Privacy Policy Statement

OUR POLICY REGARDING YOUR PRIVACY

In order to provide tuition refund plans that respond to our customers’ diverse needs, A.W.G. Dewar, Inc. (“DEWAR”) collects certain personal information.  DEWAR does not disclose any nonpublic personal information to any affiliated or nonaffiliated third party for marketing purposes.  At DEWAR, maintaining the confidentiality of our customers’ personal information is of the highest importance.  DEWAR’s personal information-handling practices are governed by this privacy policy and are further regulated by law.  This notice describes those practices and how they preserve your privacy in a way that permits DEWAR to provide you with the products and service you demand.

Collection of Personal Information

We get most of our information directly from you.  The application you complete, as well as any additional information you provide, generally gives us most of the information we need to know.  Sometimes we may contact you to obtain additional information.  Your information is used to send your tuition refund plan to you, to contact you when necessary for the transaction, and for billing purposes.  Information collected from you may include your name, address, telephone number, email address, school information, student ID number, social security number, credit card number and expiration date.

Disclosure of Personal Information

Information about you which has been collected will be contained in our records.  We review it in evaluating your request for a tuition refund plan.  We will also use information in our records for purposes related to issuing and servicing plans and settling claims. DEWAR may disclose personal information to others in order to service, process or administer business such as claims operations.  In this context, DEWAR may disclose (i) information we receive from you on applications and other forms, including information such as assets, income, and identifying information such as name, address and social security number; and (ii) transaction information such as information about balances, payment history and parties to the transaction.

Parties to Whom Information May be Disclosed

DEWAR will not disclose information about you to others without your written consent unless the disclosure is necessary to conduct our business. By law, DEWAR is permitted to share information about you without prior permission to the following parties: · Your agent or broker · Those who perform business, professional or insurance roles for us · Those who need to research defend or settle claims involving you · Insurance support organizations that collect data to help fight and prevent insurance fraud · Agencies that help regulate our business · Government agencies that protect us in cases of fraud or illegal activity · Persons ordered by subpoena, warrant or other court order · Parties representing you in some way (lawyers, accountants, auditors) · Insurance rate advisory organizations · Those backing our rights in regards to debt settlement, audit or interest transfer · Parties who handle transactions you request or sign off on.

Right of Access to Personal Information

You have the right to know what kind of information we keep in our files about you, to have reasonable access to it and to receive a copy.  Write to us if you have questions about the information.  Provide your complete name, address, type of tuition refund plan, and certificate number that was issued or applied for with us.  Email your request to trp@dewarinsurance.com, or mail your request to A. W. G. Dewar, Inc. 4 Batterymarch Park, Quincy, MA 02169.  You may also call 617-774-1555.  Certain types of information generally collected when evaluating claims or possible lawsuits need not be disclosed to you.

Within thirty (30) business days of receipt of your request, we will inform you in writing of the nature and substance of retrievable recorded personal information about you in our files.  You may review this information in person or receive a copy by mail.

After you have reviewed the personal information about you in our file, you can write to us if you believe it should be corrected, amended or deleted.  We will consider your request, and within thirty (30) days either change the information or tell you that we did not and state the reason.  If we do not make changes, you will have the right to insert in our file a concise statement containing what you believe to be the correct, relevant or fair information, and explaining which information on file you believe to be improper.  We will notify persons designated by you to whom we have previously disclosed the information of the change or your statement.  Subsequent disclosures we make also will include your statement.

Confidentiality and Security of Personal Information

Our company maintains appropriate standards and procedures to prevent unauthorized access to your information.  DEWAR limits employee access to personally identifiable information to those with a business reason for knowing such information.  We educate our employees so that they will understand the importance of confidentiality of personal information and take appropriate measures to enforce privacy responsibilities.

Treatment of Personal Information of Former Customers

DEWAR follows this personal information privacy policy even when a customer relationship no longer exists.

DEWAR may modify this Policy from time to time. The current policy is always available at www.tuitionrefundplan.com. If significant changes are made to the Policy, DEWAR will notify its policyholders.

Effective: February 2011