintaining of our products and services. We also maintain physical, electronic and procedural safeguards designed to protect Information. When we share or provide Information to other persons or organizations, we contractually obligate them, if required by law, to treat Information as confidential and conform to our privacy policy and applicable laws and regulations. Correction and Access to Information Upon our receipt of a customer’s written request to us, we will, generally, make available Information for the customer’s review. If the customer believes the Information we have about it is incorrect or inaccurate, the customer may request that we make any necessary corrections, additions or deletions. If we agree with the customer, we will correct our records if required by applicable law. If we do not agree, the customer may submit to us a short statement of dispute, which we will include in any future disclosure by us of such Information if required by applicable law.

SOCIAL SECURITY NUMBER PRIVACY PROTECTION POLICY

I. POLICY Nautilus Insurance Company and Great Divide Insurance Company (“we”, “our” or “us”) are committed to maintaining the confidentiality of Social Security numbers that it collects during the regular course of business. Accordingly, we have established this policy to restrict access, disclosure, use and disposal of Social Security numbers that have been collected by us. The purpose of this policy is to comply with Federal, state and local law protecting the confidentiality of Social Security numbers, including but not limited to Connecticut Public Act No. 08-167, effective October 1, 2008. II. PROCEDURES TO PROTECT THE CONFIDENTIALITY OF SOCIAL SECURITY NUMBERS   Authorized Collection And Access To Social Security Numbers We collect the Social Security numbers of employees, applicants, independent contractors, interns and other individuals only for legitimate business reasons. Examples of such reasons may include: The handling of insurance claims and payments in connection with operating its insurance business; Background checks for applicants for employment; Determining eligibility for employment; Enrollment in employee benefits programs; Reporting that is required by law, such as for tax purposes. We restrict access to the Social Security numbers that it collects only to our employees and certain third parties who are authorized to access this information. Authorized employees are those whom we have determined to have a legitimate business need to access this information. Authorized third parties are those who have a legitimate need to access this information and owe a duty to maintain its confidentiality (e.g. vendors who are provided Social Security numbers to run background checks and insurance providers).   Disclosure And Use Of Social Security Numbers We prohibit the disclosure and use of Social Security numbers unless such disclosure and use complies with this policy and with Federal, state and local law. Social Security numbers shall not be displayed on identification cards or badges, bulletin boards, or any similar materials that are publicly displayed. Documents, materials or computer screens that display Social Security numbers shall be shown only to authorized employees and third parties and shall be kept out of public view at all times. Social Security numbers may only be used by authorized employees for legitimate business reasons, including but not limited to those reasons described above.   Storage And Disposal Of Personal Information Including Social Security Numbers We shall take reasonable steps so that all documents and files (both electronic and in hard copy) that contain personal information such as Social Security numbers shall be stored in a physically secure manner. “Personal information” is defined under the law as information capable of being associated with a particular individual through one or more identifiers. Examples of personal information include a person’s Social Security number, driver’s license number, passport number, credit or debit card numbers and health insurance identification numbers. We require that personal information be stored in a way that prevents unauthorized access. For example, hard copy documents that contain personal information should be stored in files that can only be accessed by authorized employees or third parties, and computers or other electronic devices that contain personal information should be secured against unauthorized access, such as through the use of a password. We require that any authorized personnel who maintains personal information must take appropriate steps consistent with this policy to safeguard such information. Documents or other materials (both electronic and in hard copy) that contain personal information shall be disposed of in a manner such that the personal information is erased or made unreadable at the time of disposal. It may be necessary to consult with our IT department to ensure proper disposal of personal information that is stored electronically. III. NON-COMPLIANCE WITH THIS POLICY AND THE LAW Failure to comply with this policy may result in disciplinary action up to and including termination. Furthermore, the law provides civil and criminal penalties for individuals who violate laws protecting the confidentiality of Social Security numbers. If you have any questions about this policy, including about how to dispose of personal information, please contact Jan Shemanske, Vice President at jshemanske@nautilus-ins.com or by telephone at 1.800.842.8972.