Specialty Program Group LLC Privacy Policy (U.S.) and Privacy Notice for California Residents

1. Updates to Policy, Accessibility of Policy, and Regional Differences

Updates to Policy

From time to time, we may change our privacy practices, which will require changes to this Policy. The latest version of this Policy will be posted on our websites, and the date it is effective will be displayed. We encourage you to look for updates and changes to this Policy when you access our websites. Your continued use of SPG's websites, mobile applications, and services following the posting of changes constitutes your acceptance of such changes with respect to your use of our websites, mobile applications, and services.

Accessibility

If you have special needs with regard to accessing the content of this Policy, contact us at: privacy.compliance@specialtyprogramgroup.com. Please include the words "Accessibility Issue" in your subject line and explain steps we can take to help you to review and understand this Policy.

Regional Differences

Certain jurisdictions provide enhanced Personal Information rights to residents depending on the jurisdiction and the reason SPG is processing Personal Information

2. Definition and Exclusions of Personal Information

"Personal Information" means any information that identifies you or can reasonably be linked to you or your household and includes data such as your name, postal address, email address, and telephone number. Due to the nature of our business as described further in the Section called "Information SPG Collects" below, Personal Information handled by SPG about you may also include:

• your name, Social Security Number, driver's license, or other government-issued identification;
• assets and income, occupation, and employment status, dependent information, and other relevant financial information;
• information relating to any of your past claims, driving history, certifications, license details, previous insurance policy details, previous accident and claims history including any driving convictions;
• information from reporting agencies and state and federal government agencies, such as state motor vehicle departments;
• information from other sources, such as medical or health care providers and other third parties with which you or we maintain a relationship including credit reference agencies, vetting and data validation agencies, advisory service providers, insurers, underwriters, reinsurers, business partners;
• your account activity and premium payment history;
• benefits information such as benefits elections, pension entitlement information, date of retirement and any relevant matters impacting your benefits;
• information about your interest in and attendance at SPG sponsored events, including feedback responses;
• information from social media interactions with SPG's social media presence, feedback forms or surveys;
• credit card, bank account or other account information as may be required to facilitate your payment of insurance premium or similar amounts, which payment generally is made through systems maintained by third parties, such as insurance carriers;
• passive tracking information from our website or the Internet, including information obtained through the use of internet "cookies" as detailed in the "Cookie Choices" section below; and
• inferences drawn from other Personal Information, precise geolocation data, and sensory data such as audio or visual information.

Personal Information does not include aggregated or anonymous information which does not identify and cannot reasonably be used to identify you or your household. It also does not include other categories of information excluded by state or federal law.

3. Information SPG Collects

We are generally unable to perform insurance brokerage or other insurance or financial industry services on your behalf without collecting, using, or disclosing your Personal Information, including sensitive Personal Information. Typically, you will provide your Personal Information directly to us as your broker, as part of a written application for insurance coverage. Other times, we may receive this and other Personal Information from third parties, including insurance carriers and other industry service providers, and other third parties with which you maintain a relationship (for example, your employer and providers of financial or medical services). We may also develop this information over time based on your direct or indirect interactions with us, such as through the use of cookies on our websites.

Please keep in mind that when you provide information to us on a third-party site or platform, the information you provide may be separately collected by the third-party site or platform. We encourage you to read the privacy policies of other sites and mobile applications that may collect your Personal Information.

When you hire SPG to broker insurance or advise you directly, we collect the amount and types of Personal Information that are required for us to perform or support services you requested. This includes information that may be required by an insurance carrier or an industry service provider in the course of providing you with insurance coverage or related services. If you use our websites, we may collect information about your device, browser and other information regarding your web usage using tracking tools described in this Policy. This information collection could include relevant market research designed to make our products and services better; this and other information may include the Personal Information as defined above. SPG also offers its products and services to organizations that act in the performance of their business or profession ("Commercial Clients"). For instance, if SPG performs insurance-related services for your employer (such as employee benefits, retirement, or risk management services), then SPG may need to collect and handle some of your Personal Information to perform those services. SPG refers to this work as our Commercial Business and in that situation, your employer would be a Commercial Client. In these cases, (1) SPG requires Commercial Clients (such your employer or retirement plan) to have appropriate authorization to provide your Personal Information to SPG, (2) SPG requires the client to provide the minimum amount of your Personal Information necessary for SPG to provide the requested services, and (3) SPG Processes the information pursuant to directions and security safeguards required by SPG's contract with the client. Please see "Information SPG Processes When Performing Services for Commercial Clients" below for more details.

4. Use of Cookies and Other Web Tracking Technologies

When you visit any website, it may store or retrieve information on your browser, often in the form of cookies. Cookies are files which can store information in your computer hard drive or other devices and help us and our partners to better understand user behavior. We may use cookies and other web tracking technologies such as pixels, web beacons and session recording tools (collectively, "Web Tracking Technologies") on our websites and mobile applications. Information collected in this manner might be about you, your preferences, or your device; it is primarily used to allow the website to work as you expect it to and to provide a more personalized web experience. This information is also used for security and fraud prevention purposes, to identify which parts of our websites people have visited, to facilitate and measure the effectiveness of advertisements and web searches, and to improve user experiences. We may combine information derived from Web Tracking Technologies with information provided directly by you.

