Alert Program Privacy Policy and Terms and Conditions

• Affiliated general insurance companies means subsidiaries of Desjardins General Insurance Group Inc. other than Desjardins General Insurance Inc. and The Personal General Insurance in Quebec:
  • Certas Home and Auto Insurance Company
  • Certas Direct Insurance Company
  • The Personal Insurance Company
• Alert program or program mean the prevention program offered by Roost in collaboration with us, as described more fully in Section 2.2 of the Terms and Conditions.
• Application means the Desjardins Insurance Home-Auto mobile application.
• Home security system, security system or system means the Roost security system that includes various devices linked to a smart base.
• Personal information or your information mean any information pertaining to a specific individual that can be used to directly or indirectly identify that individual.
• Policy means the Alert Program Privacy Policy indicated in Part 1 of this document.
• Professional monitoring service means the subscription-based service offered by Roost that allows alerts to be sent to a monitoring service and emergency services to be dispatched to the participant's home if needed.
• Roost refers to Roost, Inc., the provider of the security system devices, associated software and professional monitoring service.
• Terms and Conditions means the Alert Program Terms and Conditions indicated in Part 2 of this document.
• We, us, or our refers to Desjardins General Insurance Inc. in Quebec and Desjardins General Insurance Group Inc. in all other Canadian provinces and territories where the Alert program is offered.
• Website means www.desjardins.com/en/insurance/home/alert.html.
• You, your, yours or yourself means Alert program participants.

Last update: April 17, 2024

Your privacy is invaluable. That's why we take the protection and confidentiality of personal information you entrust us with very seriously.

To generate prevention notifications, maintain the Desjardins Insurance Home-Auto mobile application or meet our legal obligations, we need to collect, use and disclose certain personal information.

It's our responsibility to ensure that all data and personal information collected is handled securely. This is the basis of our Alert Program Privacy Policy and how we apply it. It explains why we collect your personal information, how we handle it and how we protect it.

Getting your consent

What is my consent to the collection, use and disclosure of my personal information?

By giving your consent, you authorize us to collect, use and disclose your personal information to allow you to participate in the Alert program and meet our legal obligations.

We will get your consent directly from you to allow us to collect, use and disclose your personal information in accordance with the Policy.

If you have to provide us with personal information about another person (like one of your emergency contacts), make sure you have their consent before doing so. You'll also need to let that person know that we will collect, use and disclose their personal information for the purposes stated in the Policy or in accordance with applicable laws.

We collect, use and disclose only the personal information that is necessary, unless we have obtained your prior consent or we are permitted or required by law to do otherwise.

This consent to the collection, use and disclosure of your personal information is required for participation in the Alert program and takes precedence over any previous consent provided in connection with the program. Your consent will remain valid for as long as you use the application or the Alert program is activated in it.

Can I withdraw my consent to collect, use and disclose my personal information or refuse to provide certain personal information?

Downloading the application and activating the Alert program are entirely voluntary. If you do not agree to certain personal information management and protection practices or to the Terms and Conditions, you should not activate the Alert program in the application. If it is already activated, you should stop using it. Please refer to the Alert Program Terms and Conditions for more information.

If you decide to withdraw your consent to the collection, use and disclosure of the personal information necessary for participating in the Alert program and meeting our legal obligations, we may not be able to offer you the program. Your eligibility for certain advantages and discounts on your home insurance policy for subscribing to a professional monitoring service may no longer be available to you.

Collecting only what's necessary

What personal information is being collected about me and how is it collected?

We collect your personal information from 4 main sources:

• Directly from you
• When you browse our website
• When you use the application
• From Roost

A) Directly from you

When you communicate with us, regardless of the method used (for example by telephone, email or online chat), we ask you to provide personal information. For example, we need to identify you by asking you to answer authentication questions.

The same approach applies if you contact us to get information about the Alert program or the application, request a refund or make a complaint.

In addition, for us or an affiliated general insurance company to offer you home insurance discounts you might be eligible for, we ask you to provide your insurance policy number and your date of birth.

B) When you browse our website

When you browse our website, we collect the address of the website you visited and the language you viewed it in.

When you use our application or visit our website, your information may be stored in cookies and other mobile and web measurement tools that we or third parties install on your computer or device. Cookies help tailor your experience interacting with the application or our website.

