Our commitment to your privacy:

Your rights to privacy regarding your personal information are regulated by law. We, and our affiliated companies, consider ourselves very fortunate and honored to merit your trust, and it is our goal to remain worthy of it. The following policy statement describes our privacy commitment to you.

We receive non-public personal information about you from the following sources:

» Our conversations with you, as well as the applications and other forms you provide to us;
» Your transactions with us, our affiliates, or others in the normal course of business;
» Your employer, your benefit plan administrator(s) and third parties whom you have authorized to provide us with information.

We typically collect the following types of information about you:

» Your name, address and other contact details, as well as that of your family;
» Your age, occupation, salary and marital status;
» Your health and health history and that of your family;
» Your benefit elections and detailed information about your benefits;

» A personal identifier such as your Social Security Number, policy number, etc.

Updating Your Personal Information

While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly updating your personal information with your employer.

Use and Disclosure of Your Personal Information

Malleolo Associates, Inc. does not disclose any non-public personal information about you to unaffiliated third parties except as authorized by you or as permitted by law including in response to governmental or regulatory requests. Malleolo Associates, Inc. does not sell information about you to any third parties.

Securing Your Personal Information

We restrict access to non-public personal information about you to our employees, affiliates and service providers who are involved in offering or administering the products and services that we and our affiliates offer. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your non-public personal information.

Changes to Policy

This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised Policy will be effective immediately upon posting to the Malleolo Associates, Inc. Web site. This version of the Policy is effective July 2, 2009.