Privacy Policy

---

PURPOSE OF THIS NOTICE

Title  V of the Gramm-Leach-Bliley Act (GLBA) generally prohibits any  financial institution, directly or through its affiliates, from sharing  nonpublic personal information about you with a non-affiliated third  party unless the institution provides you with a notice of its privacy  policies and practices, such as the type of information that it collects  about you and the categories of persons or entities to whom it may be  disclosed. In compliance with the GLBA, we are providing you with this  document, which notifies you of the privacy policies and practices of  The Kelley Group Co. 

The  GLBA further requires that we inform you that you have a right to  prevent us from sharing nonpublic personal information about you with a  non-affiliated third party for any purpose that is not specifically  authorized by law. Your right to prevent us from sharing nonpublic  personal information about you with a non-affiliated third party for a  purpose that is not specifically authorized by law is called your right  to “opt out” of such information sharing. 

OUR PRIVACY POLICIES AND PRACTICES

1. Information we collect: 

a. We collect nonpublic personal information about you from the following sources: 

i.  Information we receive from you on insurance applications or other  insurance company forms with regard to insurance coverage in place.

ii. Information about your transactions with us or with others as it pertains to insurance coverage in place. 

iii.  Information we receive from a consumer reporting agency such as credit  reports bearing on your creditworthiness, credit standing, credit  capacity, character, general reputation, personal characteristics or  mode of life which is used, expected to be used, or collected for the  purpose of serving as a factor in establishing your eligibility for  insurance to be used primarily for personal purposes. 

iv.  Information we receive from claims adjusters or other individuals or  entities concerning the processing or administration of claims that you  might have as a result of purchasing an insurance product from us. 

v.  Information we receive from underwriting services such as CLUE or Fair  Isaac provided for insurance companies and agents and used as a factor  in establishing your eligibility for insurance to be used primarily for  personal purposes. 

vi.  Information we receive from government agencies such as motor vehicle  records. vii. Information that we compile from sources that are within  the public domain such as telephone books, city directories, and  membership lists that are subsequently compiled into a nonpublic  personal information database used by us. 

b.  Unless it is specifically stated otherwise in an amended Privacy Policy  Notice, no additional information will be collected about you. 

2. Information we may disclose to third parties: 

a.  We may disclose all of the information we collect, as described above,  about our customers or former customers, to companies that perform  marketing services on our behalf or to other financial institutions with  whom we have joint marketing agreements. We also may disclose  information about our customers or former customers as permitted by law.  

3. Non-affiliated third parties to whom disclosures may be made: 

a.  We may disclose nonpublic personal information about you, such as we  have described above, to the following types of third parties: 

i.  Financial institutions with whom we have joint marketing agreements  such as insurance providers including those that have issued a policy or  policies to you. 

ii.  Financial institutions that may have loaned you money to acquire an item  of personal property such as a house, boat, car, jewelry, etc. that  requires proof of insurance coverage. 

iii. Other insurance agents or brokers to enable us to provide insurance coverage requested by you. 

iv. We may also disclose nonpublic personal information about you to non-affiliated third parties as permitted by law. 

b. Notification of Your Right To Opt Out of Certain Disclosures 

i.  The Kelley Group Co. does not disclose any nonpublic personal  information about you for any purpose that is not expressly permitted by  the Gramm-Leach-Bliley Act. 

4. Our practices regarding information confidentiality and security: 

a.  We restrict access to nonpublic personal information about you to those  employees who need to know that information in order to provide  products or services to you. We maintain physical, electronic, and  procedural safeguards that comply with federal regulations to guard your  nonpublic personal information. 

5. Our policy regarding dispute resolution: 

a.  Any controversy or claim arising out of or relating to our privacy  policy, or the breach thereof, shall be settled by arbitration in  accordance with the rules of the American Arbitration Association, and  judgment upon the award rendered by the arbitrator(s) may be entered in  any court having jurisdiction thereof. 

6. Reservation of the right to disclose information in unforeseen circumstances: 

a.  In connection with the potential sale or transfer of its interests, The  Kelley Group Co. reserves the right to sell or transfer your  information (including but not limited to your address, name, age, sex,  zip code, state and country of residency and other information that you  provide through other communications) to a third party entity that (1)  concentrates its business in a similar practice or service; (2) agrees  to be The Kelley Group Co.’s successor in interest with regard to the  maintenance and protection of the information collected; and (3) agrees  to the obligations of this privacy statement.