If you'd like to learn more about what cookies are, which web and mobile measurement tools we use, how we use them and what your options are with regard to these technologies, see our practices for the use of cookies and other technologies.

C) When you use the application

Once you've downloaded the application, in order to create your account and confirm your identity, we ask you to provide us with personal information like your first and last name, province, email address and cellphone number.

When you set up your security system in the application, we collect the home address where the system is installed and the serial number for the system's smart base (MAC address).

We also collect data and personal information about your use of the security system within the application:

• Security system status (armed or disarmed)
• Name of each device connected to the security system that you enter in the application
• Security system settings that can be changed in the application
• First and last name and telephone number of the emergency contacts that you choose to put in the application

We temporarily collect the various system passwords (4-digit codes) that you create and assign in the application to be used by you, other security system users and designated emergency contacts. We do not store these passwords; they are recorded directly into your security system by Roost.

Finally, we collect data about the connection settings for your home Wi-Fi network that you use to keep the security system connected to the internet and working.

D) From Roost

Once your security system is installed and working, we collect certain data and personal information from Roost about events detected by the devices connected to your system's smart base. The data and personal information described below is first collected securely by Roost from your system through your home's Wi-Fi network or the cellular network. Then it is securely provided to us in real time using an anonymous identification number to protect your personal information.

The following data and personal information are collected by the security system devices (meaning the smart base, keypad, door and window contacts, motion detector, water and freeze detectors, and/or smoke alarm listener):

• Date and time of the event detected by the device
• Device battery charge level
• Wi-Fi network and cellular network connection quality
• System or a system device connectivity, as applicable
• Device AC or battery power status
• Security system status (armed or disarmed)
• User ID of the person who changed the security system status
• Silent panic alarm initiation events
• Motion detection events
• Water or freeze detection events
• Humidity level at a given time
• Temperature at a given time
• Open and close events for each door and window contact
• Smoke alarm sound detection event

Roost also provides us with your professional monitoring service subscription status.

How long will my personal information be collected?

Your information is collected as soon as you create your account in the application. It continues to be collected for as long as your security system is installed and active in your application or connected to the internet. Only devices that are compatible with Roost's security system can be connected to the smart base.

The security system temporarily or permanently stops collecting data if any of the following happen:

• One or more devices are not correctly connected to the smart base
• The smart base is connected neither to the Wi-Fi network nor the cellular network
• You stop participating in the Alert program by uninstalling your security system from your home and from the smart base settings in the application
• We or Roost terminate your participation in the Alert program for the reasons stated in the Terms and Conditions or the Alert program is discontinued

Being transparent about our practices

What do you use my personal information for?

We use your personal information for the purposes identified below and to meet our legal obligations.

We'll inform you if we plan to use your personal information for any other purpose, unless we are legally authorized to use it otherwise.

As such, before we can serve you and provide you with the Alert program, we must:

Identify you

• Confirm who is participating in the Alert program by verifying that you are who you say you are (identify you and validate your identity).
• Ensure that your personal information is still accurate, complete and up to date before we use it; however, it is your responsibility to inform us of any changes.

Assess your eligibility for the Alert program

• Assess whether you meet the eligibility requirements for the Alert program.

Offer you the benefits of the Alert program

• Send you notifications in the application or by text message, according to your communication preferences, in the event of smoke, a break-in, a water leak, freezing temperatures or a power outage. You can prevent the application from sending you notifications at any time by changing your communication preferences in the application. However, if you disable notifications, it could affect your ability to react to events detected by the system devices.
• Offer you or enable you to be offered home insurance premium discounts you might be eligible for from us or an affiliated general insurance company, as applicable.
• Design statistical models to deliver products, services and other advantages in connection with the Alert program that meet your needs.
• Maintain the application you downloaded and the Alert program you activated.
• Communicate with you about the Alert program and your application by email, mail or telephone.
• Handle inquiries, complaints and dissatisfaction.

Manage the risks associated with our activities

• Assess and monitor the performance of the Alert program in the application, improve them and create new related services.
• Develop, maintain and improve internal audit systems, processes, methods, practices and procedures.
• Design statistical models and build dashboards, indicators and other types of reports to assess and further develop our insurance risk management mechanisms.
• Find, identify and assess risks to continuously improve the Alert program and the application.
• Design statistical models and build dashboards, indicators and other types of reports to monitor operations and ensure the security of your information.

