Last Updated: February 16, 2021

Victoria Corporation, LTD (“Victoria”, “Company”, “we,” or “us”) is committed to protecting the privacy and security of information you share with us. This privacy policy (“Privacy Policy”) explains how we handle information collected through our website www.vclrisk.com (the “Website”), including any content, functionality, and services (collectively, the “Services”) offered on or through the Website, on any platform and in any format. This Privacy Policy does not apply to claims processing information or other information collected by our insureds that is provided to us outside the Website.

By submitting information to us through the Website you consent to our collection, use, processing, sharing, storage, security, retention and access as described in this Privacy Policy.

Please refer to our Terms of Use (“Terms”) for additional information.

No Children Under 18

The Services are not directed at or intended for use by children under 18 years old. We do not knowingly collect or retain personal information from minors under the age of 18. If you are under the age of 18 and are visiting or otherwise using the Website please exit the Website immediately and do not disclose or provide any personally-identifiable information via the Website.

Users Outside the United States

The Services are not directed at or intended for users outside the U.S. Please be advised that if you are located in the European Union or another region with laws related to data collection, use and transfer that may differ from U.S. law, your personal information submitted through the Services and transferred to the U.S. may not have the same legal data protection as in your jurisdiction. If you access the Website from outside the United States, you do so on your own initiative and are responsible for compliance with local laws.

Information We Collect

As you browse and access content on the Website, we passively collect certain information from you and your computer. We collect such information about your Website usage and interest in the Services as you browse the Website through the use of cookies, beacons, and analytics tools as described more fully below. If you do not want us to collect this information, do not use the Website.

Information we directly collect from you through the Website may include:

• Information that identifies you personally such as your name, email address, and telephone number.

• Any other information you voluntarily provide when you contact us through online forms made available on the Website that may identify you or allow online or offline contact with you.

How We Use Collected Information

We use information collected through the Website as follows.

• To act on and respond to your requests and inquiries.

• To personalize your experience and allow us to market and deliver Services that are of interest to you as they become available.

• To analyze Website usage and improve the Services.

• To notify you regarding any concerns with the Website or information collected by us through the Website, including, as required by law in the event that personal information you provided to us is exposed to unauthorized third-parties.

How We Share Collected Information

We will not share your information except in the following limited circumstances:

• We may collect, report and share personal information with third parties that perform services on our behalf, for example, our technical and content service providers. We may also share your personal information with third-party providers of cloud, web and/or server hosting services. Certain third-party service providers utilized by us may collect personal information from you as authorized by us. Our service providers may provide information collected by them through this Website to us, such as reports of email addresses they collect, store and/or process for us, which we may use to contact you. We are not responsible for the privacy practices of these service providers or of other websites. By using our Website, you consent to the processing and handling of your personal information by our service providers in the manner and for the purposes described here and in their respective privacy policies. We do not authorize these third parties to use your personal information except as necessary to provide their services to us or for purposes authorized by us.

• Additionally, we may disclose your personal data (1) to comply with a law, regulation or other governmental request, for example, to comply with subpoenas, court orders, legal process or requests by law enforcement or governmental entities; (2) to investigate or defend against third-party claims against us; (3) to detect, prevent or investigate fraud or other illegal activity or to enforce these terms; (4) to repair or resolve technical issues in the operation of this Website or provision of the Services; (5) if required by law, to respond to a request by you to disclose the information, including a request to allow access to your account and personal information by third-parties designated by you; (6) with your knowledge and consent; and (7) to address emergencies or acts of God.

Cookies, Beacons and Similar Tracking Technologies

This Website may use various technologies, such as cookies and web beacons, to collect and store information when you access and use the Services. Examples of the type of information collected through these tools include internet protocol (IP) address, browser type and version, date and time of the visit, the page from which you accessed the current page, and Website volume, traffic pattern, and related information

A cookie is a piece of data that is either stored in your computer’s memory temporarily and automatically deleted when you close your browser (a “session” cookie) or placed on your hard drive (a “persistent” cookie) by a web server. A persistent cookie is not deleted when the browser is closed. Cookies allow us to make your interaction with the Website faster and more personal, for example by remembering your preferences the next time you return to the Website. Cookies also allow us to monitor how you and other users use the Website. This information can be used to improve the Services or detect and prevent Website misuse.

Web beacons, which are also known as clear GIFs, bugs or pixel tags, are often used in combination with cookies. They are images (often transparent) that are embedded as part of the Website for the purpose of monitoring the behavior of persons who interact with the Website.

We may use cookies and web beacons, alone or in combination, to track visitors around our Website and to analyze browsing, use and navigation patterns on our Website so that we may enhance and improve the Services.

This Website may contain links to other websites, for example, links to our company profiles on Facebook or Linkedin. These third-party websites may set cookies or other tracking tools on your device. We are not responsible for the cookie or tracking practices of other websites.

Most web browsers allow you to set controls to accept or refuse cookies. If you choose to reject cookies, you may still use the Website though your access to some functionality and areas of the Website may be restricted. The means by which you can refuse cookies through your web browser controls vary from browser-to-browser so you should visit your browser help menu for more information.

Google

Among other technologies, our Website uses certain features from the Google Marketing Platform. Google uses cookies to help analyze how users use interact with our Website. Google has its own policy that describes how it collects and processes data, located here. By using our Website, you consent to the processing of data about you by Google in the manner and for the purposes described here and in Google’s policies.

Do-Not-Track Disclosure

This Website does not respond to “Do Not Track Signals.”

Links to Third Party Websites

This Website may contain links to other websites, including those of our clients, partners, sponsors, or of other third parties. Please be aware that we are not responsible for the privacy practices or content of other websites. This Privacy Policy applies solely to information collected through the Website. We encourage our visitors to be aware when they leave the Website and to read the privacy policies of other websites and online services.

How Do We Protect Your Information

We take the security of the information you provide us seriously. To protect your information from unauthorized access and use, we employ reasonable security measures that comply with applicable state and federal law. These measures include commercially reasonable technical, physical and administrative safeguards to protect against the loss, misuse and unauthorized access, disclosure, alteration and destruction of information collected through this Website or through other means. However, we cannot and do not guarantee that the information you provide to us will never be accessed by an unauthorized party or otherwise breached during transmission through the Internet or while stored on our system or otherwise in our care. Additionally, any contact with us through the Website might not be secure. For example, others could view this information in transit.

In the event that we believe any of the personal information you provided to us has been exposed to unauthorized third-parties, we will notify you as required by law or upon our own choice. In the event of such unauthorized exposure, we expressly reserve the right to provide notice to you electronically, if permitted to do so by law.

Your Choices

By submitting information to use through any forms we make available on the Website, you are choosing to “Opt In” to receive communications from Victoria about our Services, including any updates and news releases that we think might be of interest to you. You will have the opportunity to “Opt-Out” of these communications by “unsubscribing” when you receive future communications from us.

Retention of Collected Information

We will retain the information you provide to us for only as long as we deem reasonably necessary or desirable. We reserve the right to delete or destroy any information collected, including personal information, at any time.

Updates to this Privacy Policy

We may update or change our privacy practices and this policy from time to time. If we update the policy, we will publish an announcement on this page of the Website or as otherwise required by law. The date at the top of this policy reflects the date of the most recent update.

Further Inquiries

You may direct questions about this Privacy Policy, or other issues, to us by emailing us at hello@vclrisk.com or by writing to us at: 7000 Six Forks Road, Suite 104, Raleigh, NC, 27615