NOTICE OF PRIVACY POLICY OF CAPAX – GIDDINGS, CORBY, HYNES

This notice is given in compliance with Title V of the Gramm-Leach-Bliley Act (GLBA) and the laws of the State of California. These laws generally prohibit us from sharing non-public personal information about you with a third party unless we provide you with this notice of our privacy policies and practices describing the type of information that we collect about you and the categories of persons or entities to whom that information may be disclosed. In compliance with GLBA and California law, we are providing you with this document, which notifies you of the privacy policies and practices of Capax – Giddings, Corby, Hynes, Inc.

OUR PRIVACY POLICIES AND PRACTICES

• Your Right To Know

You have the right to know what we do with the personal and confidential information we collect about you in the normal course of business of offering, processing, administering and maintaining the insurance and financial products you purchase from our agency. Because we value our relationship, we want to assure you that we are safeguarding your important information.

• Information We Collect

We collect personal information that you provide to us on applications, other forms and in interviews. In addition, we maintain information about your transactions with us, such as policy coverages, premiums, and payment history. We may obtain additional information from third parties which may include agents, employers, other insurers, consumer credit reporting agencies, the Department of Motor Vehicles, or health care providers in the course of processing, underwriting or administering your insurance policies and annuity contracts.

• Information We May Disclose To Third Parties

We may share your non-public personal information on a confidential basis only with authorized employees, representatives and third parties whose services are required to assure the highest level of service to you. We will not disclose any non-public personal information about you or about any other customers or former customers except as authorized by law, as described in this Privacy Notice or as otherwise communicated to you. We will not provide your non-public personal information to anyone outside of our Companies except as described above. We will notify you if we make any material change in this Privacy Notice. We may share selected financial information about you with our own affiliated companies in order to better serve you and to offer you worthwhile insurance products and services.

• Protection Of Your Insurance Information

Reasonable care will be taken to keep your records current, complete and accurate. If you see any inaccuracy in any information you receive from our office or insurance policy information, please contact us at the address shown below so that corrections may be made. We will protect all information collected about you, and we will restrict access to your non-public personal information by maintaining physical, electronic and procedural safeguards. Access will be restricted to only those individuals who must use it in the performance of their job-related duties.

• Our Policy Regarding Controversy or Claim

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

• · Reservation Of The Right To Disclose Information In Unforeseen Circumstances

In connection with the potential sale or transfer of its interests, Capax-Giddings, Corby, Hynes, Inc. reserve the right to sell or transfer your information (including but not limited to your name, address, 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, product or service; (2) agrees to be Capax-Giddings, Corby, Hynes, Inc.’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.

Explanation of opt out rights: If you do not want us to attempt to obtain better coverage or better prices from a different insurance company when your current policy comes up for renewal, you may tell us now. By “opting out”, you instruct us not to share or disclose any personal information with other insurance companies for the purpose of obtaining renewal quotations. You may opt-out at any time by sending us a written request. Even if you opt-out, we may still disclose information as allowed by law.

FEES/COMMISSION DISCLOSURE

Giddings, Corby, Hynes, Inc. primarily receives compensation through standard commissions it receives from various insurance companies providing coverage. Standard commissions are based on the commission schedules developed by each insurance company and calculated as a percentage of the premium.

Giddings, Corby, Hynes, Inc. and/or Value Services, Inc. may receive service fees. Where such fees are charged, they will be specifically negotiated and disclosed in the insurance proposal, finance agreement and/or billing statement.

Giddings, Corby, Hynes, Inc. may or may not also receive additional compensation including contingent commissions and other awards and bonuses, from the insurer. Such compensation, which is not client-specific, is based on a variety of prior year factors that may include volume, profitability, growth, retention or other performance measures established by the insurers with whom we do business.