We must also use your personal information to meet our legal obligations to prevent cyber threats, fraud and other financial crimes, and respond to information requests, warrants and orders from courts and other organizations.

We do not use your email address or your cellphone number to contact you about products and services other than those in the Alert program, unless we've received your consent to do so.

In addition, if you are insured by us, we do not use the personal information collected to cancel or nullify your home insurance or to refuse to renew it. We do not use the personal information collected to your disadvantage in the event an insurance claim is made by or against you. Finally, we do not use the personal information collected to increase or decrease your home insurance premiums. If you are insured by an affiliated general insurance company, your information is also not collected or used by the applicable affiliated general insurance company in the manner described above.

Who has access to my personal information?

Access to your information is limited to our employees, service providers, consultants, agents, and representatives who need access to it to perform their duties.

Our employees and consultants commit annually to protect the confidentiality of the personal information they need while performing their duties and must regularly take security and privacy training.

Affiliated general insurance companies

Certain personal information may be disclosed between us and an affiliated general insurance company that you have a home insurance policy with, if applicable, for the purpose of confirming your eligibility for any discounts.

Courts, authorities and other agencies

Certain situations require us to disclose your personal information to courts, law enforcement authorities and other agencies.

This may be necessary to prevent cyber threats, fraud and other financial crimes, to respond to requests, warrants and orders, or to meet our insurance obligations.

Suppliers and partners

We may disclose personal information about you to suppliers and partners.

Suppliers and partners could include, but are not limited to, the following:

• Information technology services and products companies
• Consulting firms mandated by us
• Cloud, web-hosting and data-processing services
• Legal services

Partners and suppliers must contractually agree to comply with and abide by our strict standards for the protection and confidentiality of your personal information as set forth in this Privacy Policy.

We entrust our suppliers and partners with the personal information they need to perform their duties, functions and contractual obligations with us.

In addition to being subject to confidentiality obligations, the employees of suppliers who have access to personal information must also fully comply with our contractual requirements. Lastly, our suppliers and partners must apply adequate physical, information technology and administrative security measures.

More specifically, we provide Roost with only the personal information and data that is necessary to provide you with the Alert program. Personal information is securely transmitted through a wireless network using an anonymous identification number to protect your personal information.

We'll inform you if a new need arises, unless we're authorized by law to disclose your information without your consent. In all cases, we ensure the protection and confidentiality of the personal information we disclose.

Protecting the security and confidentiality of your information

Is my personal information secure?

We apply the necessary security measures rigorously to ensure the protection of your personal information.

These measures may consist of:

Technology security measures

• Password
• Data encryption
• Access management system
• Monitoring and control to detect suspicious activity
• Any other security measures required to limit access

Administrative security measures

• Access to your information limited to our employees, consultants, agents and representatives who need it to perform their duties
• Adherence to the Code of Professional Conduct and annual certification required for all our employees and consultants, with strict rules governing the protection of personal information
• Regular training and education of employees and consultants on the Code of Professional Conduct, policies, practices and procedures on security and privacy
• Policies and procedures for monitoring, investigating and updating security systems and measures
• Ongoing monitoring and control to detect suspicious activity and potential deviations from our directives and policies

Where is my personal information stored?

Your information is usually stored in Canada, but we may use suppliers or partners in other countries. If required by law or court order, those countries' legal authorities may have access to it, including law enforcement and national security agencies.

If we need to disclose personal information to our suppliers and partners, we will ensure the protection and confidentiality of this personal information meets our own requirements and will ask these suppliers and partners to contractually agree to comply with and respect these requirements.

In all cases, we'll ensure the protection and confidentiality of your information.

How is my personal information stored?

We store your personal information in a secure and confidential manner for as long as necessary to fulfill the purpose for which it was collected and meet our legal obligations.

For example, in Canada, we're subject to laws and regulations that stipulate minimum retention periods. The retention periods must take into account the exhaustion of potential remedies and limitation periods applicable in Canada. These retention periods vary depending on the situation. Therefore, we may retain your personal information after your relationship with us has ended.

When and how is personal information disposed of?

Once the retention period has expired, we ensure that your personal information is safely disposed of or de-identified. While deletion is a final and irreversible disposal process, de-identification means that your personal information is altered so that it can no longer directly or indirectly identify you.

