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Privacy & Security

Effective Date: 03/15/2013

Privacy Notice Table Of Contents

Our Commitment To Privacy:

Your privacy is important to us. Renaissance Benefit Advisors, Inc. is committed to protecting the confidentiality and security of information you provide us on our websites. To better protect your privacy, we provide this Privacy and Security Policy to explain our online information practices and the choices you can make about the ways your information is collected and used. This Policy can be found on our homepage and at any place on our websites where personally identifiable information is requested.

If we decide to change our privacy policy, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page.

The Scope of This Privacy and Security Policy:

This Privacy and Security Policy only addresses our use and disclosure of information we collect from you on our websites. The website dcp.mydeferral.com is our service platform. The data collected from the "end user" on these sites is owned by our "Client." On our corporate website, www.mydeferral.com, all data collected on this site is collected and owned by Renaissance Benefit Advisors, Inc. Please note that other websites or third parties, referenced on our website, may adhere to their own customs and policies. We are not affiliated with the creation or management of the content or privacy policies of such websites or third parties. We are neither responsible nor liable for privacy or other information collection issues related to such other websites or third parties.

Data collected

We only collect the information that you provide to us or that we are directed to collect by the Client. Such data may include basic contact information such as your name, postal address, e-mail address, and phone number, as well as sensitive personal information such as compensation or payment information if required. In this regard, we do not control what end user data we may receive and host, nor what steps the Client, as data controller, has taken to ensure that the data is reliable for its intended use, accurate, complete, and current. We also collect Client Information on our portal and corporate website. Client Information is personal information about people in our Client's organization, such as account managers and users, who interact with our portal. Client Information usually is limited to name, work e-mail address, work phone number, and job title, and we collect it through the portal or other means provided to us. We use this information to support your account, maintain our business relationship with you, respond to your inquiries, and perform recordkeeping functions.

Notice

We operate under the assumption that it is generally our Client's obligation as data controller to notify individuals about the purposes for which we collect and use information about them, how individuals can contact us with any inquiries or complaints, the types of third parties to which they disclose your information, and the choices and means offered for limiting our use and disclosure. As your data processor, we make available to you this privacy policy so that you can better understand our data practices and whether they are consistent with privacy notices made available to you.

Access

The U.S.-EU Safe Harbor requires that data subjects must have access to personal information about them that an organization holds, and that they be able to correct, amend, or delete that information where it is inaccurate. We operate under the assumption that it is generally the Client's obligation as data controller to provide data subjects a means of accessing their data. If you would like your data deleted, please contact us at the information below. We will respond to requests within 30 days of receipt.

Choice

The U.S.-EU Safe Harbor requires that members offer end users a choice to opt out of uses and disclosures of their data that are incompatible with the purposes for which that data was originally collected or subsequently authorized. We operate under the assumption that it is generally our Client's obligation as data controller to obtain from data subjects the appropriate consent to transfer their data to us and to process data using our products for defined purposes. As your data processor, we will not share, sell, rent, or trade with third parties for their marketing purposes any Client or end user data collected by us, unless you direct us to do so and have the appropriate authorization to do so.

The Information We Collect and The Ways We Use It:

This notice applies to all information collected or submitted on our websites. On some pages, you can log into your account, initiate account transfers, make changes to account information, and request additional information. Once you log onto any of our websites, you provide us with the identity of your current Internet address and the type of operating system and browser software you are using. While you are visiting our website, we may ask you for other personal information. The types of personal information that we may request from you, upon you visiting our website, are your name, address, e-mail address, phone number, etc. Please note that providing such information is optional. However, in order to access the personal information we collect about you, you may be required to provide identifying information.

During your visit to our website, we may also keep track of the sections of our website that you visit the most. We do this so we can continually provide our users with better visiting experiences. For instance, we may use such user tracking information to modify the most frequently visited sections of our website, so that they can be accessed more efficiently by a broader range of operating systems. Additionally, we may aggregate your tracking information with that of our other website users in order to tell our programmers that X number of users visited a certain area on our website, or that Y number of users filled out a form. We will not, however, disclose any information that could be used to identify you or any of the other website users. Any personal information that you provide us with on our website is only used on your behalf to complete a transaction or change, or provide any other assistance, that you request. We do not share this information with outside parties except to the extent necessary to complete that transaction, change, or request. We use return email addresses only to answer the emails we receive. Such addresses are not used for any other purpose and are not shared with outside parties. Moreover, we never use or share the personally identifiable information provided to us online in ways unrelated to the ways described above, without first providing you with an opportunity to opt-out or otherwise prohibit such unrelated uses.

Our Commitment To Data Security:

The security of your personal information is important to us. When you enter sensitive information on our portals, we encrypt that information using secure socket layer technology (SSL).

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

"Cookies" are data files sent by a website to your computer memory. They can be used to track activity on the website and help protect the security of confidential data. Your privacy and security are not compromised when you accept a cookie from our website because no other company can access our cookie information except us. The visitor information stored in a cookie, during a session to our website, is only valid for that single session; it would be useless to anyone who could decipher it once the visitor is logged out.

Some of our business partners use cookies and other tracking technologies on our corporate site. We have no access to or control over these cookies and data is only collected in the aggregate.

Accessing Or Correcting Your Information:

You can access all your personally identifiable information that we collect online and maintain by visiting the website or contacting the plan administrator. If there are any factual errors regarding your personal information located on our website, you can correct the errors by sending a request to the designated contact of the website that credibly shows error.

To protect your privacy and security, if the contact individual is our employee, we will also take reasonable steps to verify your identity before granting access or making any corrections.

Minors:

This website does not intend to collect any information from, or market any products or services to, children. We do not knowingly gather or solicit data from children under the age of 18 through our website for marketing purposes.

Additional Rights:

Applicable federal and state laws may give you additional rights that are not put forth in this online Privacy and Security Policy. We reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Website.

How To Contact Us:

Should you have any questions or concerns about this Privacy and Security Policy, please call us at 1-800-692-8463 (Outside the U.S. call +1-267-482-6400), contact us online, or at our mailing address at :

MyDeferral Client Services
2600 Kelly Road, Suite 210
Warrington, PA 18976

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