Hoch Insurance Group - Notice of Privacy Policy

(as of November 1, 2002)

At Hoch Insurance Group, protecting your privacy is very important to us. We recognize that our relationships with current and prospective clients are based on integrity and trust. We work hard to maintain your privacy and are very careful to preserve the private nature of our relationship with you. At the same time, the very nature of our business sometimes requires that we collect or share certain information about you with other organizations or companies. Therefore, we want you to be aware of how we handle personal information.

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 notice, which acquaints you of the privacy policies and practices of the Hoch Insurance Group and its affiliated companies (hereafter referred to as "Hoch Insurance Group" or "HIG"). Our "affiliates" are companies with which we share common ownership and which offer property and casualty, life and health, benefits, and investment products. For a complete list of Hoch Insurance Group affiliated companies, please see the section titled, "Hoch Insurance Group Family of Companies."

The Hoch Insurance Group and its affiliated companies do not and will not sell or share nonpublic personal information about you with any non-affiliated third party for any purpose unless you authorize it or it is otherwise permitted by law.

OUR PRIVACY POLICIES AND PRACTICES

1. Information we collect:

We collect nonpublic personal information about you from various sources to help serve your financial and insurance needs, provide customer service, offer new products or services, and fulfill legal and regulatory requirements. The type of information that HIG collects varies according to the products or services you request, and may include:

? Information we receive from you on applications, interviews, or by other means (such as name, address, Social Security number, assets and income);

? Information about your transactions with us, our affiliates or others (such as products or services purchased, account balances and payment history);

? Information from your employer, benefit plan sponsor, or association for any insurance product you may purchase through HIG (such as name, address, Social Security number, age and marital status);

? Information we receive from a consumer reporting agency (such as credit relationships and history);

? Information from other non-HIG sources (such as motor vehicle reports, medical information, and demographic information);

? Information from visitors to HIG websites (such as that provided through online forms, site visitor data and online information collecting devices known as "cookies").

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:

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.

Any medical or health information we collect about you will be disclosed to third parties only to underwrite insurance or administer your policy or claim, as permitted by law or as authorized by you.

3. Nonaffiliated third parties to whom disclosures may be made:

We may disclose nonpublic personal information about you, such as we have described above, to the following types of third parties that perform marketing services on our behalf or with whom we have joint marketing agreements:

? Fulfillment service providers, such as envelope stuffing services;

? Financial institutions with whom we have joint marketing agreements, such as insurance companies, agencies and brokerages; and

? Non-Financial Institutions with whom we have joint marketing agreements or who may be performing services or functions on our behalf, such as trade associations and affinity groups.

These disclosures will be made only to the extent permitted by law.

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

4. Affiliates with whom we share certain information protected by the Fair Credit Reporting Act, unless you tell us not to:

A. Categories of Information We Disclose to Affiliated Companies:

We may disclose the following kinds of nonpublic personal information about you to our affiliates:

? Information we receive from you on applications or other forms, such as name, address and Social Security number, and information we may receive from you in connection with investment and insurance products, such as your assets and income;

? Information about your transactions with us, our affiliates or others, such as types of insurance and investments you have through us, your policy information, payment history, and parties to the transaction; and

? Information we receive from consumer reporting agencies and other agencies, such as your creditworthiness, credit history and motor vehicle reports.

We disclose this information to our affiliates for a number of reasons, such as to assist us in administering your insurance and investments or to identify products or services our affiliates may offer that may be of interest to you. Our affiliates observe the same practices we do to protect the privacy of information about you.

B. Categories of Affiliates to Whom We Disclose Information:

We may disclose nonpublic personal information about you to the following types of our affiliated companies: financial service providers such as our insurance agency and brokerage companies, our insurance agents and brokers, and our registered securities broker-dealer.

C. Your rights Concerning Certain Information We Disclose to Our Affiliates:

Under the Fair Credit Reporting Act, you may exercise your right to opt out of Hoch Insurance Group's sharing of non-transactional information about you with HIG affiliates. HIG may share other information about you with its affiliates as permitted by law. If you prefer that HIG not share non-transactional information about you with HIG affiliates as provided under the Fair Credit Reporting Act, then you may direct us not to share this information by writing us at Hoch Insurance Group, 209 E. Washington Center Road, Fort Wayne, IN 46825 and siimply state, "I wish to exercise my right under the Fair Credit Reporting Act to opt out of Hoch Insurance Group's sharing of non-transactional information about me with HIG affiliates." We will honor your request.

5. Our practices regarding information confidentiality and security:

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.

6. Our policy regarding dispute resolution:

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.

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

In connection with the potential sale or transfer of its interests, HIG and its affiliates 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 HIG'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.

8. HIG Internet Privacy Policy - Information collected in connection with Web Store and Credit Card Transactions:

At HIG our commitment to protect your privacy includes your Internet purchasing activities. Our privacy policies are the same whether you access information about our products or services through our web sites or through a traditional commercial method.

A. Credit Card Transactions:

Credit card transactions may be processed through Allfirst Bank directly or via First Data Systems whose privacy policies are located at http://www.allfirst.com/legal/privacy_statement.html and http://www.firstdata.com/100.jsp, respectively. Allfirst Bank and First Data Systems, a professional payment authorization service, were selected for added security of your credit card transactions. Information collected during transactions may be maintained in their respective databases for accounting and billing purposes. Information from these transactions is not released to third party marketers by the HIG affiliated company executing the point of sale credit transaction. You will also not receive any solicitations or advertisements from the HIG affiliated company in the future other than: confirmation of your order; clarifications of orders; notice that the order has been shipped; and other communications directly to you regarding the requested transaction.

B. Protecting Children's Privacy Online

We respect the privacy of your children, and we comply with the practices established under the Children's Online Privacy Protection Act. We do not knowingly solicit data from children nor do we market to them through our web sites. We do not attempt to collect personal information from children. If children do send personal information to a HIG affiliated company, such as writing to Santa, sending e-mail, etc., the information is deleted. Note that HIG cannot always determine that a user is a child. HIG affiliated companies do not maintain databases of children or adults.

C. A Word about Cookies:

A HIG affiliated company web store uses "session" cookies that expire in about 60 minutes. They are used so a user can shop and maintain a list of items ordered in their "shopping cart" and have a total due calculated. A user does not have to supply any personal information unless they decide to complete an order. Orders can also be printed and paid by mail or fax without entering any credit card information.

When visiting any Internet site your unique address called an "IP address" is recorded. HIG affiliated companies do not release any information about the collection of this address to any third party unless you give permission first or we are required to disclose it by order of a court. HIG archives the log files in order to create aggregate statistical reports, detect errors at the web site, and for security reasons. The log files are eventually deleted.

No Images, files, or cookies are downloaded from third party servers. This means no banner networks, "hidden" images of size lx1 pixel, etc.

Note that information such as credit card number and mailing address are only maintained for a period of time necessary for bookkeeping and tax purposes. This information is automatically deleted after a period of time. No other databases are maintained. HIG does not send out advertisements to former customers or sell/release lists of former customers.

The restrictions on the dissemination of personal information contained in this policy are subject to change, however, policy changes will not lessen the privacy protection of visitors. If changes are made to this privacy policy in the future the changes will not affect information previously collected. Any such changes will be posted to this web site.

Hoch Insurance Group Family of Companies:

This Notice is being provided on behalf of the following Hoch Insurance Group affiliates:

The Hoch Agency, Inc.
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* Securities Products offered through Hoch Financial Services, Inc. - Member NASD