PRIVACY POLICY

We recognize that your privacy is important to you and that you expect us to protect the information you provide us and to use it only in relation to the execution of the Member Benefit Programs (collectively referred to as "the Programs").  To protect your information, we have adopted and adhere to the following policy regarding the privacy of your nonpublic personal information and personally identifiable information (collectively "Nonpublic Personal Information").

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information.  Please read this notice carefully to understand what we do.

A.  INFORMATION THAT WE COLLECT
We will be collecting all or some of the following personal information:  name, address, home phone number, work phone number, cell phone number, auto policy number, and other information that permits us to contact or communicate with you.

B.  HOW WE COLLECT INFORMATION
All financial companies need to share customers' personal information to run their everyday business.  In the section below (Section C), we list the reasons we share their customers' personal information; the reasons they choose to share; and whether you can limit this sharing. We collect this Nonpublic Personal Information through various sources, including: Information we receive from     you on new account forms, fact-finding questionnaires, product and service applications, and other forms; Information we receive from you, in writing, electronically, through the telephone, or through our website, when you communicate with us, or request information about the Programs;

C.  INFORMATION THAT WEDISCLOSE AND TO WHOM WE DISCLOSE IT

As permitted by law and as outlined in this policy, we disclose Nonpublic Personal Information only to unaffiliated third parties that provide services to us or with whom we have contractual relationships to allow us to administer the Programs and conduct our everyday business purposes.  These third parties with we may share your Nonpublic Personal Information include: The company which prepares the documents associated with the Programs; The company which assists in the processing of your data and makes it available to us so we may     administer the Programs.

D. STEPS WE TAKE TO PROTECT YOUR INFORMATION
We have enacted security policies and procedures designed to prevent unauthorized use or access to your Nonpublic Personal Information.  Your information is only available to our employees for various business purposes, such as processing or servicing claims, and those fulfilling compliance, legal or audit functions.  We use password protection to prevent access by unauthorized personnel, and we employ other physical, electronic, and procedural safeguards to ensure the protection of your Nonpublic Personal Information in accordance with state and federal privacy regulations.

E. AMENDMENTS TO OUR PRIVACY POLICY
When we make material amendments to our Privacy Policy, we will post an appropriate notice on our website.  In addition, we may send you an amended version of our Privacy Policy through the mail.

F.  YOUR RIGHTS
Federal law gives you the right to limit sharing for affiliates' everyday business purposes - information about your credit worthiness; affiliates from using your information to market to you; and sharing for nonaffiliates to market to you.  State laws and individual companies may give you additional rights to limit sharing.