SPG uses different categories of cookies:

• Strictly Necessary Cookies. These cookies are necessary for the website or application to function and cannot be disabled. They are used where required to provide a specific feature or service that you have accessed or requested and that cannot be provided without the use of such cookies (e.g., actions like setting privacy preferences, logging into your account, or filing form fields). If you set your browser to block these cookies, then some parts of the website may not work.
• Performance or Analytical Cookies. These cookies allow measurement of website activity by tracking user visits, the geographic location of users, and the volume of users. We use these cookies to help us analyze and count visits and traffic sources so we can measure and improve the performance of our site. For instance, these cookies help us learn which pages are the most and least popular and understand how visitors move around the site. If you do not allow these cookies, SPG will not know when you have visited its website and will be unable to fully monitor the website's performance.
• Functional Cookies. These cookies enable the website to provide enhanced functionality and personalization. Some functional cookies may be developed by third party service providers whose services are incorporated into the website. Disabling these cookies may (i) disable third-party services and (ii) impact the overall ease of use of the website or application functionality.
• Targeting Cookies. These cookies collect information used to understand how visitors interact with our websites and online services. This information helps us: (a) to assess the effectiveness of web searches, (b) to provide you with a more customized experience, and (c) to provide personalized and relevant product offerings and advertisements. Social media cookies are a subset of Targeting Cookies that may share Personal Information you generate on SPG's website with social network websites and subject your data to those websites' privacy policies and user terms of service. These cookies may be developed by our advertising partners and collect information that may be used by SPG and its advertising partners to build a profile of your interests and to show you relevant advertisements on other websites. If you do not allow these cookies, you will experience less advertising that is curated to your interests.

5. Use and Disclosure of Personal Information

We generally only disclose your Personal Information to perform services on your behalf and provide you with the insurance products and services you expect from us. In addition, in order to operate our business and provide you with the services you request from us, information technology and other support service providers with which we maintain an arrangement may also have access to your Personal Information. Your Personal Information may be disclosed to third parties in connection with a merger, sale, or other transfer of organizational assets where Personal Information held by us about our clients is among the assets transferred.

We may from time to time disclose your Personal Information for the following reasons:

• to fulfill or meet the reason you provided the information and for our everyday business purposes, such as to obtain initial and renewal quotations for insurance or other insurance or financial industry services (including those procured proactively and/or in connection with the movement of a book of business from one provider to another) on your behalf; to obtain insurance (or similar products) on your behalf or to facilitate the performance of related services by other industry service providers; to maintain or service your account or insurance, including by reporting claims of loss to other industry service providers, such as insurance carriers and adjusters; to evaluate our performance or offerings; to allow risk management or actuarial evaluation of prospective or existing placements; to confer with medical professionals if necessary regarding a relevant claim; and to make reports to credit bureaus. We may also save your information to facilitate new quotations or placements.
• for legal reasons, such as to make required or advisable reports to insurance regulatory, law enforcement or other similarly situated authorities including government authorities; to respond to and comply with court orders, applicable law, and other legal requirements; and to defend ourselves against claims and to enforce our rights or protect our employees or property.
• for our own marketing purposes so that we may offer you our products and services, including using targeted or similar advertising on the internet. You will be given the opportunity to opt out of direct marketing from SPG, and you can change your marketing preferences by contacting SPG as set forth in this Policy.
• for joint marketing purposes so that we and any third-party product or service provider may together offer you products and services.
• for our affiliates' everyday business purposes, such as to process or service transactions or to provide or receive shared organizational services.
• for our affiliates' marketing purposes so that they may offer you their products and services using Personal Information, including eligibility information.
• for our and our affiliates' fraud prevention purposes where necessary to prevent and detect fraud.
• for non-affiliated third parties whenever you consent to such sharing, when the information cannot reasonably identify you, when business partners or third-party companies play a related or expected role in an insurance transaction, or as needed for SPG to participate in insurance support organizations. SPG may disclose to its referral partners with whom you already have a relationship certain Personal Information, including (i) campaign performance information such as the e-mail open rates, click rates, unsubscribe rates, and (ii) information about insurance coverage obtained because of the partner's referral to SPG. This information is disclosed to measure the impact of marketing and outreach campaigns and to calculate commissions.
• for our internal and external auditors, where necessary for company audits, complaint investigation or investigation of a security threat.
• for other purposes as may be permitted by law.
• to evaluate, negotiate or effect a business transaction (e.g., a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets) in which Personal Information held by us about our consumers or website users is among the assets evaluated or transferred.

6. Use of Automation for Insurance Quoting

SPG's online formats may utilize certain types of automation which assist insurance carrier partners ("insurers") with their underwriting of insurance. Such automation may result in the use of your Personal Information by the insurer to create predictions about insurance products and premium pricing, and information about insurance carrier market categories that would be appropriate for you. The goal of such an interaction would be for you to receive one or more insurance quotations or estimations of premium and coverage details. Each insurer will have methodologies, including underwriting algorithms, to help with making underwriting decisions. Insurers' underwriting decisions for insurance coverage, and the use of data for making those decisions, are each subject to the applicable privacy policy and privacy rights request process of that insurer. Your Personal Information is protected and is utilized consistently with the purposes and categories of this Policy, and the intention of our use of this technology is that it operates without improper biases. Based on applicable law, you may have the rights to: (a) opt-out of the processing of your Personal Information by automated decision-making technology that produces a legal or consequential effect, (b) correct inaccurate Personal Information used by automated decision-making technology to make a consequential decision about you, and/or (c) appeal, via human review if technically feasible, an adverse consequential decision concerning you arising from the use of automated decision-making technology. If available in your area, these rights can be exercised through the SPG Consumer Privacy Request Portal.

7. Your Privacy Rights and How to Exercise Them

Governments are increasingly granting consumers certain rights regarding their Personal Information. SPG honors requests in accordance with and to the extent required by applicable consumer privacy laws, which may vary depending on where you live. Depending on your state of residence, your rights may include:

To exercise any of these privacy rights, to make a related request, or to ask any question concerning this Privacy Policy, please contact us via any of the following methods:

• Visit the SPG Consumer Privacy Request Portal
• Email privacy.compliance@specialtyprogramgroup.com (please include "Personal Information Rights Request" in your subject line)
• Call us at 866-415-2207
• Write us at:
  Chief Legal Officer
  Specialty Program Group LLC
  150 N Riverside Plaza, 17th Floor
  Chicago, IL 60606

Please include your name, address, telephone number, and email address whenever you contact us. Depending upon the nature of your request, SPG may require you to provide additional information to verify your identity and authority to access or direct the processing of the Personal Information that is the subject of the request. SPG may deny certain privacy requests with respect to your Personal Information if we cannot verify your identity. You may also use an authorized agent to submit a request to exercise your privacy rights on your behalf. If you have an authorized agent submit a request on your behalf, SPG will require (i) you to provide the authorized agent with written permission to act on your behalf, and (ii) your agent to verify their identity directly with SPG. SPG may deny a privacy-related request from an agent that does not meet these requirements.

