While confidential information is the cornerstone of our ability to provide superior service, our most important asset is our customers’ trust. Keeping customer information secure, and using it only as our customers would want us to, is a top priority for all of us. Here then, is our promise to our individual customers:

1. We will safeguard, according to strict standards of security and confidentiality, any information our customers share with us.

2. We will limit the collection and use of customer information to the minimum we require to deliver superior service to our customers, which includes advising our customers about our products, services and other opportunities, and to administer our business.

3. We will permit only authorized employees, who are trained in the proper handling of customer information, to have access to that information. Employees who violate our Privacy Policy will be subject to our normal disciplinary process.

4. We will not reveal customer information to any external unrelated organization unless we have previously informed the customer in disclosures or agreements, have been authorized by the customer, or are required by law or by duly authorized regulators.

5. We will always maintain control over the confidentiality of our customer information. We do share a limited amount of pertinent customer information with our strategic partners, with lenders with which we have formal affiliations (i.e. correspondents), and with private investors with whom we routinely work. These other parties all adhere to similar privacy policies.

6. We do not sell, lease, rent or otherwise share our customer lists. We provide customers with an option to remove their names from marketing lists. At any time, customers can contact us to remove their names from such lists.

7. Whenever we hire other organizations to provide support and/or third party consulting services, we require them to conform to our policy standards, and to allow us to audit them for compliance.

8. We will not use or share – internally or externally – personally identifiable medical information for any purpose other than the appropriate underwriting of an account, or as disclosed to the customer when the information is collected, or to which the customer consents.

9. We will attempt to keep customer files complete, up to date, and accurate. We will tell our customers how and where to conveniently access their account information (except when we’re prohibited by law), and how to notify us about errors which we will promptly correct