PRIVACY POLICY NOTICE
Revised 03/01/2008

Introduction
CU People, Inc. respects your privacy. We make use of any personal information that you provide to us for the purpose of serving you better. We have created this privacy policy (“Privacy Policy”) to demonstrate our firm commitment to the security and integrity of your personal information. This “Privacy Policy Notice” discloses the information gathering and dissemination practices of CU People, Inc. --which are available primarily to us, our clients, and our employees. This Privacy Policy applies to all information that you provide to CU People, Inc. and that CU People, Inc. maintains electronically, whether you provide the information through cupeople.com, or through other means. Additionally, this Privacy Policy applies to any personal information obtained from your use (and, if applicable, your family’s use) of CU People, Inc.’s websites, or through day-to-day operations in servicing our business partners/clients. This Privacy Policy does not apply to any information that you may provide to third parties; for example, other sites linked to CU People, Inc.'s websites.
As used herein, the terms “CU People, Inc.,” “we,” “our” and “its” when referring to CU People, Inc., and its related companies are used only for convenience and are not intended to be an accurate description of ownership, operation or corporate/legal relationships.

What information does CU People, Inc. collect? 
If you are an employee or client of CU People, Inc., we collect and maintain a variety of personal information about you and, if applicable, your company and employees, and family members. This information may be collected through our website, our online systems, or through paper forms submitted by you. For employees, the information we maintain includes, among other things:

• your name, your phone number and address (street and e-mail)
• age, marital status and occupation
• information about your job history and employment status
• information about your salary and benefits, including health benefits, your time off, your retirement plans, your social security or taxpayer identification number
• your recruiting and training history
• information about your family members such as their names, addresses and social security numbers

We may make some or all of this information available for you or your worksite employer's use on CUPI’s website and/or additional online systems. For clients, examples of this information include:

• your location
• your number of worksite employees
• the gross payroll of worksite employees assigned to your location
• your SIC codes
• information about insurance and other benefit plans

Depending on the use that you make of CU People, Inc.’s website, we may also collect your Internet Protocol (IP) Address (which is the unique address of your computer), information about your interests and preferences, and, if you decide to send us your resume, information included in your resume. From time to time, we may conduct surveys or offer contests or other promotional events, and gather additional personal information from you in connection with those events. CU People, Inc. may store and analyze log files from user sessions.

What is this information used for?
We use your personal information in the course of your employment or client relationship with CU People, Inc.. Among other things, we use this information to provide you with the services available through our insurance broker relationship. We also use your information for other things which may include, but are not limited to, the following:

• Contacting You.
  CU People, Inc. uses your personally identifiable information to communicate with you in the course of your employment or client relationship. We may also contact you to tell you about products and services provided by CU People, Inc.'s strategic alliances and other third-party organizations. While we must be able to contact you for matters relating to your employment or your client relationship, if you do not wish to receive email communications from CU People, Inc. regarding strategic alliance offers or other third-party products and services, you may opt out of receiving such communications by following the procedure set forth in such e-mail. CU People, Inc. will continue to contact you for matters relating to your employment or your client relationship.
• Other General Information.
  CU People, Inc. may also collect the name of the domain from which you access the Internet (e.g., aol.com); the date and time you access CU People, Inc.'s website; and the Internet address of any website from which you link directly to CU People, Inc.'s website; as well as collecting and storing other information in a user’s log file. A user’s log file tells CU People, Inc. where a user comes from when entering an CU People, Inc. website; which part of the CU People, Inc. website the user visits as well as where the user goes when leaving the CU People, Inc. website; and how much time the user spends in the CU People, Inc.’s website. In addition, CU People, Inc. may collect e-mail addresses and other personal information from persons who are not current employees or clients of CU People, Inc..
• Rewarding Use of CU People, Inc. website.
  CU People, Inc. may use information it collects in order to reward or provide incentives to employees, client companies or other CU People, Inc. website users for visiting CU People, Inc. websites; using services provided on the CU People, Inc. websites; or for visiting the websites of CU People, Inc.’s strategic alliances.