Situations Where Rights Cannot Be Granted

There may be situations where we cannot grant a particular request --- for example, if you ask us to delete your transaction data but we are legally obligated to keep a record of that transaction to comply with law or if we are unable to verify your identity through standard and reasonable means. We may also decline to grant a request where doing so would undermine our legitimate use of data for anti-fraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied could be that granting the request would jeopardize the privacy of others; that the request is substantively frivolous or vexatious; or that granting the request would be highly impractical in the context of our legitimate business purposes. If we are unable to fulfill your privacy request to access, review, delete or correct your Personal Information, we will provide you with an explanation

8. Cookie Choices

SPG gives you the ability to opt-out of cookies that are not essential to the services of the SPG-controlled websites and applications you use. This option is presented by SPG's Cookie Preference Center when you visit our websites (i) for the first time and (ii) after you clear your browser cache.

Your computers or devices also have tools within their browsers that allow you to manage your acceptance of cookies. These can include the ability to disable or block non-essential cookies, remove cookies, automatically accept cookies, or notify you when a cookie is received. Refer to "https://allaboutcookies.org/how-to-manage-cookies" for detailed explanations by browser (e.g., Google Chrome). Generally, disabling or rejecting cookies can negatively impact your user experience (e.g., because certain features of our website may not be available).

SPG uses both Adobe and Google as website service providers. To learn about Adobe Analytics privacy practices or to opt-out of Adobe cookies which are used to facilitate reporting, visit Adobe Privacy Center. To learn more about Google's privacy practices, visit the Google Privacy Center. To access and use the Google Analytics Opt-out Browser Add-on, visit Google Opt-out.

9. Global Privacy Control (GPC) Signal

In certain jurisdictions, you have the right to opt-out of the use, sharing, and sale of your Personal Information for targeted advertising purposes by broadcasting an opt-out preference signal, such as the Global Privacy Control ("GPC"), on browsers or extensions that support the GPC signal. A list of GPC-enabled available browsers or extensions is available here: https://globalprivacycontrol.org/#download. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use. Your request to opt-out will be linked to your browser identifier only. For more information about how to opt-out of the sale or sharing of your Personal Information, see the "Do Not Share or Sell My Personal Information Notice" below.

10. Sales of Personal Information

In the preceding twelve (12) months, we have shared information for cross-contextual behavioral advertising or targeted advertising purposes which might be considered a "sale" of Personal Information as defined by the laws of some jurisdictions. SPG does not knowingly sell the Personal Information of minors.

11. Do Not Share or Sell My Personal Information Notice

Notice of Right to Opt-out of Sharing:

In an increasing number of jurisdictions, you can request that SPG not: (a) sell your Personal Information, (b) share it with third parties for cross-context behavioral advertising purposes, or (c) process it for targeted advertising purposes.

To exercise your rights to opt-out of SPG selling or sharing your Personal Information for cross-context behavioral advertising purposes and/or processing it for targeted or personalized advertising purposes, take the following steps:

1. You can opt-out of certain forms of online sale, sharing, or targeted advertising by turning off non-essential cookies and tracking tools. To do so, interact with SPG's cookie consent tool (upon your first visit or by clicking the cookie settings icon) and disable non-essential cookies. Alternatively, you can utilize the GPC Signal; SPG's websites respond to universal opt-out preference signals, including the GPC, to the extent required by law.
2. To opt out of other kinds of sale, sharing, or targeted advertising, such as "offline" uses of Personal Information to support marketing campaigns, you must also complete and submit an opt-out request via the SPG Consumer Privacy Request Portal.

Effect of Opting-Out:

Your cookie selections are specific to the device, website, and browser you're using, and your selections are deleted whenever you clear your browser's cache. If you use another device or browser, you will need to opt-out on each device and browser. Blocking or clearing cookies from your browser may remove your opt-out settings, requiring you to opt-out again. After you have opted-out, you may still see advertisements for SPG's products and services because not all advertisements are placed using cookies or Personal Information. For example, you may see contextual ads online such as those based on the topic and content of a webpage you visit; some advertisements published to third party websites are simply made visible to all visitors to that website.

12. Retention of Your Information

SPG retains certain records of your Personal Information as necessary to operate our business and comply with our legal and regulatory obligations. Such records are retained for legally defined retention periods that may extend beyond the period for which we provide the Services to you or to our Commercial Clients. We have implemented appropriate measures to confirm that Personal Information is securely disposed of when no longer required.

13. Other Important Website and Mobile Application Information

Our website contains links to third party sites. If you click on one of those links, you will be taken to websites we do not control. This Policy does not apply to the information practices of those sites. You should read the privacy policies of those other websites carefully. We are not responsible for those third-party sites. Links to third party sites do not constitute or imply endorsement by us of the linked site or any material displayed on those sites.

To the extent that SPG provides mobile application access for your use, please note that your Personal Information may be collected. In addition to being subject to this Policy, your use of a downloaded application provided by SPG may also be subject to the privacy terms and conditions of the providers and developers of the application. SPG may have access to and utilize certain data collected by such providers or developers. SPG may utilize such data to better service your account, to improve the performance of the application, as well as for the other purposes set forth in this Policy.

SPG websites are not intended for children under 13 years of age. No one under age 13 may provide any information through our websites, and we do not knowingly collect Personal Information from children under thirteen. If you are under thirteen, do not use or provide any information on this website or otherwise provide any information about yourself to us, including your name, address, telephone number, email address, or any screen or username you may use. If we learn we have collected or received Personal Information from a child under thirteen without verification of parental consent, we will use commercially reasonable efforts to delete that information. If you believe we might have any information from or about a child under thirteen without parental consent, please contact us at the mailing address shown beneath the heading "Your Privacy Rights and How to Exercise Them."