Deletion and de-identification are carried out in a secure manner, in accordance with applicable best practices.

Respecting your rights when it comes to your information

Can I access, correct or update my personal information?

Yes, you can access your personal information at any time.

To do so, you must submit a written request to us. Your request must be detailed enough to allow us to identify the documents or other media containing the personal information you wish to access.

We may need to validate your identity and the reason for your request.

We'll inform you if there are any fees for processing your request. These fees, if any, are reasonable and are usually limited to the cost of transcription, reproduction or transmission. In such cases, we'll ask for your permission before proceeding.

Yes, you can correct inaccurate and incomplete personal information we have about you.

If you wish to correct any inaccurate or incomplete personal information we have about you, you can make the changes in the application. You can also contact us.

Some personal information cannot be changed directly in the application. For example, for a change of address, you're responsible for contacting us to update your personal information.

What can I do if I have questions or if I'm not satisfied with the handling of my personal information?

If you have a question, concern or complaint about the processing of your personal information, you can:

1. First, contact us.

   Talk to a customer service employee to ensure that your complaint or concern is addressed in a timely manner. Call us:

   Quebec: 1-866-835-8975
   Elsewhere in Canada: 1-800-794-0008

2. If you're not satisfied with the response you received, you may contact the Desjardins Group Chief Privacy Officer.

   By mail

   Office of the Chief Privacy Officer
   100 Rue Des Commandeurs
   LEV-100-6^e
   Lévis, QC  G6V 7N5

   By email

   cpo@desjardins.com

You must provide your name and contact information, the nature of your request, the name of the department or person you have already contacted and any relevant information.

If you wish, you may also contact the appropriate provincial or federal privacy commissioner.

Understanding our Policy

Who is the Privacy Policy for?

Any person who downloads the application and participates in the Alert program.

What does it apply to?

The Privacy Policy applies to the personal information we collect and hold about you, which includes any information about you that allows us to identify you. It also includes personal information collected from you on our behalf by one of our agents or representatives.

We collect, use, disclose and protect your personal information in accordance with Canada's privacy laws.

Can your Privacy Policy change? If so, will I be notified?

From time to time, we may make certain changes to our Privacy Policy.

Be sure to check the Privacy Policy periodically for any updates. Changes are effective as of the date indicated on the Privacy Policy.

Last update: April 17, 2024

1. Introduction

You must agree to these Terms and Conditions to participate in the Alert program. Your participation is entirely voluntary. If you do not want to agree to these Terms and Conditions, you should not participate in the Alert program or activate it in the application. See Section 2.5 for eligibility requirements for the Alert program.

You can stop participating in the Alert program at any time, subject to certain conditions. See Section 2.14 for more information.

These Terms and Conditions do not change Roost's terms and conditions or those of the App Store or Google Play as applicable.

2. Program description

2.1 Participating in the Alert program

To participate in the Alert program, you must buy the security system from Roost, download the application if you haven't done so already, and agree to the Privacy Policy and these Terms and Conditions of the Alert program.

2.2 Scope of the Alert program

The Alert program is a prevention program offered by Roost in collaboration with us. It allows you to:

• Arm and disarm your security system using your smartphone or the keypad included in your security system; and
• Receive notifications in the application or by text message, according to your communication preferences, in the event of smoke, a break-in, a water leak, freezing temperatures or a power outage.

With a subscription to Roost's professional monitoring service, you will also receive:

• Text messages on your smartphone, automated calls or, if needed, a call from the monitoring service contracted by Roost in the event of a smoke or intrusion alert to see whether it's necessary to dispatch emergency services to your home.

The devices included in the security system do not prevent incidents such as water leaks, frozen pipes, or break-ins from occurring. You can prevent or limit the damage caused by such incidents by taking action when you receive an alert on your smartphone about any event detected by the security system. Please also note that receiving an alert does not mean an insurance claim has been started, and the fact that you received an alert has no impact on any insurance claim you may file.

If your security system is not installed properly, the functions that the application offers may not work. It is your responsibility to follow the instructions provided and make sure the security system devices are installed correctly. You must test and maintain your devices, replacing batteries as necessary.

2.3 Services offered by Roost

The security system and the professional monitoring service are offered by Roost. Information about the status of your subscription to the professional monitoring service and about events detected by the security system are displayed in the application, using data provided by Roost.