With whom is this information shared?
CU People, Inc. shares personal information only as described below:

• Other CU People, Inc. Companies and Third-Party Contractors
  We may share your information among related companies of CU People, Inc., even if the related company is not a party to your client service or employment agreement. In addition, we may from time to time transfer our database of employee information to third-party contractors who analyze such information on behalf of CU People, Inc. for the purpose of, among other things, targeting e-mails to employees regarding strategic alliance offers, or who mail marketing materials to employees regarding strategic alliance offers. Additionally, we may from time to time transfer our database of employee information to a third-party contractor who provides employment verification services on behalf of CU People, Inc.. Such third-party contractors are contractually bound to hold all such information in confidence and do not share such information with any parties other than CU People, Inc.. 
• Your Worksite Employer
  If you are an employee, most of your personal information is also available to your individual worksite employer. However, CU People, Inc. does not provide information regarding your physical and/or mental health to any third party for any purposes, unless compelled by a governmental or legal authority.
• Governmental Authorities, Compliance with Law and Protection of CU People, Inc. and Others
  We provide information to governmental authorities when required to do so by law (for example, we report information regarding your compensation and withholding to the U.S. Internal Revenue Service and state taxing authorities). CU People, Inc. will also provide personally identifiable information to third parties if compelled to do so by an appropriately empowered governmental or legal authority, or, as necessary, to protect CU People, Inc.'s rights or the rights of third parties. 
• Benefit Plan Providers
  CU People, Inc. will also provide personally identifiable information to its third-party benefit providers in conjunction with the administration of its benefit plans.
• Medical Emergencies
  If necessary to respond to an apparent medical emergency, CU People, Inc. may disclose selected employee information.
• Strategic Alliances.
  CU People, Inc. has entered into marketing agreements, strategic alliances and other relationships with third-party organizations that may offer or provide products and services to you, sometimes under discounted or preferential terms. We sometimes agree to give these third parties (including potential parties to strategic alliances) aggregated, non-personally identifiable information about our clients, employees or visitors.  If you do not wish to have any of your personal information furnished to such third-parties you may opt out by following the procedure set forth in such e-mail notifications.

What access do you have to information you provide?
You have access to much of your personal information through your worksite employer and CU People, Inc.’s online systems, where you can view and update some of the personal information we maintain. 

Security measures
CU People, Inc. makes access to your personally identifiable information subject to certain security measures, including technological controls such as "firewalls", in accordance with industry standards. When the use of CU People, Inc. website involves the transmission of confidential information about you or CU People, Inc., we use technology that establishes a secure connection between your PC and our server. These security measures allow for the transmission of encrypted information from your PC to our server and back again and is the industry standard for Internet platform security. No data transmission over the Internet can be guaranteed to be 100% secure, so while CU People, Inc. strives to protect your personal information, we cannot ensure or warrant the security of any information that you transmit to CU People, Inc..

Disclaimer of responsibility for privacy policy and content at linked sites
CU People, Inc.’s website may provide you with links to other websites. We are not responsible for those sites and cannot control the use of information that you submit once you reach those sites, nor can we control the content of what is offered on those sites or on links from those sites. You should contact such third-party websites directly to determine their privacy policies.

Use of information from third parties
We may use information about you provided to us by third parties (such as credit reporting agencies or strategic alliances) in order to offer you their services and products, to improve our own services, or to evaluate your eligibility for our services. 

This is not a children’s website
CU People, Inc. does not knowingly solicit data from children, and we do not knowingly market to children.

Applicable only to U.S. residents
CU People, Inc.'s website is designed for and intended only for the use of client companies located in the United States and employees who are U.S. citizens or are residents of the United States.  If you are a client company that is located outside of the United States, you are not authorized to access CU People, Inc.'s website. 

CU People, Inc. employees and privacy
CU People, Inc. trains all CU People, Inc. employees about the importance of privacy. It is CU People, Inc.'s policy to give access to your information only to those employees who require it to carry out the responsibilities of their jobs.

Changes in these policies and practices
CU People, Inc. reserves the right to change its privacy policies and practices periodically, without providing individual notice, by updating this Privacy Policy notice.   You agree that it is your responsibility to monitor such updates and that your continued use of CU People, Inc.'s website after such revisions have been made constitutes your full acceptance of such revised terms and conditions.

For more information
If you have questions regarding CU People, Inc.’s Privacy Policy:

Please write to:                   
CU People, Inc.
Privacy Policy Inquiry
14019 Southwest Freeway, Suite 340
Sugar Land, Texas 77478

Or call:                                 
281.242.0835 / 800.236.8309

Or fax questions to:   
281.491.5354

As a PEO, CU People, Inc. is licensed and regulated by the Texas Department of Licensing and Regulations.