14. Information SPG Processes When Performing Services for Commercial Clients

When SPG provides services to its Commercial Clients, SPG may collect, from the client, information about the client's business operations and Personal Information about you and your relationship with that client. For example, SPG offers services to employers and retirement plans, among others. During the course of providing these services, SPG (i) is informed that you are the client's employee or plan's participant, and (ii) receives Personal Information about you including, your name, contact details, date of birth, gender, marital status, certain financial information (like premiums you paid), employment details, benefit coverage, and other types of data described in the "Definition And Exclusions of Personal Information" and "Information SPG Collects" sections above. SPG may also collect data from public information sources including social media and other websites, government agencies, third-party service providers, and business partners. When SPG processes this information, it does so as the Commercial Client's data processor and only handles the Personal Information to provide its services to the Commercial Client. Accordingly, if you submit to SPG a Data Subject Access Right ("DSAR") Request (e.g., if you seek to exercise your privacy rights to access, correct, or delete Personal Information about you) concerning information provided to SPG by a Commercial Client, SPG will notify you that you must submit your DSAR Request directly to the Commercial Client.

15. Information Security

We maintain technical and organizational security measures reasonably designed to protect the security of your Personal Information against loss, misuse, and unauthorized access, disclosure, or alteration. SPG International Limited and its affiliates take steps to secure your Personal Information with appropriate levels of security around storage and use. Despite this, the security of information cannot be guaranteed. If you have reason to believe that your Personal Information maintained by us is no longer secure, please immediately notify us utilizing the contact information set forth above. In the event of a breach impacting your Personal Information, we intend to provide you with notification to the extent required by applicable law.

SPECIALTY PROGRAM GROUP LLC -- CALIFORNIA PRIVACY NOTICE

Privacy Notice for California Residents

Including Applicants, Employees and Contractors

Version Date: November 25, 2025

This California Privacy Notice is subject to change and updates for regulatory compliance purposes. Please note that the latest version should be accessed at https://www.specialtyprogramgroup.com/privacy-policy/ for confirmation of the information herein which may have changed from the publication date of this document.

This Privacy Notice for California Residents (this "Notice") including Applicants, Employees and Contractors, supplements the information contained in the SPG Privacy Policy (the "Policy") and is provided on behalf of Specialty Program Group LLC ("SPG") and its subsidiaries, found here.

This Notice provides our "notice at collection" and provides certain mandated disclosures about our treatment of California residents' information, both online and offline. We adopt this Notice to comply with the California Consumer Privacy Act of 2018 as supplemented by the California Privacy Rights Act of 2020 (collectively "CCPA") and any terms defined in the CCPA have the same meaning when used in this Notice (unless separately defined in this Notice or Policy). This Notice applies solely to residents of the State of California as defined in the CCPA ("California Residents") who do business with us directly and/or visit the mobile apps and websites of SPG and its subsidiaries ("our websites"). Relevant sections of this Notice apply to employees (current or past), contractors, and applicants for positions.

1. Updates To This Notice and Accessibility

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the websites and update the Notice's effective date. We encourage you to look for updates and changes to this Notice when you access our websites. Your continued use of our websites and mobile applications following the posting of changes constitutes your acceptance of such changes with respect to your use of the websites and mobile applications.

Accessibility. If you have special needs with regard to accessing the content of this Notice, contact us at privacy.compliance@specialtyprogramgroup.com. Please include the words "Accessibility Issue" in your subject line and explain steps we can take to help you to review and understand this Notice.

Certain state-level privacy rights may not apply to Personal Information under SPG's custody or control that is subject to certain federal and state laws regulating insurance or health or financial information.

2. Definition and Exclusions of Personal Information and Sensitive Personal Information under the CCPA and at Specialty Program Group LLC

"Personal Information" means any information that identifies you or can reasonably be linked to you or your household and includes data such as your name, postal address, email address, and telephone number. Due to the nature of our business as described further in the Section called "Information SPG Collects" below, Personal Information handled by SPG about you may also include:

• your name, Social Security Number, driver's license, or other government-issued identification;
• assets and income, occupation, and employment status, dependent information, and other relevant financial information;
• information relating to any of your past claims, driving history, certifications, license details, previous insurance policy details, previous accident, and claims history including any driving convictions;
• information from reporting agencies and state and federal government agencies, such as state motor vehicle departments;
• information from other sources, such as medical or health care providers and other third parties with which you or we maintain a relationship including credit reference agencies, vetting and data validation agencies, advisory service providers, insurers, underwriters, reinsurers, business partners;
• your account activity and premium payment history;
• benefits information such as benefits elections, pension entitlement information, date of retirement and any relevant matters impacting your benefits;
• information about your interest in and attendance at SPG sponsored events, including feedback responses;
• information from social media interactions with SPG's social media presence, feedback forms, or surveys;
• credit card, bank account or other account information as may be required to facilitate your payment of insurance premium or similar amounts, which payment generally is made through systems maintained by third parties, such as insurance carriers;
• passive tracking information from our website or the Internet, including information obtained through the use of internet "cookies" as detailed in the "Cookie Choices" section below; and
• inferences drawn from other Personal Information, precise geolocation data, and sensory data such as audio or visual information.

Personal Information as defined under the CCPA does not include: (1) Publicly available information from government records as defined under Civil Code Section 1798.140; (2) Deidentified or aggregated consumer information; (3) Health or medical information to the extent covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and (4) Personal information to the extent covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver's Privacy Protection Act of 1994.

Certain types of Personal Information are considered "Sensitive Personal Information" under the CCPA. Sensitive Personal Information is a subset of Personal Information defined by the CCPA as information that reveals a consumer's:

• Social Security, driver's license, state identification card, or passport number;
• Account login, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
• Precise geolocation;
• Racial or ethnic origin, citizenship, or immigration status, religious or philosophical beliefs, or union membership;
• Mail, email, and text message content, unless the business is the intended recipient of the communication;
• Health, sex life, sexual orientation;
• Genetic or neural data; and/or
• Biometric information used to identify you or your household, including DNA information, retina scans, fingerprints, voice recordings, as well as certain physiological, biological, or behavioral characteristics.

