The Findley Inc. companies* are committed to protecting your privacy. To provide the products and services you expect
from a financial services leader, we must collect personal information about you. We do not sell your personal information to
third parties. We share your personal information with third parties as necessary to provide you with the products or services you
request and to administer your business with us. This Notice describes our current privacy practices. While your relationship with us
continues, we will update and send our Privacy Practices Notice as required by law. Even after that relationship ends, we will continue
to protect your personal information. You do not need to take any action because of this Notice, but you do have certain rights as
We collect personal information about you to help us identify you as our customer or our former customer; to process your requests
and transactions; to offer investment or insurance services to you; to pay your claim; or to tell you about our products or services we
believe you may want and use. The type of personal information we collect depends on the products or services you request and may
include the following:
- Information from you: When you submit your application or other forms, you give us information such as your
name, address, Social Security number; and your fi nancial, health, and employment history.
- Information about your transactions: We keep information about your transactions with us, such as the products
you buy from us; the amount you paid for those products; your account balances; and your payment history.
- Information from outside our family of companies: If you are purchasing insurance products, we may collect
information from consumer reporting agencies such as your credit history; credit scores; and driving and employment
records. With your authorization, we may also collect information, such as medical information from other individuals
- Information from your employer: If your employer purchases group products from us, we may obtain information
about you from your employer in order to enroll you in the plan.
We may share your personal information within our companies and with certain service providers. They use this information to
process transactions you have requested; provide customer service; and inform you of products or services we offer that you may
fi nd useful. Our service providers may or may not be affi liated with us. They include fi nancial service providers (for example,
third party administrators; broker-dealers; insurance agents and brokers, registered representatives; reinsurers and other fi nancial
services companies with whom we have joint marketing agreements). Our service providers also include non-fi nancial companies and
individuals (for example, consultants; vendors; and companies that perform marketing services on our behalf). Information we obtain
from a report prepared by a service provider may be kept by the service provider and shared with other persons; however, we require
our service providers to protect your personal information and to use or disclose it only for the work they are performing for us, or as
permitted by law.
When you apply for one of our products, we may share information about your application with credit bureaus. We also may provide
information to group policy owners, regulatory authorities and law enforcement offi cials and to others when we believe in good faith
that the law requires disclosure. In the event of a sale of all or part of our businesses, we may share customer information as part of
the sale. We do not sell or share your information with outside marketers who may want to offer you their own products and
services; nor do we share information we receive about you from a consumer reporting agency. You do not need to take any
action for this benefit.
We have an important responsibility to keep your information safe. We use safeguards to protect your information from unauthorized
disclosure. Our employees are authorized to access your information only when they need it to provide you with products, services, or
to maintain your accounts. Employees who have access to your personal information are required to keep it confi dential. Employees
are trained on the importance of data privacy.
Questions about your personal information should be directed to:
1 SeaGate, Suite 2050
Toledo, OH 43604
We understand that you may be especially concerned about the privacy of your medical information. We do not sell or rent your medical
information to anyone; nor do we share it with others for marketing purposes. We only use and share your medical information for
the purpose of underwriting insurance, administering your policy or claim and other purposes permitted by law, such as disclosure to
regulatory authorities or in response to a legal proceeding.
We want to make sure we have accurate information about you. Upon written request we will tell you, within 30 business days,
what personal information we have about you. You may see a copy of your personal information in person or receive a copy by mail,
whichever you prefer. We will share with you who provided the information. In some cases we may provide your medical information
to your personal physician. We will not provide you with information we have collected in connection with, or in anticipation of, a
claim or legal proceeding. If you believe that any of our records are not correct, you may write and tell us of any changes you believe
should be made. We will respond to your request within 30 business days. A copy of your request will be kept on fi le with your personal
information so anyone reviewing your information in the future will be aware of your request. If we make changes to your records as
a result of your request, we will notify you in writing and we will send the updated information, at your request, to any person who
may have received the information within the prior two years. We will also send the updated information to any insurance support
organization that gave us the information, and any service provider that received the information within the prior 7 years.
Questions about your personal medical information should be directed to:
1 SeaGate, Suite 2050
Toledo, OH 43604