Insurance Information Practices Privacy Notice

Last Updated: July 24, 2026

1. Who We Are and How This Notice Applies

Global Advisers, LLC (“Global Advisers,” “we,” “us,” or “our”) provides investment advisory services and may also provide insurance-related services in jurisdictions where it is properly licensed or otherwise authorized to do so.

For purposes of this Insurance Information Practices Privacy Notice (“Notice”), “you” and “your” refer to individuals whose personal information is collected, used, or disclosed by Global Advisers in connection with an insurance transaction.

This Notice applies to personal information collected, received, maintained, used, or disclosed in connection with evaluating insurance needs, recommending insurance products, submitting insurance applications, supporting underwriting, placing coverage, servicing policies, or performing other insurance-related activities permitted by law.

Relationship to Our Other Privacy Notices

This Notice supplements our general Privacy Policy and any privacy notice applicable to information governed by the Gramm-Leach-Bliley Act (“GLBA”) or other federal or state financial privacy laws.

Where more than one privacy notice applies, the notice that is most specific to the activity, information, transaction, or jurisdiction involved governs to the extent of any conflict.

2. Information We Collect

We collect personal information as reasonably necessary to evaluate, recommend, apply for, underwrite, place, issue, administer, and service insurance products and to perform other functions permitted under applicable insurance privacy laws.

Information We May Receive From Existing Client Records

Where permitted by law and relevant to an insurance transaction, we may use or receive information already maintained in connection with an existing relationship with you, including:

• Identifiers and contact information, such as your name, postal address, email address, and telephone number;
• Client profile and relationship information;
• Financial, suitability, risk-management, or planning-related information relevant to your insurance needs;
• Household, beneficiary, dependent, and ownership information;
• Information concerning existing insurance coverage; and
• Other information reasonably necessary to evaluate, recommend, place, or service insurance products.

Information We Collect Directly From You

We may collect additional information directly from you that is necessary to:

• Evaluate your insurance needs and suitability;
• Prepare or submit an insurance application;
• Support underwriting, eligibility, policy issuance, or policy servicing;
• Configure ownership, beneficiary, premium-payor, or payment selections;
• Verify your identity;
• Comply with insurance, anti-fraud, licensing, and recordkeeping requirements; and
• Support ongoing insurance communications and servicing.

Depending on the insurance product, this information may include:

• Name, address, date of birth, telephone number, and email address;
• Social Security or taxpayer identification number;
• Driver’s-license or other government-issued identification information;
• Employment and occupational information;
• Income, assets, liabilities, and other financial information;
• Existing insurance coverage and claims history;
• Medical history, health conditions, medications, treatment history, and family medical history;
• Lifestyle, avocation, travel, tobacco, alcohol, and other underwriting information;
• Beneficiary, owner, insured, and premium-payor information;
• Banking or payment information where needed to establish premium payments; and
• Other information requested by an insurance carrier or reasonably necessary to complete or service an insurance transaction.

Information We Obtain From Other Sources

We may also receive personal information from:

• Insurance carriers and their affiliates;
• Insurance-support organizations;
• Brokerage general agencies, insurance marketing organizations, distributors, and third-party administrators;
• Consumer reporting agencies;
• Medical-information services;
• Medical institutions, physicians, or other health professionals, subject to applicable authorization requirements;
• Pharmacy-benefit or prescription-history services;
• Motor-vehicle departments and other government agencies;
• Inspection, laboratory, paramedical, and underwriting service providers;
• Reinsurers and insurance intermediaries;
• Authorized representatives and professional advisers; and
• Other institutional sources involved in evaluating, underwriting, placing, issuing, administering, or servicing insurance policies.

Insurance-support organizations may retain and disclose information as permitted by applicable law.

Consumer Reports and Investigative Information

For certain insurance products or transactions, we or the insurance carrier may obtain consumer reports, investigative consumer reports, motor-vehicle records, prescription-history reports, medical-information reports, inspection reports, or other underwriting information in accordance with applicable law.

If an investigative consumer report or similar report is obtained, we or the insurance carrier will provide any notices, disclosures, or rights required by applicable law.

We do not use pretext interviews or other deceptive practices prohibited under applicable insurance privacy laws, and we require third parties acting on our behalf to comply with applicable legal requirements.

Marketing and Research Uses

We do not collect personal information in connection with an insurance transaction for the primary purpose of marketing or research unless the use is permitted by applicable law and disclosed when the information is obtained.

Where consent is required for a marketing or research use, we will request that consent before using the information for that purpose.

Medical and Health Information

For certain insurance products, we may collect medical or health information through applications, questionnaires, interviews, examinations, laboratory testing, medical records, prescription-history reports, or other authorized sources.