3. Personal Information and Sources of Personal Information SPG Collects

SPG may collect Personal and/or Sensitive Personal Information from the following sources:

1. Directly from you (e.g. from insurance applications, when you visit a SPG site or attend a SPG event or webinar; through your use of our services or in connection with your communications with us);
2. From Third Parties (e.g. insurance carriers and other industry service providers, underwriters, reinsurers, credit reference agencies, medical professionals, government bodies, claimants, sponsors, joint ventures or business partners, vetting and data validation agencies and other professional advisory service partners, and other third parties with which you maintain a relationship, such as an employer, financial service or medical or health providers, or any industry provider from which we purchase or acquire industry assets or operations. This may occasionally include referral sources.);
3. Indirectly from you through electronic devices (e.g., computer, mobile device, vehicle telematics sensors, diagnostics and GPS technology) or when you visit us online or through emails or observing your actions on our websites, including through the use of "cookies" as described on our websites, as permitted, or described in those other third-party sites' own Privacy Policies, or as may otherwise be developed over time based on your interactions with us; and
4. From publicly available sources and government records.

Categories of Personal Information and/or Sensitive Personal Information listed below have been collected from California Residents within the last twelve (12) months:

A. Identifiers, including name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security Number, driver's license number, passport number, other government-issued identifiers, and device identifiers.

B. Personal information includes categories listed in the California Civil Code Section 1798.80 such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Note: Some data types included in this category overlap with other categories.

C. Protected classification characteristics under California or federal law, including age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, and pregnancy, childbirth, and other related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

D. Commercial information such as records of personal property (including vehicle information, VINs, and other consumer products related to the vehicle), products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. Biometric information such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information. Examples include fingerprints, faceprints, voiceprints, iris or retina scans, keystroke analyses, gait or other physical patterns, and sleep, health, or exercise data used to identify an individual.

F. Internet or other similar network activity including browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

G. Precise geolocation data such as physical location or movements within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet and intended to locate a consumer.

H. Sensory data including audio, electronic, visual, thermal, or similar information.

I. Professional or employment-related information such as current or past job history.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

K. Inferences drawn from other Personal Information. We draw inferences using the information we collect to create a profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, aptitudes, and other attributes.

L. Sensitive Personal Information. We collect sensitive information such as payment details, health information, government identification, racial or ethnic origin, and login credentials to our websites. We collect this information with your permission to administer accounts, operate websites, as part of our core business functions, such as processing an insurance application or other request for our products, services or offerings, events, promotions or in connection with strategic partner offerings or market research. We may not be able to process your request for our Services without the requested sensitive information.

M. Information Specific to Recruiting, Contractor and Employment Data of SPG. In the past twelve (12) months, we have collected, used, and retained, for recruitment, contractor administration, and/or employment purposes, the categories of Personal Information listed in the following table:

Category	Examples of Personal Information and Purpose
Additional personal details, contact details and identifiers.	Additional personal details for recruitment/employment purposes, such as national identification number, Social Security number, insurance information, your National Producer Number, marital/civil partnership status, domestic partners, dependents, emergency contact information, and military history; professional/personal calendar availability/scheduling information for meeting/communication purposes. We would use this information to communicate with you via email, mail or other methods about the company, compensation, job opportunities, and technology or services offered or other information relevant to your employment status or to carry out activities required in the normal course of an employment or recruiting relationship.
Education information and professional or employment-related information.	Information about your education and professional or employment-related information, such as your employment history, to help SPG determine whether you meet the requirements for the position or whether you have met licensing or continuing education requirements for the position.
Sensitive data for recruitment purposes.	We collect certain types of sensitive personal information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and information on criminal convictions and offenses. We collect this information for specific purposes, such as health/medical information in order to provide accommodations or benefits, consider eligibility under leave policies and other similar accommodations or benefits (subject to applicable limits); background checks and diversity-related information (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination. We may not be able to fulfill certain legal obligations or provide you with requested accommodations without certain Personal Information.
Documentation required under immigration laws for employees, job candidates, and contractors of SPG.	Data on citizenship, passport data, and details of residency or work permit (a physical copy and/or an electronic copy) as required under various laws.
Financial information for payroll/benefits purposes.	Your banking and other relevant financial details are needed for payroll/benefits purposes, for administering wages and other payments, and for providing, establishing, or communicating to you about benefits; this may include contact information and identifiers for members of your household, including minor children, for the purposes of administering benefits. When you provide us with information, including financial information of other individuals, you confirm that you are authorized to do so and we ask that you provide a copy of this policy to them. We may also use information in this category for compiling directories and establishing emergency contacts.
Talent management information.	Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance, and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver's license and car ownership information, and information used to populate biographies.
Requested recruitment information.	Information SPG requires from all applicants during the recruitment process, to the extent allowed by applicable law to make comparison and verify the accuracy of information submitted by applicants. This may include using employment application forms, collecting consent for background checks, and obtaining official copies of qualifications, certificates, or transcripts.
Recruitment information you submit.	Information that you submit in résumés / CVs, letters, writing samples, or other written materials (including photographs).
Information generated by us during recruitment.	Information generated by interviewers and recruiters related to you, based on their interactions with you or basic Internet searches, where allowed under applicable law to be used as part of the recruitment process.
Recruitment information received from third parties.	Information related to you provided by third-party placement firms, recruiters, or job-search websites, where applicable to streamline collection, compilation, and assessment of information to be used by the hiring team.
Audiovisual and electronic information processed during recruitment and employment.	This includes photographs, and images/audio/video footage captured (a) when visiting or calling our office, (b) during recruitment events or interviews, (c) during corporate activities and meetings, or (d) in connection with performance of your work while employed by SPG. This information is recorded, where permitted by law, to communicate with you, to record tasks performed for business operations, to prevent and detect fraud and unlawful activities, and to maintain corporate security.
Recommendations.	Recommendations provided on your behalf by others.
Employment history and background checks.	Information about your prior employment, education, and -- where applicable and allowed by applicable law -- credit history, criminal records, and other information revealed during background screenings. We use this information to conduct due diligence, verify identity, comply with anti-money laundering requirements, assess suitability for a particular role, and conduct other risk management checks.
Diversity-related information.	Information about race / ethnicity / religion / disability / gender and self-identified LGBT status, for purposes of government reporting where required by law, as well as to understand the diversity characteristics of our workforce, subject to legal limits.
Assessment information.	Personal Information and other data generated by your participation in psychological, technical, or behavioral assessments. You will receive more information about the nature of such assessments before your participation in any of them, including whether your participation is mandatory. Inferences drawn from the personal information collected may be used to create a profile about you.
Internet or electronic network activity information	Browsing history, search history, information regarding your interaction with our website, software application, online advertisement, links you use or web pages you visit while visiting our site or applications, browser type, internet service provider (ISP), cookies, and mobile device information including device identifier or other information. This information, some of which may be gathered through SPG's use of web session recording tools provided by a service provider under contract with SPG, is gathered for usage analytics and trends, website performance, troubleshooting, measuring compliance with information security or other corporate standards including compliance with IT Usage and Security Policies.
Various categories of the above employment or recruitment data	The prior categories of employment or recruitment data listed above may also be used as follows: To analyze, develop, and/or improve employee-related processes, tools, databases, information systems, and networks. To analyze, develop, and/or improve tools that utilize artificial intelligence, machine learning, or algorithms; To conduct surveys and research studies To forecast workforce trends, To monitor employee usage of online tools, To suggest training opportunities, To improve recruiting processes and identify potential opportunities based on employee skills or experiences, To update or correct our records, including combining information we have with information received from other sources, including publicly available databases. To conduct performance reviews, establish training requirements, To conduct investigations or pursue disciplinary actions or termination. To protect the safety and security of our business, services, websites, and mobile applications. To comply with legal requirements, To investigate and respond to conduct suspected of violating law or SPG policies and procedures, To comply with lawful requests from regulatory and law enforcement authorities, To defend our rights and property or the rights of third parties and to meet contractual obligations, To prevent suspected fraud, misuse of SPG information, and threats to our network or data, and For any other reason permitted by law.

