Privacy Notice

 

The Great-West Family of CompaniesSM

Great-West Life & Annuity Insurance Company

��� www.gwla.com

The Great-West Life Assurance Company

First Great-West Life & Annuity Insurance Company

Alta Health & Life Insurance Company

Advised Assets Group, Inc.

Alta Agency, Inc.

BenefitsCorp, Inc. �

BenefitsCorp Equities, Inc. �

BenefitsCorp, Inc. of Wyoming �

Deferred Comp of Michigan, Inc. �

FASCore, LLC.

Great-West Benefit Services, Inc.

Greenwood Investments, Inc.

GW Capital Management, LLC

GWL Properties Inc.

Maxim Series Fund, Inc.

National Plan Coordinators of Delaware, Inc. �

National Plan Coordinators of Ohio, Inc. �

National Plan Coordinators of Washington, Inc. �

NPC Administrative Services Corporation �

NPC Securities, Inc. �

One Benefits, Inc.*

One Health Plan, Inc.*

One Health Plan of Alaska, Inc. *

One Health Plan of Arizona, Inc. *

One Health Plan of California, Inc. *

One Health Plan of Colorado, Inc. *

One Health Plan of Florida, Inc. *

One Health Plan of Georgia, Inc.� *

One Health Plan of Illinois, Inc. *

One Health Plan of Indiana, Inc. *

One Health Plan of Kansas/Missouri, Inc.*

One Health Plan of Maine, Inc. *

One Health Plan of Massachusetts, Inc. *

One Health Plan of Michigan, Inc.*

One Health Plan of Minnesota, Inc.*

One Health Plan of Nevada, Inc. *

One Health Plan of New Hampshire, Inc. *

One Health Plan of New Jersey, Inc. *

One Health Plan of New York, Inc.*

One Health Plan of North Carolina, Inc. *

One Health Plan of Ohio, Inc. *

One Health Plan of Oregon, Inc. *

One Health Plan of Pennsylvania, Inc.*

One Health Plan of South Carolina, Inc. *

One Health Plan of Tennessee, Inc. *

One Health Plan of Texas, Inc. *

One Health Plan of Virginia, Inc.*

One Health Plan of Washington, Inc. *

One Health Plan of Wisconsin, Inc. *

One Health Plan of Wyoming, Inc. *

One of Arizona, Inc.*

One Orchard Equities, Inc.

Orchard Capital Management, LLC

Orchard Series Fund

Orchard Trust Company

P.C. Enrollment Services & Insurance Brokerage, Inc.�

 

� www.benefitscorp.com

* www.onehealthplan.com

 

The Great-West Family of CompaniesSM is committed to protecting the privacy of our customers both online and offline.� As a result, we have established policies and practices that respect the privacy of all our customers. We keep information about you confidential, but we may share information about you, as described below, with our affiliated companies, third parties with whom we do business and as otherwise permitted by law.

 

The Types of Information About You That We Collect.� In the ordinary course of business, we collect, retain and use information about you to administer your account(s) and benefits. This information, known as nonpublic personal information, is collected from several sources and includes: information we receive from you on applications or other forms (for example, name, Social Security number, address); information about your transactions with us, our affiliates and non-affiliated third parties (for example, information about your account balance, contributions, premiums); and, in some cases, information we receive from consumer reporting agencies and insurance reporting companies (for example, credit reports and health information).

 

Security of Your Information.� We have implemented strict procedures and policy guidelines to safeguard the privacy of your nonpublic personal information from unauthorized use or improper access. These guidelines include implementation of physical, electronic and procedural safeguards.�

 

Access to Information.� Access to customer information is authorized for business purposes only. We permit authorized employees who need to know such information to provide products or services to you or to conduct our business to have access to customer information.� Employees who have access to customer information are required to protect it and keep it confidential.� Employees who violate this policy will be subject to our disciplinary policies and procedures.

 

Our Information-sharing Practices.� We restrict the types of information about you that we share and the types of entities with whom we share it. The primary reason for sharing information about you is to provide you with more convenience and efficiency in transactions with us and to give you more choices about financial services and products. The type of information we collect varies according to the products or services you request, and may include information:

�          from your application and related forms (such as name, address, Social Security number, assets and income);

�          about your relationship with us (such as products or services purchased, account balances, payment histories);

�          from your employer, benefit plan sponsor, or association for any group product in which you may participate (such as name, address, Social Security number, age and marital status);

�          from consumer reporting agencies (such as credit relationships and history);

�          from other third party sources (such as health information and demographic information); and

�          from visitors to websites of the Great-West Family of CompaniesSM (such as that provided through online forms, site visitorship data and online information collecting devices known as �cookies�).

 

Sharing of Health Information. We will not share � internally or externally � personally identifiable health information about you for any purpose other than conducting our business, or as disclosed to you when the information is collected, or to which you consent.

