UFCW Local 655 Welfare Fund WEB SITE PRIVACY POLICY

Effective Date: August 01, 2009

UFCW Local 655 Welfare Fund is committed to protecting the privacy of the personal information you provide on this Web site in accordance with federal and state law requirements and our internal policies. The following provisions set forth our privacy objectives for this Web site.

Registering for Member Services

In order to access certain areas of this Web site, we require plan participants and eligible dependents to register for a unique account. We collect personal information about you when registering for an account in order to verify your identity and attempt to prevent unauthorized access to your account. We cannot make certain features of this Web site available to you without registration. However, instead of using these features, you are welcome to contact us by mail or by telephone at the address and phone number identified below.

How We Use and Disclose Your Medical Information

We use and disclose medical information about you in accordance with applicable law, including the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"). Please review our Notice of Privacy Practices for protected health information carefully for more information Privacy Practices. In the event any of the provisions of that notice conflict with the provisions set forth below, the HIPAA notice will control.

How We Collect Personal Information

UFCW Local 655 Welfare Fund may collect and store any information that you provide on or through this Web site, including any personal information that you provide through a Web page form or through an email generated using this Web site. This may include your name, address, phone number, email address, plan and benefits information, health information, and any other information that you voluntarily provide to us.

How We Collect Non-Personal Information

UFCW Local 655 Welfare Fund may collect and store certain types of non-personal information when you visit our Web site. This may include the name of the domain and host from which you access the Internet; the IP address of the computer you are using; the type of browser and operating system you are using; and the date and time you access the Web site. In many cases, this information may be collected automatically when you choose to visit our Web site.

How We Use Information About You

In addition to the uses of information described in our Notice of Privacy Practices for medical information, UFCW Local 655 Welfare Fund may use the information that you provide on or through the Web site in order to:

• Verify your identity and prevent unauthorized access to the Web site
• Communicate with you about your benefits plan and our other products and services
• Respond to your requests for produces, services, information, or assistance
• Improve the quality and variety of products and services we make available to you
• Perform quality control, for instance, by comparing the information on the Web site against other information we have about you as a result of your relationship with us
• Administer and maintain this Web site
• Measure the number of visitors to this Web site and how the Site is used, in order to make the Web site as useful as possible to our visitors

Sharing Information About You

In general, UFCW Local 655 Welfare Fund will disclose information about you collected on this Web site only as necessary for the uses identified above (see "How We Use Information About You"). In addition to the disclosures described in our Notice of Privacy Practices for medical information, we may disclose information about you to our affiliated entities, our business associates, and our service providers. Please note that we obligate our business associates and service providers to maintain the confidentiality of any personal information shared with them, and seek to limit any use of personal information solely to providing services to UFCW Local 655 Welfare Fund.

Disclosures Required by Law

UFCW Local 655 Welfare Fund may be required by applicable law to disclose information about you to government authorities or third parties under certain circumstances. We reserve the right to respond to any valid subpoena or other legal process received from law enforcement authorities or any government agency without prior notice to you.

Additionally, if UFCW Local 655 Welfare Fund needs to investigate or resolve possible problems or inquiries, UFCW Local 655 Welfare Fund may disclose certain information about you to private entities, law enforcement or other government officials as UFCW Local 655 Welfare Fund, in its sole discretion, believes necessary or appropriate.

Sale of Personal Information

UFCW Local 655 Welfare Fund will not sell or rent any personal information about you collected on this Web site to any third party for marketing or solicitation purposes. However, we may sell your personal information to a successor in interest in the event of a merger, acquisition, corporate reorganization, or sale of our business or assets.

Use of Cookies

We may use "cookies" to automatically collect and store information about you. A cookie is a small text file that the system sends to your computer to collect information about your activities on the Web site. The cookie transmits this information back to the Web site each time your browser requests a page from the Site, and the information may be stored to help facilitate your use of the Site the next time you visit. If you do not want to receive cookies from this Web site, you can set your browser to not accept cookies.

Security

The site has security measures in place to protect against the loss, misuse or alteration of information under UFCW Local 655 Welfare Fund's control. However, please bear in mind that no Web site or data transmission over the Internet is totally secure. As a result, while UFCW Local 655 Welfare Fund strives to protect your personal information, UFCW Local 655 Welfare Fund cannot promise or guarantee the security of any information you provide on or through this site.

Steps You Can Take to Protect Your Privacy

You can help protect against unauthorized access to our use this Web site by (1) protecting your login name and password, (2) if changing your password, choosing a password that is unique and not used by you for any other Web site; and (3) logging out of the site and closing the Web browser window at the end of each viewing session. These safeguards are particularly important if accessing the site from a public computer terminal.

Links to Third Party Web Sites

This Web site contains links to other Web sites maintained and operated by third parties. These links are for the convenience of visitors to the Web site only, and the inclusion of such links does not necessarily imply an affiliation, sponsorship or endorsement. You should review the privacy policies of other Web sites carefully before providing any information to such Web sites. UFCW Local 655 Welfare Fund is not responsible for the privacy policies or procedures or the content of any other Web site.

Changes to our Privacy Statement

This Privacy Statement may be changed from time to time at UFCW Local 655 Welfare Fund's sole discretion and as provided by applicable law. We will notify you of these changes by updating the "Effective Date" for this Privacy Statement, or by posting a notice on our Site that the Privacy Statement has been changed. However, it remains your responsibility to review the Privacy Statement, and your continued use of the Web site after we have amended the Privacy Statement shall signify your acceptance of any modifications.

Contacting Us

If you have questions about this Privacy Statement, or any other questions concerning the Web site, please contact us at: UFCW Local 655 Welfare Fund 13537 Barrett Parkway Suite 100 Manchester, MO 63021 Phone: 1-866-565-2700 or 314-835-2700 (local)