Privacy and Security
Integrated Corporate Health's Online Privacy Policy

At Integrated Corporate Health ("ICH") we take the issue of privacy very
seriously. We want to assure Users of our Web sites (meaning any individual,
including site visitors as well as those individuals who provide personal
information via this Web site, herein referred to as "User(s)") that their
information is secure and maintained in confidence, consistent with applicable
state and federal laws. Please read through the following pages, which describe
our online privacy policy.

I. Information Collected Online
A. General

How you use the ICH Web site will determine whether or not we need to collect
information from you and how much information we collect. For some features,
we do not require any information on who you are or ask questions about you.
For some of our features, we need to either verify your identity through a
login process, or collect sufficient information from you to provide the
service of that feature.

B. Email, Product Inquiry 

ICH invites Users to send secure messages to ICH regarding Web site accounts
or ICH's products or services. ICH retains copies of these secure messages for
1,000 days, but does not disclose secure messages to any non-affiliated third

The information provided through the use of these secure messages and feedback
forms will be used by ICH representatives or other appropriate third parties
who need to view this information to respond to the inquiry.

ICH also invites Users to send emails and access products and services from
non-related service providers through links on the ICH pages.  Users should
also review the privacy polices contained on these Web sites for information
regarding how the service providers use the information.  ICH is not
responsible for any misuse by a linked site of information submitted by a User
on such site.

C. Use of Cookies

A cookie is a small piece of information about an Internet session that may
be created when an individual accesses a Web site.

Cookies can contain a variety of information, including the name of the Web
site that issued them, where on the site the User visited, passwords, and even
Users' names that have been supplied via forms.  Note that most Web browsers
can be modified by the User to prevent cookies from being attached to the User. 

Our Web site and certain sites it provides links to use cookies to facilitate
easier navigation within the sites, to provide a higher level of convenience
for Users, and for internal reporting and statistical purposes.  The use of
cookies by the linked site is subject to the privacy policies of the owner or
operator of such site.  ICH is not responsible for the misuse of cookies by a
linked site.

II. Use of Information Collected Online

ICH does not sell your non-public personal information to anyone.

All information submitted by any individual to ICH may be retained to provide
a record of such communications and to comply with any applicable legal and/or
regulatory requirements and may be verified for accuracy. In addition:

ICH uses any information submitted by you on the ICH sites as well as
information submitted by you on sites of non-related service providers that
are linked to ICH to provide improved customer service, to provide relevant
health care related information, to update information we have about you
and/or your group, and to monitor the effectiveness of our online services.
In some cases, ICH may use such information to provide you with access to
information on products and services offered by ICH or our affiliates. 

ICH uses the name and email information you supply to send you emails and
special notices.  The emails and special notices may be sent by and through a
third party vendor contracted by ICH to provide such services to you. You may
remove yourself from these mailings at any time by emailing
Your e-mail address information will be used only for ICH-related mailings and
will not be given, sold or rented to any other party for any other use without
your prior approval.

Information may also be "cleansed" by ICH (stripped of any information which
could identify you personally, such as your name or e-mail address), aggregated
with other data, and used for general research, classification purposes,
marketing, or other purposes without permission, but only in non-individually
identifiable forms.

III. Access to Information Collected Online
A. Employees

Certain ICH employees may be provided with information regarding Users in
order to respond to the individual's needs and provide requested information
regarding specific products or services. Certain employees will also be
provided with information regarding Users in order to administer the Users'
individual or group benefit programs and to monitor the effectiveness of the
online services provided by ICH. ICH employees are required, by written
confidentiality statements, corporate policies, and state or federal laws or
regulations to maintain the confidentiality of personal information and to use
strict standards of care in handling the information. Employees who do not
conform to these confidentiality requirements are subject to disciplinary
sanctions that may include dismissal.

B. ICH Affiliates, Business Associates and Service Providers

ICH may disclose personal information of its Users collected through its Web
sites as permitted by law to affiliates or non-related service providers that
assist ICH in meeting the needs of its customers. Information collected by
affiliates and non-related service providers may also be shared with ICH as
permitted by law.  All such information will be disclosed only to respond to
the User's needs and to provide information about products or services offered
by or through ICH, ICH's affiliates and the non-related service providers.
Personal information is treated with the same standards of confidentiality that
ICH applies to other confidential information. 

C. Third Parties

Other than as set forth above, ICH does not transmit any personal information
collected from a User through its Web sites to any third party without the
permission of the User. Personal information may be transmitted, however, if
the transmittal of such information is necessary in order to complete a
transaction requested by the User. 

IV. Compliance Assurance
A. Security

ICH uses commercially reasonable computer security technology selected and
implemented to provide adherence to the security and privacy policies described
in this online posting. Although we make reasonable efforts to protect your
information from unauthorized use or alteration, you should be aware there is
always some risk in sending information over the Internet.

B. Account Access
Consistent with the requirements set forth under certain state and federal
laws, ICH grants access to personal information only to those employees,
affiliates and third parties as required to provide healthcare products and
services, or as you permit. All such employees, affiliates and third parties
are subject to privacy policies, at least as restrictive as the policy
described in this online document.

C. Questions and Concerns

If you have questions about this online privacy policy, or concerns regarding
your personal information, please send us your question by clicking Contact Us
from the bottom of any of our Web pages.

(Copyright Notice 2010 Integrated Corporate Health)