This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients’, customers’, members’ personal information.  Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’, customers’, members’ personal information and allowing our clients, customers, members to request access to, and correction of, their personal information.

Unless the purposes for collecting personal information are obvious and the client, customer, member voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

Consent can be provided or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client, customer, member voluntarily provides personal information for that purpose.