 

Sharing Information with Affiliates. �The Great-West Family of CompaniesSM is made up of several companies. These companies are affiliated with one

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���������������������������������������������������� (Continued on Next Page)

The Great-West Family of CompaniesSM

Great-West Life & Annuity Insurance Company

��� www.gwla.com

The Great-West Life Assurance Company

First Great-West Life & Annuity Insurance Company

Alta Health & Life Insurance Company

Advised Assets Group, Inc.

Alta Agency, Inc.

BenefitsCorp, Inc. �

BenefitsCorp Equities, Inc. �

BenefitsCorp, Inc. of Wyoming �

Deferred Comp of Michigan, Inc. �

FASCore, LLC.

Great-West Benefit Services, Inc.

Greenwood Investments, Inc.

GW Capital Management, LLC

GWL Properties Inc.

Maxim Series Fund, Inc.

National Plan Coordinators of Delaware, Inc. �

National Plan Coordinators of Ohio, Inc. �

National Plan Coordinators of Washington, Inc. �

NPC Administrative Services Corporation �

NPC Securities, Inc. �

One Benefits, Inc.*

One Health Plan, Inc.*

One Health Plan of Alaska, Inc. *

One Health Plan of Arizona, Inc. *

One Health Plan of California, Inc. *

One Health Plan of Colorado, Inc. *

One Health Plan of Florida, Inc. *

One Health Plan of Georgia, Inc.� *

One Health Plan of Illinois, Inc. *

One Health Plan of Indiana, Inc. *

One Health Plan of Kansas/Missouri, Inc.*

One Health Plan of Maine, Inc. *

One Health Plan of Massachusetts, Inc. *

One Health Plan of Michigan, Inc.*

One Health Plan of Minnesota, Inc.*

One Health Plan of Nevada, Inc. *

One Health Plan of New Hampshire, Inc. *

One Health Plan of New Jersey, Inc. *

One Health Plan of New York, Inc.*

One Health Plan of North Carolina, Inc. *

One Health Plan of Ohio, Inc. *

One Health Plan of Oregon, Inc. *

One Health Plan of Pennsylvania, Inc.*

One Health Plan of South Carolina, Inc. *

One Health Plan of Tennessee, Inc. *

One Health Plan of Texas, Inc. *

One Health Plan of Virginia, Inc.*

One Health Plan of Washington, Inc. *

One Health Plan of Wisconsin, Inc. *

One Health Plan of Wyoming, Inc. *

One of Arizona, Inc.*

One Orchard Equities, Inc.

Orchard Capital Management, LLC

Orchard Series Fund

Orchard Trust Company

P.C. Enrollment Services & Insurance Brokerage, Inc.�

 

� www.benefitscorp.com

* www.onehealthplan.com

 

another and all are available to serve your financial services needs.� Sharing of your information with our affiliates, such as our securities broker-dealers, our registered investment advisers and mutual fund companies, our HMOs, insurance companies and agencies, and our trust company, enables us to serve you more efficiently and makes it more convenient for you to do business with us. We are permitted by law to share with our affiliates information about your benefits, account history and experiences with us, such as account balances, address and Social Security number. We may also share other types of information with our affiliates such as information we receive from you on applications or other forms, and, in some cases, information we received from a consumer reporting agency or other third party.

 

Sharing Information with Service Providers and Joint Marketers. We may disclose information about you to non-Great-West companies that perform services on our behalf or with whom we have joint-marketing agreements. For example, we may share information with:

�          companies that perform services for us or on our behalf (such as vendors we hire to respond to customer requests, to provide you with information about products or services, or to maintain or develop software for us); or

�          financial institutions (such as banks, insurance companies, securities brokers or dealers) and non-financial institutions (such as financial publications) with whom we have marketing agreements.

 

We require our service providers and those with whom we have joint-marketing agreements to adhere to similar and equally stringent polices concerning the privacy of your information. These companies may use and disclose the information provided to them by us only for the purposes for which it is provided or to the extent otherwise permitted by law.� Additionally, we may disclose information to non-affiliated third parties as allowed by law.� For example, we may disclose information in response to a subpoena, to prevent fraud, or to comply with an inquiry by a governmental agency or regulator.

 

Sharing Information with Other Third Parties.� We do not share your protected information with outside marketing agents.

 

Our Treatment of Information About Former Customers.� Our protection of your nonpublic personal information extends beyond the period of your customer relationship with us. If our customer relationship ends, we will not disclose your information to non-affiliated third parties other than as permitted by law.

 

Customer Access to Information.� If you would like to inquire about the personal information we have retained in our files or have any other questions concerning the privacy of the information we may have in our files about you, please contact the Privacy Officer at the address listed below and this information will be provided to you, subject to legal and ethical considerations.

 

Due to the rapid changes occurring in the financial services industry, we reserve the right to revise our privacy policy as necessary. If and when amendments are made to our privacy policy, we will send you a revised notice and will post the revised notice on the� www.gwla.com website and the websites of any member of the Great-West Family of Companies.

 

Privacy Officer

Great-West Life & Annuity Insurance Company

8525 E. Orchard Road

Greenwood Village, CO� 80111