Privacy Policy Notice

Paronubi, Ltd. recognizes the importance of privacy and confidentiality. This policy applies to all of our employees, as well as our contractors, vendors and other individuals or business associates (‘Interested Parties’) with whom we do business and where such business may require access to personal or confidential information

The protection of the confidential nature of every client’s personally identifiable information is of paramount importance to us; the oversight and enforcement of that protection is an integral component of our operations, and informs our procedures and job descriptions. To protect that information, and in compliancewith federal and state privacy laws, we have developed this Privacy Policy to make our clients and Interested Parties aware that Paronubi, Ltd. maintains confidential, personal information about its’ clients and their employees.

Personal Information includes any information about an individual that, when taken individually or together make them and their information identifiable beyond what is publicly available, such as name, address, age,gender, social security, identification numbers, income, ethnicity, religion, health records, etc.

Should access to private information be required by anyone other than Interested Parties, please contact the Principal Privacy Officer (‘PPO’) in writing at:

Paronubi, Ltd.

Attn: Principal Privacy Officer

2500-88 Queens Quay W., Toronto ON   M5J 0B8 – Canada

Please include all information necessary to determine if access should be granted. Except where prohibited by law, if access is granted you will be required to comply with this Privacy Policy and submit an attestation of having received, read and understand this policy. No access will be given without an executed attestationby an authorized individual regardless of need, except where such access is commanded by law.

This policy applies to all of the services offered by Paronubi, Ltd., as well as those offered by our subsidiaries or affiliated companies, if any, and their Interested Parties.

As a condition of employment or other relationship with Paronubi, Ltd., anyone with information about a violation of this policy, or who believes that a violation of this policy may have occurred or may occur must contact the PPO immediately.

Personal Information Collection in the Performance of Services

Paronubi, Ltd. may collect Personal and Private Information (‘PI’) for the purposes of providing risk management and insurance services to our clients. The services provided may include communicating withclients and participants in the insurance markets, analyzing client risks, preparing policies for individuals and businesses, preparing submissions to the insurance markets, processing transactions, assisting in claims, adjustments and legal matters, etc.

We will only use PI in a reasonable manner, consistent with providing these services.

Paronubi, Ltd. discloses this information only to employees and Interested Parties for the sole purpose ofperforming risk management and insurance services on behalf of our clients, and as permitted or required by applicable law.


Information Security

 Except as permitted by law, Paronubi, Ltd. does not disclose any NPI, PII or PHI without written consent, specific to the disclosure, by the insured. All PI collected, used and retained by Paronubi, Ltd. is secured by three layers of protection:

All Interested Parties are subject to these, as applicable for the performance of their responsibilities.

Effective as of April 12, 2022

rev. 1.01