We collect, use, and disclose medical or health information only as permitted by applicable law and subject to any required authorization, notice, and limitation requirements.

3. How We Use Personal Information

We use personal information as reasonably necessary to provide insurance-related services, including to:

• Evaluate insurance needs, objectives, and suitability;
• Identify and recommend insurance products;
• Obtain illustrations, preliminary underwriting assessments, or informal carrier inquiries;
• Prepare and submit insurance applications;
• Support underwriting, eligibility review, and policy issuance;
• Place insurance coverage;
• Serve as agent or producer of record where applicable;
• Assist with policy delivery, acceptance, and premium arrangements;
• Provide ongoing policy servicing;
• Assist with beneficiary, ownership, address, payment, or other policy changes;
• Communicate with you, insurance carriers, and other parties involved in the transaction;
• Coordinate insurance matters with your authorized advisers or representatives;
• Maintain records of insurance transactions and communications;
• Satisfy legal, regulatory, licensing, supervisory, and recordkeeping obligations;
• Detect, prevent, and respond to fraud, misrepresentation, unauthorized activity, or security incidents; and
• Perform other insurance-related activities permitted by applicable law.

Use of Medical or Health Information

Medical or health information is used only for legally authorized insurance-related purposes, such as:

• Evaluating insurance needs;
• Underwriting;
• Eligibility determination;
• Risk classification;
• Policy pricing;
• Policy issuance;
• Policy administration or servicing;
• Claims-related assistance where applicable;
• Fraud prevention; and
• Other purposes permitted by insurance privacy law.

4. How We Disclose Personal Information

We disclose personal information in connection with insurance transactions only as reasonably necessary to provide insurance products or services, administer our business, comply with legal obligations, protect against fraud, or as otherwise permitted or required by law.

Global Advisers does not sell personal information in exchange for money.

We may disclose personal information, including medical or health information where permitted, to:

• Insurance carriers and their affiliates for underwriting, eligibility review, policy issuance, administration, claims handling, fraud prevention, and servicing;
• Brokerage general agencies, insurance marketing organizations, distributors, and other intermediaries that assist with product selection, placement, underwriting, or servicing;
• Insurance-support organizations that collect, use, or maintain information in connection with underwriting, claims, fraud prevention, policy administration, or servicing;
• Consumer reporting agencies and medical-information services;
• Inspection, laboratory, paramedical, and underwriting service providers;
• Reinsurers and other parties involved in evaluating or transferring insurance risk;
• Technology, communications, document-management, compliance, and recordkeeping service providers that perform functions on our behalf;
• Attorneys, accountants, auditors, compliance consultants, and other professional advisers;
• Government agencies, insurance regulators, securities regulators, courts, law-enforcement authorities, and other governmental bodies;
• Authorized representatives, beneficiaries, owners, insured persons, payors, trustees, or other parties involved in an insurance transaction;
• Parties involved in a proposed or completed merger, acquisition, financing, reorganization, transfer of business assets, or similar transaction; and
• Other persons or organizations where you direct or authorize the disclosure or where disclosure is otherwise permitted or required by law.

Depending on your state of residence and the information involved, we may be required to obtain consent or authorization before disclosing nonpublic personal financial information, nonpublic personal health information, or other protected information to certain third parties.

Insurance-Support Organizations

If information about you is obtained from or disclosed to an insurance-support organization, you may have the right under applicable law to request the organization’s name and address.

Depending on your state of residence, you may also have the right to request access to or correction of information maintained by that organization.

An insurance-support organization may retain and disclose information as permitted by law.

Medical or Health Information Disclosures

Medical or health information is disclosed only as reasonably necessary to evaluate, underwrite, price, issue, administer, or service an insurance policy, assist with claims, detect or prevent fraud, comply with law, or perform another legally authorized insurance function.

Disclosure to Related Businesses

Where permitted by applicable law, Global Advisers may disclose information between its investment advisory and insurance activities when reasonably necessary to evaluate insurance needs, provide requested services, coordinate financial planning, maintain records, or comply with legal and regulatory obligations.

Where consent or authorization is required for such a disclosure, we will obtain it before the information is disclosed.

Legal and Regulatory Disclosures

We may disclose information when required or permitted by law, including to:

• Insurance regulators;
• Securities regulators;
• Law-enforcement agencies;
• Courts;
• Tax authorities;
• Other government agencies;
• Auditors and examiners; and
• Other persons responding to lawful legal process, examinations, investigations, or audits.