1. Sources. We collect or create personal information for contractors, recruitment, and employment in different ways and from various sources:

1. Collected directly from you. We collect personal information from you directly as part of our prospective employment relationship or when you seek employment. This includes personal information provided in resumes and employment applications, information collected in connection with the onboarding process, information collected as part of your employment relationship including payroll information such as social security number, address, and bank information for direct deposits and information relating to subscribing to health and welfare benefits (e.g., short and long-term disability, medical and dental care) including beneficiary and emergency contacts information.
2. Collected via information technology: We collect information from you using cookies and similar technology when you use our websites, mobile apps, view our emails or otherwise engage with us through a computer or mobile device. We may monitor the use of our premises, equipment, devices, computers, network, applications, software, and similar assets and resources which may result in the collection of personal information about you. This monitoring may include the use of cameras in and around our premises or electronic monitoring technologies via our networks.
3. Information collected from third parties: We collect personal information about you from third parties such as consumer reporting agencies, job-related or professional websites, application providers, and data providers for recruiting, hiring and other employment-related purposes. We also collect personal information from third parties such as social networking sites or other application providers with whom you have interacted.
4. Information created about you: We collect or create information about you based on our interaction with you as a prospective or current employee such as interview notes, performance information, and wage and benefit information.

2. Retention of Applicant, Employee and Contractor Information. We retain personal information in accordance with applicable laws or regulatory requirements and also for as long as necessary to fulfill the purposes for which it was collected and to fulfill the business or commercial purposes explained in this Section M of the Privacy Notice for California Residents.

3. Disclosures of Applicant, Employee, Contractor, or Former Employee Information. We share personal information with other companies for various employment-related business purposes and work with companies that have a commitment to privacy. We may share your personal information among our affiliates for business purposes consistent with this Privacy Statement and may share your information with third parties when you consent to such sharing, direct such sharing, or such sharing is necessary to achieve an employment or recruitment objective. We may share information with others in an aggregated or de-identified form that does not reasonably identify you. We do not sell your personal information except for the sharing of applicant personal information for cross-context behavioral advertising as defined under California law as explained below. We may also share any of the categories of personal information listed above with these other parties for business purposes or as required or permitted by law:

• Service Providers who perform services on our behalf such as payroll support, tax and travel services, health and safety and professional services such as accounting, management consulting, and relocation services.
• Marketing and Advertising Providers who advertise our jobs and opportunities to potential applicants or permit marketing companies to collect the information from you on our job recruiting sites to personalize online marketing campaigns. See Use of Cookies and Other Web Tracking Technologies for more information.
• Benefits Providers who provide you with employee-related benefits such as financial investment service providers, health insurance providers, childcare providers in order to confirm your eligibility for these and other similar benefits.
• Third parties in connection with a business transaction, such as a corporate transaction, merger, sale or any or all of our company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by an affiliate or third party or in the event of a bankruptcy or similar proceeding. This may include sharing personal information with other companies to make operational changes to our workforce or subcontract out certain positions.
• Law enforcement, regulators or other parties to investigate fraud, protect the security of our network, websites, tools, facilities, or personal data, or to comply with the law and official requests of regulators or comply with a contract or to defend against potential, threatened, or actual litigation or to protect SPG, our employees, contractors, or the interests of another person.

4. Use Of Cookies and Other Web Tracking Technologies

This information is found at Part 4 of the SPG Privacy Policy.

5. Use And Disclosure of Personal Information

We generally use and only disclose your Personal Information to perform services on your behalf and provide you with the insurance products and services you expect from us. In addition, in order to operate our business and provide you with the services you request from us, information technology and other support service providers with which we maintain an arrangement may also have access to your Personal Information. Your Personal Information may be disclosed to third parties in connection with a merger, sale, or other transfer of organizational assets where Personal Information held by us about our clients is among the assets transferred. We may also use and disclosure your personal information in order to evaluate risks relating to insurance policies or to facilitate the prevention, detection and investigation of crime and the apprehension or prosecution of offenders as well as to enforce our agreements and recover any outstanding debts.

