Privacy Statement

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Under Federal law financial institutions are generally prohibited from sharing nonpublic personal information about consumers or customers with a nonaffiliated third party unless the institution provides such consumer or customer with a notice of its privacy policies and practices, such as the type of information that it collects from consumers and customers and the categories of persons or entities to whom the information may be disclosed. In compliance with Federal law and the state laws relating to privacy in the insurance industry, and in order to notify our clients of our privacy policies and practices, we have established this Privacy Policy.

Collecting Information

We collect nonpublic personal information about our individual clients and about the employees and members of our corporate and association clients (and in certain cases their family members) (collectively, "Clients") from the following sources:

• Information we receive from Clients on paper and online applications or other forms, or in connection with providing services to Clients.
• Information we receive as a result of processing and verifying the information provided to us about our Clients.
• Information we receive from affiliates, insurers, intermediaries, third party providers and others about our Clients.
• Information we receive from consumer reporting agencies.
• Information available from external sources (such as publicly available records).

Disclosing Information

We do not disclose any nonpublic personal information, including financial information, about our Clients or former Clients to any third parties, except as stated in this policy, as otherwise required by law or as otherwise may be authorized by you from time to time. We may share this information outside our company in order to process or complete, or otherwise in connection with, the transaction for which the information was provided or as otherwise authorized by our Clients. The law permits us to share this information with our affiliates. We also may disclose any of the information we collect to companies that perform marketing services on our behalf or to companies with which we have joint marketing agreements.

Confidentiality and Security of Information

We restrict access to nonpublic personal information about Clients to those employees of our company who need to know that information in order to provide products or services to our Clients.

Professional Standards

We hold ourselves to the highest of professional standards. We strive to maintain the highest level of confidentiality for our Clients.