5. Authorizations for Use and Disclosure of Personal Information

Depending on your state of residence and the information involved, applicable insurance privacy law may require us or an insurance carrier to obtain your written authorization before using or disclosing certain personal, financial, or health information.

When authorization is required, the authorization may:

• Describe the information to be used or disclosed;
• Identify the persons or categories of persons authorized to disclose the information;
• Identify the persons or categories of persons authorized to receive the information;
• Describe the purpose of the use or disclosure;
• State how long the authorization remains valid;
• Explain how you may revoke the authorization;
• Describe any limitations on revocation; and
• Explain the possible effect of revocation on underwriting, policy issuance, servicing, or claims.

We will not condition an insurance product or service on an authorization except where permitted by applicable law or where the information is reasonably necessary to complete the requested insurance transaction.

Revoking an Authorization

You may revoke an authorization by submitting a written request to Global Advisers or to the insurance carrier, as applicable.

A revocation generally does not affect information already used or disclosed in reliance on a valid authorization before the revocation was received.

Revoking an authorization may prevent an insurance carrier from completing underwriting, issuing coverage, servicing a policy, or processing a claim where the information is necessary for that purpose.

6. Retention and Security

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, to service the insurance transaction, to satisfy business and legal requirements, or as otherwise permitted or required by law.

Retention periods may depend on:

• The nature and sensitivity of the information;
• The type and status of the insurance transaction;
• Insurance-carrier requirements;
• Licensing, regulatory, and recordkeeping obligations;
• Contractual obligations;
• Fraud-prevention and security considerations;
• Whether the information is needed to establish, exercise, or defend legal claims; and
• Whether the information is subject to an examination, investigation, litigation hold, or similar obligation.

We maintain administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, acquisition, use, alteration, and disclosure.

These safeguards may include:

• Policies and procedures;
• Access restrictions;
• Authentication controls;
• System and network protections;
• Secure transmission and storage methods;
• Employee or contractor training;
• Vendor oversight;
• Incident-response procedures; and
• Physical-access controls.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7. Privacy Rights

Depending on your state of residence, you may have some or all of the following rights with respect to personal information collected, used, or disclosed in connection with an insurance transaction.

Right to Access Recorded Personal Information

You may request access to recorded personal information we maintain about you in connection with an insurance transaction, subject to applicable limitations.

In some circumstances, medical information may be provided through a physician or other medical professional designated by you rather than directly to you.

Access may also be limited where disclosure would reveal confidential commercial information, violate another person’s rights, interfere with an investigation, or otherwise be restricted by law.

Right to Know to Whom Information Has Been Disclosed

You may have the right to request information concerning the persons, organizations, or categories of organizations to whom recorded personal information has been disclosed during the period required by applicable law.

Right to Request Correction

You may request correction, amendment, or deletion of recorded personal information that you believe is inaccurate, incomplete, or improperly maintained.

We will make the requested change where required or appropriate, or explain the basis for refusing the request.

Where provided by law, you may submit a statement of dispute. That statement may be included with future disclosures of the disputed information.

Rights Relating to Adverse Underwriting Decisions

If an adverse underwriting decision is made and disclosure is required by applicable law, Global Advisers, the insurance carrier, or another responsible party will provide the reason for the decision or inform you of your right to obtain that reason.

An adverse underwriting decision may include a denial of coverage, a decision to offer coverage only at a higher rate or with modified terms, a limitation or exclusion, or another unfavorable underwriting action, as defined by applicable law.

Right to Revoke Certain Authorizations

Where an authorization is required for the use or disclosure of information, you may have the right to revoke that authorization as described in Section 5.

How to Exercise Your Rights

To exercise an applicable right, submit a written request using the contact information below and identify:

• Your full name;
• Your current contact information;
• The insurance policy, application, carrier, or transaction involved;
• The specific right you wish to exercise; and
• The information or record involved, if known.

We may request additional information reasonably necessary to verify your identity, locate the relevant records, or confirm your authority to act for another person.

We will respond within the period and in the manner required by applicable law.

If your state does not require us to provide or honor a particular right, or if an exception applies, we may deny or limit the request and will provide an explanation where required.

8. Changes to This Notice

We may update this Notice periodically to reflect changes in our insurance practices, services, carriers, service providers, legal requirements, regulatory requirements, or business operations.

When we revise this Notice, we will update the Last Updated date at the top.

Where appropriate or required by law, we may provide additional notice of material changes.

9. Questions and Contact Information

If you have questions about this Notice, our insurance privacy practices, or a request concerning insurance information, contact us at:

Global Advisers, LLC
1650 Market Street, Suite 3600
Philadelphia, Pennsylvania 19103

Telephone: 800-832-8514
Email: corporate@globaladvisers.com