Financial Privacy Notice

Our Policy Regarding Privacy of Your Financial Information Privacy Overview as Related to Customers

The Oxford Life^® Family of Companies^* values the trust and confidence that you, our customer, have placed with us. We are dedicated to the responsible management and protection of your personal information. We collect personal information in order to serve our customers and to administer our business. Customers are defined as those individuals with whom we have entered into a continuing relationship, such as when an insurance policy is purchased.

This notice explains our Privacy Policy with respect to the collecting and disclosure of your personal information.

Personal information means information that identifies an individual personally and is not otherwise available to the public. This includes personal financial information such as, credit history, income, financial benefits, policy or claim information. Personal health information such as individual medical records or information relating to an illness, injury or disability would also be considered to be personal information.

Personal information may be obtained from the customer, from customer-related transactions and from third parties such as a consumer-reporting agency. We also may collect personal information such as name, address, income, payment history or credit history from applications or transactions.

We may share personal information with our affiliates, including agents, insurance brokerage companies and third party administrators.

In order to serve our customers and to efficiently administer our business, we may share personal information with unaffiliated third parties. These third parties may include software companies, agents, insurance brokerage companies, service providers and administrators and other parties as permitted or required by law. We may also share personal information with other unaffiliated third parties who are working with us by marketing our products or services or offering our products or services under a joint agreement between us and one or more companies.

Before sharing personal financial information with unaffiliated third parties, other than as described in this notice, we will give affected customers an opportunity to let us know that such information should not be disclosed.

We may disclose personal health information only with proper written authorization or as otherwise allowed or required by law.

Our employees have access to personal information while performing their jobs. This includes paying claims, underwriting, advising customers about our products or services and while developing new products.

We use both manual and electronic security measures to protect the confidentiality and integrity of personal information and to guard against unauthorized access to it. Security techniques we use include, but are not limited to, user authentication, encryption, computer firewall protection, locked files and detection software programming.

We are responsible for identifying the information that must be safeguarded, providing the necessary protection for the data and allowing access to such data only to those who must use it while performing their jobs. Our Privacy Policy is very important to us, as it protects you, our customer. Any employee who violates our Privacy Policy will be subject to disciplinary action.

We will continue to follow this policy with respect to personal information even after a customer relationship has ended.

We will notify our customers of our Privacy Policy at the start of our business relationship and then on an annual basis. Our Privacy Policy is subject to change at any time. We will notify our customers of any changes at least annually.

Online (Website) Privacy

When you use our website, we do not gather any non-public personal information. We do track number of visitors without any retention of personal data. When you send us an e-mail, we do gather the data you provide as contained in the e-mail. Such data is available only on a limited basis, and only to those individuals whose responsibilities include processing and responding to such e-mails.

^* The Oxford Life^® Family of Companies includes: Oxford Life Insurance Company^®; Dallas General Life Insurance Company^™; North American Insurance Company^™; Christian Fidelity Life Insurance Company^® and Oxford Life^® as the third party administrator for Medicare supplement insurance policies issued by Celtic Insurance Company or USAble.