We may from time to time use and disclose your Personal Information for the following reasons:

• to fulfill or meet the reason you provided the information and for our everyday business purposes, such as to obtain initial and renewal quotations for insurance or other insurance or financial industry services (including those procured proactively and/or in connection with the movement of a book of business from one provider to another) on your behalf; to obtain insurance (or similar products) on your behalf or to facilitate the performance of related services by other industry service providers; to maintain or service your account or insurance, including by reporting claims of loss to other industry service providers, such as insurance carriers and adjusters; to evaluate our performance or offerings; to allow risk management or actuarial evaluation of prospective or existing placements; to confer with medical professionals if necessary regarding a relevant claim; and to make reports to credit bureaus. We may also save your information to facilitate new quotations or placements.
• for legal reasons, such as to make required or advisable reports to insurance regulatory, law enforcement or other similarly situated authorities including government authorities; to respond to and comply with court orders, applicable law, and other legal requirements; and to defend ourselves against claims and to enforce our rights or protect our employees or property.
• for our own marketing purposes so that we may offer you our products and services, including using targeted or similar advertising on the internet. You will be given the opportunity to opt-out of direct marketing from SPG, and you can change your marketing preferences by contacting SPG as set forth in this Policy.
• for joint marketing purposes so that we and any third-party product or service provider may together offer you products and services.
• for our affiliates' everyday business purposes, such as to process or service transactions or to provide or receive shared organizational services.
• for our affiliates' marketing purposes so that they may offer you their products and services using Personal Information, including eligibility information.
• for our and our affiliates' fraud prevention purposes where necessary to prevent and detect fraud.
• for non-affiliated third parties whenever you consent to such sharing, when the information cannot reasonably identify you, when business partners or third-party companies play a related or expected role in an insurance transaction, or as needed for SPG to participate in insurance support organizations. SPG may disclose to its referral partners with whom you already have a relationship certain Personal Information, including (i) campaign performance information such as the e-mail open rates, click rates, unsubscribe rates, and (ii) information about insurance coverage obtained because of the partner's referral to SPG. This information is disclosed to measure the impact of marketing and outreach campaigns and to calculate commissions.
• for our internal and external auditors, where necessary for company audits, complaint investigation, or investigation of a security threat.
• for other purposes as may be permitted by law.
• to evaluate, negotiate or effect a business transaction (e.g., a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets) in which Personal Information held by us about our consumers or website users is among the assets evaluated or transferred.

6. Use of Automation for Insurance Quoting

This information is found at Part 6 of the SPG Privacy Policy.

7. Your Privacy Rights and How to Exercise Them

Governments are increasingly granting consumers certain rights regarding their Personal Information. SPG honors requests in accordance with and to the extent required by applicable consumer privacy laws, which may vary depending on where you live.

The CCPA provides California Residents with specific rights regarding their Personal Information:

(A) Right to Know: You have the right to request that we provide you (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which we collected your Personal Information; (iii) the business or commercial purposes for which we collected, sold, or shared your Personal Information; (iv) the categories of Personal Information we disclosed to Service Providers or third parties for a business purpose and the categories of Service Providers and third parties to whom we disclosed it; and (v) the categories of third parties to whom we sold/shared your Personal Information and the categories of Personal Information sold/shared to each category of third party.

(B) Right to Access: You have the right to access and inspect Personal Information about you or be provided with a copy of the information we hold about you. SPG may take additional steps to verify your identity before it provides access to Personal Information that is sensitive, or the unauthorized disclosure of which could create a substantial risk of potential harm to the subject of the data.

(C) Right to Correct: If you believe that Personal Information about you is inaccurate, then you may request that SPG correct the information. When you make this request, please (i) identify the specific information that you believe is inaccurate, (ii) provide the information that should replace the inaccurate data, and (iii) provide documentation related to your proposed correction. We will correct the information if we determine, based on the totality of the circumstances, that the correction you requested is more likely than not accurate. SPG may decide to delete the allegedly inaccurate information instead of correcting it.

(D) Right to Deletion: You have the right to request that we delete Personal Information we collected about you. Under applicable consumer privacy laws, SPG is not required to honor a deletion request in certain situations, such as where SPG needs to maintain the information to: (i) complete a requested or reasonably anticipated transaction, (ii) prevent security incidents or fraud, (iii) comply with litigation holds and establish, exercise, or defend legal claims, and (iv) comply with SPG's regulatory and licensing obligations.

(E) Data Portability: You have the right under the laws of certain jurisdictions to request that Personal Information about you be provided in an electronic format to you or a third party of your choice.

(F) Disclosing the Recipients of Personal Information: Consumers in certain jurisdictions have the right to request that SPG disclose to them the categories of third parties to whom SPG has disclosed their Personal Information. In limited jurisdictions, SPG may be required to provide you with a list of specific third parties that have received Personal Information about you.

(G) Right to Restrict Processing/Right to Limit Use and Disclosure of Sensitive Personal Information: Some jurisdictions allow you to request that SPG limit the use of your Sensitive Personal Information to only certain specified purposes such as (i) providing to you the goods and services you reasonably expect, (ii) complying with legal obligations, exercising legal claims or rights, and defending legal claims, (iii) preventing security incidents or fraud, or (iv) verifying or maintaining the quality or safety of goods or services we provide. Other jurisdictions require SPG to obtain your consent to process Sensitive Personal Information about you; the definitions of Sensitive Personal Information vary by jurisdiction. SPG processes these types of requests subject to any exceptions permitted by law. If you reside in a jurisdiction that requires us to obtain your consent before processing Sensitive Personal Information on your behalf, SPG may take additional steps to contact you before treating your request as a revocation of consent to avoid unintended consequences, such as the cessation of processing your Personal Information for a SPG product or service that you requested. You may choose to withdraw your consent at any time; however, we may be unable to provide the product or service you requested without the necessary information.

(H) Right to Opt-Out from the Sale or Sharing of Personal Information/Do Not Sell or Share My Personal Information Request: You have the right to direct us to not sell or share your Personal Information for marketing and/or targeted advertising purposes with affiliates or non-affiliates. We will process requests subject to any applicable exceptions and extensions permitted by law.