2.4 Specific information about the smoke alarm listener

The security system does not include a smoke detector. The smoke alarm listener included in your security system does not replace the smoke detector in your home and does not detect smoke. It only detects alarm sounds emitted by your smoke detector.

Warning: Some older models of smoke detectors are not compatible with the security system.

2.5 Eligibility requirements for participating in the Alert program

• Reside in Canada in one of the participating provinces or territories: Quebec, Ontario, Saskatchewan, Manitoba, Prince Edward Island, Nova Scotia, Nunavut or Northwest Territories.
• Have a Wi-Fi network connected to a high-speed internet service in the home where the security system is installed.
• Have a smartphone (e.g., iPhone or Android) with wireless service.
• Buy Roost's home security system.
• Install the application on your smartphone and install the security system in your home.
• Authorize the collection, use and sharing of your personal information in accordance with applicable regulations and the Alert Program Privacy Policy presented in Part 1 of this document.

2.6 Basic requirements for security system functioning

In order for the security system to work properly, you must:

• Ensure the smart base is connected to your home's Wi-Fi network.
• Maintain the power supply to the smart base.
• Ensure your devices are paired with the smart base.
• Ensure the batteries in each device are charged.
• Install all the devices as instructed in the application.

If you make changes to your home's Wi-Fi settings or switch internet providers, you are responsible for updating the Wi-Fi settings for the smart base in the application to make sure the security system continues working properly.

To continue participating in the Alert program, you agree to:

• Download all updates available for the application
• Not delete or deactivate the application on your smartphone
• Not permanently uninstall the security system from the application

2.7 Updating personal information in the application

If you move or if your personal information changes, you are responsible for contacting us to make sure the right address is on file for your security system. You are also responsible for updating your cellphone number in the application if you change it. Since your contact information is shared with the central station in case of an emergency (if you have a professional monitoring service subscription), it's important to keep it up to date.

It is also your responsibility to maintain up-to-date information for your emergency contacts in the application.

2.8 Moving to another country, province or territory

The Alert program is available in Canada only. It is not available outside Canada or in the following provinces and territories: Alberta, British Columbia, New Brunswick, Newfoundland and Labrador, and Yukon. If you move to one of these provinces or territories or to another country, you can no longer participate in the Alert program.

2.9 Potential discounts on home insurance premiums

The Alert program is not a property and casualty insurance product. However, by participating in the Alert program, you might be eligible for a discount on your home insurance premiums.

The discount is automatically applied to qualifying insurance policies in this application if you meet the following conditions:

• You are the primary insured on a home insurance policy that's eligible for discounts from the insurer.
• You synced your home insurance policy in this application.
• For the discounts for having a centrally monitored security system:
  • You have the required number of devices and they are connected to the smart base and visible in the app.
  • You tested that your smoke alarm listener detects your smoke detector using the instructions provided in the application.
• For the discount for having a centrally monitored water leak detector system:
  • You installed at least 5 water and freeze detectors and you've kept them installed in the application and connected to the security system's smart base.
• You have an ongoing subscription to Roost's professional monitoring service.

If you do not meet these conditions, please contact us to check whether you're eligible for discounts.

Any discounts you receive will automatically be terminated if you no longer meet one of the conditions mentioned above or if you stop participating in the Alert program. Your discount will expire a minimum of 30 days after you stop participating in the Alert program or no longer meet the conditions for the discount.

We reserve the right to change the conditions, activation process and automatic deactivation process for these discounts at any time.

2.10 Smartphone usage

Warning: The Alert program uses a certain amount of power from your smartphone's battery in order to run in the application. In order for your application to be able to send you alerts about events detected by your security system, you must:

• Keep your smartphone powered on
• Make sure your smartphone's battery is charged
• Make sure your security system's devices are installed and working in the application

The types of alerts you receive depend on your communication preferences in the application. You can choose to enable push notifications and/or text messages.

Warning: The Alert program in your application receives data collected by your security system through a Wi-Fi connection or cellular network. If your smartphone is not connected to Wi-Fi, the Alert program might use data from your cellphone plan. You are responsible for paying any data usage fees that may apply.

2.11 Managing your security system from another smartphone

The Alert program can only be used on one smartphone to manage the security system and it can only be associated with one mobile number.

If you want to manage your security system from another smartphone, you must uninstall your security system from the application and reinstall it in the application downloaded onto the other smartphone.

