“ZC Sterling” refers to ZC Sterling Corporation, a Delaware corporation (“ZCSC”) and the active companies owned or controlled by ZCSC.These companies are ZC Sterling Insurance Agency, Inc., a California corporation (“ZCSIA”), and ZC Real Estate Tax Solutions Limited, a Delaware corporation (“ZCRETS”). ZCSIA is regulated by the insurance departments of the various states due to its status as managing agent, managing general agency or program manager for its various affiliated and non-affiliated insurance companies.

We respect the privacy of our customers and are committed to protecting their information on our Web sites with the same care we utilize for all ZC Sterling transactions.

ZC Sterling does not automatically collect personal information from visitors to its Web-sites.Some ZC Sterling Web sites employ cookies, which are small pieces of information that a Web-site stores on a visitor’s Web browser to remind the site about the visitor the next time they visit the site. ZC Sterling does not store confidential or sensitive information in cookies. ZC Sterling uses cookies to enhance our customers’ online session by making navigation easier. For certain applications, such as those related to our ZIPS single system hazard outsourcing solution and our personal lines underwriting site, cookies are a requirement because they help protect the privacy of a customer’s transactions by, for example, automatically terminating the online session if the customer forgets to log out.

Cookies cannot be used to capture your e-mail address, obtain data from your hard drive or gain confidential or sensitive information about you. Additionally, cookies cannot be read by a Web-site other than the one that set the cookie. However, some Web sites use cookies to obtain information from your browser.

ZC Sterling Customer Information Privacy Principles

As financial services professionals entrusted with sensitive information, we respect the privacy of our customers and are committed to treating customer information responsibly. Our Customer Information Privacy Principles serve as standards for all ZC Sterling employees for collection, use, retention, and security of individual customer information.

ZC Sterling Collects and Retains Only Customer Information That Is Needed

We limit the amount and type of customer information we collect and retain that which is required to establish and manage customer relationships, understand customer needs, provide customer services, offer new products and services, and comply with legal and regulatory requirements. Examples of information collected include the following:

• Property Information:Includes mailing address, property address, square footage, year built, underwriting inspection reports, claims history reports, independent claims adjustment reports, and other miscellaneous underwriting information.
  
  
• Insurance Information:Includes carrier and agent name, policy number, policy inception and expiration dates, premium amount, premium due date, policy amount, coverage amounts and types, loss payee/mortgagee and additional insured, and covered property address.
  
  
• Loan Information:Includes loan number, loan inception date, principal balance, escrow account number, escrow account balance, mortgagor name and address, mortgagor phone number, and credit reports.

Note: Other information collected and maintained by ZC Sterling’s Real Estate Tax application includes real estate tax parcel, billing, and payment information from taxing authorities throughout the United States.All such information is available to the public, and as such, all information gathered and maintained is “publicly-available information,” and thus exempted from the purview of privacy legislation.

ZC Sterling Employees Are Responsible For Customer Information Protection

We limit employee access to customer information to those employees with a legitimate business need for the information. We have policies, procedures, employee orientation, and communication programs designed for the protection of customer information. It is the responsibility of each ZC Sterling employee to comply with our Customer Information Privacy Principles policies and procedures. Failure to comply subjects our employees to disciplinary action.

ZC Sterling Limits The Internal Disclosure Of Customer Information

We share non-transactional personal information, such as applications, insurance underwriting and claims information, and real estate tax information among affiliated and non-affiliated insurance companies and local taxing jurisdictions.

ZC Sterling Limits The External Disclosure Of Customer Information

We do not disclose customer information outside the ZC Sterling companies, except:

We may share your personal information only with authorized employees and with vendors, such as medical exam providers, insurance agents and claims administrators whose services are required to assure the highest level of service to you, as well as affiliates of ZC Sterling as applicable as permitted by law.We reserve the right to disclose your information to these employees and vendors without your authorization as applicable as permitted by law.

We will not disclose any non-public personal financial information about our customers to others, except as authorized by law or as described in this Privacy Policy.

We may also enter into joint marketing agreements with other reputable financial institutions in order to bring additional products and services to your attention. We may disclose all of the financial information we collect as described above to individuals or companies that perform marketing services on our behalf, or to other financial institutions with whom we have joint marketing arrangements.We will choose these partners carefully and hold them to our own standards of respect for your privacy.We also may share your financial information:

• when we suspect fraud or are otherwise required or permitted to do so by law or regulation,
• when a customer requests or gives us permission to do so.

ZC Sterling Provides Security Safeguards To Protect Customer Information

We use advanced technology and information management techniques to implement security, audit, and control programs designed to protect customer information.

ZC Sterling Protects Customer Information On Our Web-sites

We protect the privacy of customer information sent to and from our web-sites. In addition to the security and privacy standards that are applied to transactions, we also use specific controls designed to identify and authenticate all our online customers and prevent and detect unauthorized access to our web-sites.