Data Collection and Use Definitions and Terms for Commercial PFA (or NOAA)
For purposes of this Commercial Finance Agreement, accepted after May 6, 2016,
“Commercial Customer” shall mean a person or entity who seeks or obtains financing products and
services for business or commercial purposes, as in connection with financing of premiums for
property & casualty and other commercial lines, including but not limited to professional liability,
general liability, workers compensation, excess and umbrella lines, and directors & officers insurance.
“Company Information” means any information about a Commercial Customer from which the Commercial Customer
could be identified, whether obtained directly from the Commercial Customer or from another source.
Company Information may include, but is not limited to: (a) company name; (b) physical address, including
street name and name of city or town; (c) e-mail address or other electronic contact information;
(d) telephone number(s); (e) tax identification number; (f) credit history; (g) bank or credit card account
number; (h) financial statements; (i) information about officers, directors, and other control persons;
and (j) any other information from or about a Commercial Customer. However, the following is not considered
Company Information: (a) aggregated or anonymous information that does not identify a customer and
(b) information that IPFS obtains from a public source (or knows to be available from a public source).
Aggregated and Other Data Collection and Use. IPFS owns the aggregated and statistical data derived from the
operation of its business, including the collection and use of Company Information or transactional or
other experience data associated with Commercial Customers. Nothing herein or in the finance agreement
shall be construed as prohibiting IPFS from utilizing its Commercial Customer data, including aggregated data,
for purposes of operating its business. IPFS may use Company Information for research, analysis, promotional
or commercial purposes. IPFS reserves the right to aggregate such information with other data,
to create predictive analysis, to analyze, aggregate, and report summaries or in the aggregate on trends,
and to make such reports, summaries or analyses available to third parties. IPFS may share Company Information
with non-affiliated third parties in order to offer Commercial Customers additional products and services.
IPFS may also disclose Company Information to non-affiliated third parties for routine business reasons,
such as service providers and other third parties as necessary to facilitate a transaction requested by a
Commercial Customer, or to exchange information with commercial credit bureaus such as Dun & Bradstreet.
IPFS may also disclose Company Information to non-affiliated third parties in response to legal process,
or as otherwise required or advisable considering applicable law or regulation, or to banking, securities,
or other regulators without any prior notification or any other restriction. Finally, if our company or
our assets are acquired by another company, or in the event of a merger, consolidation, change in control,
transfer of substantial assets, reorganization, or liquidation, we may transfer, sell,
or assign to third parties, information concerning our customers including, without limitation,
personal information that you provide and other information concerning your relationship with us.
Such third parties will assume responsibility for the personal information collected by us and will assume