Please note that you cannot manage multiple security systems from the same smartphone because each security system must be associated with its own mobile phone number. If you want to use more than one security system, each additional security system must be connected to a unique mobile phone number.

2.12 Installing your security system in another home

All devices from the same security system must be installed at the same address.

To install your security system at another address, you'll first need to uninstall all the devices of your security system from your home. Do not uninstall them from your application. Next, reinstall them at your new address, following the best practices for installation described in the application and the Installation and User Guide. If you change the address of the security system, contact us and let us know.

2.13 Changes to the Alert program or the Terms and Conditions

We reserve the right to change the Alert program and the Terms and Conditions at any time. By continuing to participate in the Alert program, you are agreeing to any potential changes. We recommend reviewing these Terms and Conditions on a regular basis.

Please check the date at the top of the Terms and Conditions to see when they were last updated.

2.14 Terminating your participation in the Alert program

To end your participation in the Alert program, uninstall your security system from your home and from the application. If you have a subscription to the professional monitoring service, you must cancel it through Roost's online store.

As soon as you stop participating in the Alert program, you will no longer receive alerts related to the security system on your smartphone, and you will no longer have access to the services offered through the Alert program.

We may terminate your participation in the Alert program if you no longer meet one of the eligibility criteria in section 2.5.

2.15 Termination of the Alert program

We reserve the right to terminate the program at any time.

3. Licence

Subject to your compliance with the Terms and Conditions, we grant you a revocable, non-exclusive and non-transferable limited licence to use the Alert program in the application on any smartphone in your possession or under your control in accordance with the usage rules stated in the App Store or Google Play terms and conditions, as applicable.

4. No representations or warranties

The application is provided "as is", "with all faults" and "as available." Your use of the application is at your sole risk. We, on behalf of ourselves, the creator of the application, the distributors of the application, the operators of the network used for its distribution and their respective affiliates and suppliers, do not make any express or implied warranties with respect to the application, including, but not limited to, warranties of merchantability or fitness for a particular purpose. We do not guarantee, represent or warrant that the application's features and the use of the application will be uninterrupted or error-free, that any defect related to the application will be corrected, or that the application or the servers that make it available will be free of viruses or other elements that may cause damage.

5. Limitation of liability

You acknowledge and agree that participation in the Alert program through your use of the application is not a substitute for insurance and that you have arranged for appropriate insurance coverage for your home. You further acknowledge and agree that we bear no liability to you for any matter related to, or in connection with the system, whether such matter involves you, any authorized user or any third party whatsoever.

To the maximum extent permitted by applicable law, in no event shall we be liable to you or to any third party for any direct, indirect, special, consequential, incidental, exemplary or punitive damages sustained by you arising out of your participation in the Alert program, or for any legal proceedings brought against us, arising from our error, negligence, omission or fault.

To the maximum extent permitted by applicable law, if we are found liable for any loss, damage or injury due to a failure of the application in any respect, liability shall be limited to a sum equal to one hundred dollars (CAN$100.00), as the agreed upon damages or in lieu of any type of damages and not as a penalty, as the exclusive remedy.

6. Disclaimer

In accordance with the provisions of Sections 2.13, 2.14 and 2.15, we reserve the right to modify the Alert program or to terminate it at any time for any reason whatsoever.

7. Trademarks

Alert^TM is a trademark of Desjardins General Insurance Group Inc., used under licence.

Desjardins^®, Desjardins Insurance^®, trademarks containing the word Desjardins and their logos are trademarks of the Fédération des caisses Desjardins du Québec, used under licence.

Roost^® is a registered trademark of Roost Inc., used under licence.

Apple, the Apple logo and iPhone are trademarks of Apple Inc., registered in the U.S. and other countries.

App Store is a trademark of Apple Inc.

Google Play, the Google Play logo and Android are trademarks of Google LLC.

These trademarks are protected by Canadian laws.

8. Contact us

Contact us using the following numbers:

Quebec: 1-866-710-4759
Elsewhere in Canada: 1-866-710-4760

By downloading the application and activating the Alert program in the application, you:

• agree to participate in the Alert program
• consent to these Terms and Conditions
• agree to the collection, use, sharing and retention of your personal information in accordance with applicable regulations and the Alert Program Privacy Policy presented to you in Part 1 of this document