Personal information that is provided to Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. is used to determine eligibility under various benefit plans, to adjudicate and process claims and to meet regulatory or contractual requirements. Personal information also includes records and data relating to the claims experience and history of benefit plan members.

Most personal information is supplied to us by our client, the benefit plan sponsor, or by the benefit plan member directly. If additional personal information is required from any other source, we shall not request such information without notifying the benefit plan member.

Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. records telephone calls for quality assurance, training and conflict resolutions purposes. Recorded telephone calls will involve the collection of an individual’s personal information, and Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. will use, disclose, protect and retain such personal information in accordance with this privacy policy.

The privacy and protection of personal information is extremely important to us. This information can take a number of forms, including paper or electronic records. In view of the nature, types, and forms of the personal information we receive, Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. has developed a series of security procedures to safeguard and protect personal information in our possession against, theft, unauthorized disclosure, and unauthorized use or modification. We will continue to maintain these safeguards and to upgrade our security procedures for personal information as required.

Each of Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. employees, agents, and subcontractors must abide by these Privacy Guidelines in handling of personal information of our clients and plan members. Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. employees, agents, and subcontractors will use personal information only in accordance with this Policy, our contractual rights and obligations, and the law.

Personal information will be accessible by or provided to those external third parties that have been granted access by the plan member, except as required by insurers or claims processors, medical or healthcare providers, or as required by statutory authority, legal process, contractual obligations or widely accepted and ethical business practice.

Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. will process paper health benefit claims that are submitted by benefit plan members on approved, properly completed claim forms. These claim forms are available on our benefits website.

Upon request, Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. shall make available to an eligible benefit plan participant the personal information maintained in our files relative to this individual, subject to any applicable legal or ethical prohibition or privilege. Personal medical information will only be made available through an appropriate healthcare professional.

Any individual has the opportunity to request that we correct or clarify personal information that we have retained for that individual. Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. shall correct or amend the individual’s information to the extent that the original information was incorrect.

By using the Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. website, products and services (collectively, the “Services”) and providing Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. with your personal information, you agree that Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. may collect your personal information, and you voluntarily consent to the collection, use, disclosure and transfer of your Personal Information in accordance with this privacy policy. If you do not agree with any terms of this privacy policy, please do not use the Services or provide Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. with any personal information. If you do not understand the nature, purpose and consequences of collecting, using and disclosing personal information to Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd., please do not use the Services or provide Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. with any personal information, and you may contact Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. at the contact information set forth below to address your questions and concerns.

A privacy-related inquiry may be made by contacting Williams Leal & Vito Inc. and/or Target Benefit Administrators Ltd. We will investigate all inquiries and complaints. If a complaint is justified, we will take appropriate steps to correct the situation, including changing our policies and procedures if necessary.