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Internet Privacy Statement

Welcome to the Benefit Access web site. This Privacy Statement explains our policy regarding personal information that you supply us when you visit the site. Keeping your personal information secure, and making sure you understand how we use such information, is important to us.

You may use this site only in connection with your participation in your employer's employee benefit plan ("Plan"). To visit the site, you will be required to give us your e-mail address. In addition, you must use the user name and password that we furnish to you.

The personal information you provide (and that your employer provides to us about you), and the personalized data you create and save on the site, is used primarily to facilitate your participation in the Plan (including effecting transactions). In addition, we use such information and data to provide you with "real-time" information about your Plan account, and in connection with your "modeling" of various transaction scenarios under the Plan. The information will be used in a manner consistent with the terms and conditions that govern your use of the site as well as all applicable law, rules, regulations and other legal obligations.

When you send us e-mails, they will be maintained in a manner consistent with our legal and regulatory requirements regarding client and public communications.

Online access to your option grant information is only possible through a secure (SSL capable) web browser. SSL capable web browsers support encryption technology, which helps prevent unauthorized users from viewing your Plan account information as it travels over the Internet.

Collection and use of information about you for pattern recognition and other authentication procedures are part of the log on process for clients and guests registered to use the site. The process is intended to assess the authenticity of a request by registered users to access, transact business through, or otherwise use the site. A combination of multiple authentication elements about you such as your individual and user information, transactional data, session surveillance, device fingerprint, IP information, and pattern recognition may be collected and used by us in a manner that will generally be transparent to you during your sessions on the site. If the authentication elements do not meet our satisfaction at any time as determined by us in our sole discretion, you may be required to pass through additional authentication assessments such as supplying specific answers to challenge questions or other procedures. We will collect and use information from or about you for such assessments, procedures and other administrative and business reasons as we may determine from time to time. In order to provide better service or to address security hazards, we will occasionally use a "cookie". A cookie is a small piece of information which a web site stores on your web browser on your PC and can later retrieve. The cookie cannot be read by a web site other than the one that set the cookie. We use cookies for a number of administrative purposes. Most cookies last only through a single visit to our site. None will contain information that will enable anyone to contact you via telephone, e-mail, or any other means.

Your browser software may contain a feature, which is intended to notify you of the cookies policies of the various websites that you visit. For example, certain Microsoft® Internet Explorer versions and other browser software contain such a cookie-filtering device commonly known as P3P. To learn more about P3P and how it may affect your online experience, click here. Although we have attempted to make this site compatible with the P3P privacy filtering tool, P3P is still an evolving standard and therefore, we are not responsible for any problems you may experience when using a P3P filter, or any discrepancies between the machine-coded statements of our privacy policy which are read by the P3P tool and the human readable policy which you see here. The privacy notice delivered to you as a Benefit Access participant, and the terms and conditions of the use of this site are controlling documents to which you should refer if you have any questions about our privacy policies concerning your use of this site.


Electronic Authentication

Collection and use of information about you for pattern recognition and other authentication procedures are part of the log on process for those registered to use the site. The process is intended to assess the authenticity of a request by registered users to access, transact business through, or otherwise use the site. A combination of multiple authentication elements about you such as your individual and user information, transactional data, session surveillance, device fingerprint, IP information, and pattern recognition may be collected and used by us in a manner that will generally be transparent to you during your sessions on the site. If the authentication elements do not meet our satisfaction at any time as determined by us in our sole discretion you may be required to pass through additional authentication assessments such as supplying specific answers to challenge questions or other procedures. We will collect and use information from or about you for such assessments, procedures and other administrative and business reasons as we may determine from time to time.


Other Sites and Services

This site may contain links to other Internet sites not under our direction or control. This privacy statement does not apply to those sites. We are not responsible for such sites, cannot control how such sites use personal information, cookies or other data, and their representations do not apply to this site. You should always review the privacy representations of those sites that you link to before you use them and particularly before you share personal information.


benefitaccess.com

Participants can review information about them through statements, the secure site or by contacting a Customer Service Representative as described in our site. Contact information such as our Internet or mailing addresses and telephone numbers are found on statements (as applicable), correspondence or this site. There may be a charge for requested information. To protect your privacy, proof of identity or other authentication may be required.


Security

We maintain your personal information and data according to strict standards of security and confidentiality as described on this site and in related materials. Online access to your information is through a secure (SSL capable) web browser. SSL capable web browsers support encryption technology, which helps prevent unauthorized users from viewing your information.

This Privacy Statement does not supersede the terms and conditions that govern your use of the site. Any conflict between the two shall be determined in favor of such terms and conditions. We may change this Privacy Statement at any time. Any changes or updates will be effective immediately upon posting to the site.

It is part of our policy for those businesses that collect U.S. Social Security numbers in the course of business to: protect the confidentiality of such Social Security numbers; prohibit the unlawful disclosure of such Social Security numbers; and limit access to such Social Security numbers.

Online privacy statements found on sites of our affiliates and other companies cover aspects of your relationship with those other entities and companies and are not confined to the policies concerning this site and may differ from such policies. Read those other statements carefully before using those sites.


Changes

We may change this privacy statement at any time. Any changes or updates will be effective immediately upon posting to this site. The effective date of this privacy statement, as stated below, indicates the last time this statement was materially changed. Checking the effective date below allows you to determine whether there have been such changes since the last time you reviewed the statement.


Questions

As a participant, a Customer Service Representative can assist you or direct your inquiries on these matters. Otherwise, for further direction regarding inquiries concerning this privacy statement, you may contact our Help Desk by or telephone as described on the site.


Effective Date

This online privacy statement was last modified: June 1, 2009.



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