(I) Right to Opt-Out of Automated Decision-Making and Profiling: Consumers in certain jurisdictions have the right to direct SPG to not process their Personal Information for automated decision-making or profiling that produces legal or other consequential effects. For instance, SPG and its insurance carrier partners may conduct assessments using models and information technology solutions: (i) to determine whether you are eligible to receive the insurance-related product or service you requested and (ii) to calculate your premiums. This process may involve information about your behaviors or making calculated predictions about you which are related to the product or service you requested. If you exercise this right prior to the application process, SPG may not be able to process your application for a product or service.

(J) Opt-Out of SPG Sharing Creditworthiness Information with SPG Affiliates: You may request that SPG not share with its affiliates information that bears on your eligibility for credit or insurance, including information about your credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living. This opt-out right does not extend to the sharing of (i) information about first-hand transactions or experiences between you and SPG, or (ii) opinions based solely upon those first-hand transactions or experiences.

(K) Opt-Out of Receiving Marketing Communications from SPG via Email: You have the right to unsubscribe from receiving communications of a marketing nature from SPG via email.

(L) Opt-Out of Receiving Automated Phone Calls and Text Messages from SPG: You have the right to request that SPG refrain from calling you or sending text messages to you using automated dialing systems.

(M) Right to Appeal: If we deny, in full or in part, your request to exercise a privacy right, and if you live in a jurisdiction that affords you the right, you may appeal SPG's decision. To initiate an appeal, send an email to privacy.compliance@specialtyprogramgroup.com that includes in the subject line the phrase "Privacy Appeal" and your state of residence; in the body of the email, please identify the decision you are appealing and the grounds of your appeal. If SPG denies your appeal, you may contact your state Attorney General to inquire about additional appeal rights.

(N) Right of Non-Discrimination: You have the right not to be discriminated against for exercising your privacy rights.

(O) Other California Privacy Rights: California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website who are California Residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.

To exercise any of these privacy rights, to make a related request, or to ask any question concerning this Privacy Policy, please contact us via any of the following methods:

Postal Address:
Chief Legal Officer
Specialty Program Group LLC
150 N Riverside Plaza, 17th Floor
Chicago, IL 60606

Or by:

• Visiting us at: the SPG Consumer Privacy Request Portal
• Emailing us at: privacy.compliance@specialtyprogramgroup.com
• Calling us at: 866-415-2207

Please include your name, address, telephone number, and email address whenever you contact us. Depending upon the nature of your request, SPG may require you to provide additional information to verify your identity and authority to access or direct the processing of the Personal Information that is the subject of the request. SPG may deny certain privacy requests with respect to your Personal Information if we cannot verify your identity. You may also use an authorized agent to submit a request to exercise your privacy rights on your behalf. If you have an authorized agent submit a request on your behalf, SPG will require (i) you to provide the authorized agent with written permission to act on your behalf, and (ii) your agent to verify their identity directly with SPG. SPG may deny a privacy-related request from an agent that does not meet these requirements.

Situations Where Rights Cannot Be Granted. There may be situations where we cannot grant a particular request --- for example, if you ask us to delete your transaction data but we are legally obligated to keep a record of that transaction to comply with law or if we are unable to verify your identity through standard and reasonable means. We may also decline to grant a request where doing so would undermine our legitimate use of data for anti-fraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied could be that granting the request would jeopardize the privacy of others; that the request is substantively frivolous or vexatious; or that granting the request would be highly impractical in the context of our legitimate business purposes. If we are unable to fulfill your privacy request to access, review, delete or correct your Personal Information, we will provide you with an explanation.

Responses. We will acknowledge and comply, to the extent possible, with your request within applicable timeframes as proscribed by law. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you with a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

8. Cookie Choices

This information is found at Part 8 of the SPG Privacy Policy.

9. Global Privacy Control (GPC) Signal

This information is found at Part 9 of the SPG Privacy Policy.

10. Sales Of Personal Information

In the preceding twelve (12) months, we have shared information for cross-contextual behavioral advertising or targeted advertising purposes which might be considered a "sale" of Personal Information as defined by the laws of some jurisdictions. SPG does not knowingly sell the Personal Information of minors.

11. Do Not Share or Sell My Personal Information Notice

Notice of Right to Opt-out of Sharing: In an increasing number of jurisdictions, you can request that SPG not: (a) sell your Personal Information, (b) share it with third parties for cross-context behavioral advertising purposes, or (c) process it for targeted advertising purposes.

To exercise your rights to opt-out of SPG selling or sharing your Personal Information for cross-context behavioral advertising purposes and/or processing it for targeted or personalized advertising purposes, take the following steps:

1. You can opt-out of certain forms of online sale, sharing, or targeted advertising by turning off non-essential cookies and tracking tools. To do so, interact with SPG's cookie consent tool (upon your first visit or by clicking the cookie settings icon) and disable non-essential cookies. Alternatively, you can utilize the GPC Signal; SPG's websites respond to universal opt-out preference signals, including the GPC, to the extent required by law.
2. To opt out of other kinds of sale, sharing, or targeted advertising, such as "offline" uses of Personal Information to support marketing campaigns, you must also complete and submit an opt-out request via the SPG Privacy Request Portal

Effect of Opting-Out: Your cookie selections are specific to the device, website, and browser you are using, and your selections are deleted whenever you clear your browser's cache. If you use another device or browser, you will need to opt-out on each device and browser. Blocking or clearing cookies from your browser may remove your opt-out settings, requiring you to opt-out again. After you have opted-out, you may still see advertisements for SPG's products and services because not all advertisements are placed using cookies or Personal Information. For example, you may see contextual ads online such as those based on the topic and content of a webpage you visit; some advertisements published to third party websites are simply made visible to all visitors to that website.

12. Retention Of Your Information

This information is found at Part 12 of the SPG Privacy Policy.

13. Other Important Website and Mobile Application Information

This information is found at Part 13 of the SPG Privacy Policy.

14. Information SPG Processes When Performing Services for Commercial Clients

This information is found at Part 14 of the SPG Privacy Policy.

15. Information Security

This information is found at Part 15 of the SPG Privacy Policy.