Privacy Policy Notice

The IMA Financial Group, Inc.
(Compensation Disclosure | Terms of Use)

Effective July 1, 2001
Revised August 15, 2008

The IMA Financial Group, Inc. and its insurance brokerage subsidiaries, IMA, Inc., IMA of Kansas, Inc., IMA of Colorado, Inc., IMA of Texas, Inc., and Towerstone, Inc. (collectively referred to in this notice as “we”, “us”, or “our”) provide insurance brokerage services and sell insurance products and services to commercial businesses and to individuals for personal, family and household purposes. The IMA Financial Group, Inc. and all of its subsidiaries are collectively referred to in this notice as the "IMA Group". "You"/”Your Company” refers to each of our customers or prospects who may engage us to provide services for or on your behalf, such as placing your insurance and/or providing you with insurance risk management or consulting products and/or services, and as otherwise allowed or required by law.

WHY YOU ARE RECEIVING THIS PRIVACY POLICY NOTICE
Federal and state laws and regulations generally prohibit us from sharing nonpublic personal, financial or health information about you with a non-affiliated third party unless we provide you with a notice of our privacy policies and practices, such as the types of information that we collect about you and the categories of persons or entities to whom it may be disclosed. In compliance therewith, we are providing you this notice about our privacy policies and practices.

THE INFORMATION THAT WE COLLECT
We collect and maintain your information so we can provide insurance brokerage services and sell insurance products to you, as well as process your insurance claims. The types and categories of information we may collect about you includes:

• Information we receive from you on applications for insurance coverage and other forms to provide insurance brokerage services to you (such as your name, home address, social security, telephone number, financial information such as the fair market value of property you wish to insure, and health information);
  
• Information you authorize us to collect (such as health information for underwriting purposes) or information we are authorized or required by law to collect (such as medical records in a workers’ compensation case);
  
• Information that we generate to service your account (such as loss claim information);
  
• Information we receive from a consumer reporting agency such as motor vehicle and driver data, credit history, and employment information; and
  
• Information about your transactions with us and our affiliates such as your policy coverage, premium payment history, the premium you pay and claims information.

INFORMATION SHARING PRACTICES WITHIN THE IMA GROUP
We may share nonpublic information about you within the IMA Group, as permitted by law, to enable us to service and maintain your account and provide information to you about products and services of the IMA Group. IMA may collect data and other similar information of its customers and prospects and may use and share that data in our internal systems, such as sales management applications. These systems permit IMA employees to access and process such data solely for the purposes of customer request completion, business administration, business reporting, statistical analysis and marketing of IMA products and services. IMA may share the business contact data among its affiliates. The circumstances under which disclosure within the IMA Group is permitted by law include disclosure to our subsidiaries TrueNorth, Inc. and TrueNorth Securities, Inc. to provide information to you about those subsidiaries' investment management and securities brokerage services.

SHARING INFORMATION OUTSIDE THE IMA GROUP
We do not disclose any nonpublic information about you to non-affiliated third parties, except as permitted by law. The circumstances under which disclosure to non-affiliated third parties is permitted by law include disclosures to insurance companies or insurance intermediaries to obtain any insurance coverage requested by you or to process insurance claims. The circumstances under which disclosure to non-affiliated third parties is permitted by law also include to our auditors, appraisers and legal advisors, in response to a court order, governmental authorities pursuant to legal process, to prevent fraud, and/or disclosures to companies that perform marketing and other services for us, such as electronic enrollment service providers, to other financial institutions with which we have joint marketing agreements, such as banks, securities broker-dealers, registered investment advisors, and insurance providers.

HOW WE PROTECT YOUR INFORMATION
We take great care to ensure that your information is kept safe from unauthorized access. We diligently maintain physical, electronic and procedural safeguards that comply with applicable federal and state standards to guard your private information and to assist us in preventing unauthorized access to that information.

To fulfill our privacy commitment, we adhere to company-wide practices to safeguard the information we maintain about you. These include:

• Adopting policies and procedures that put in place physical, electronic and other safeguards to keep your personal information safe;
  
• Striving to maintain the accuracy of your information and promptly responding to any questions or concerns you may raise in its regard;
  
• Expecting third parties that perform services for us to follow the same standards to keep your information confidential;
  
• Protecting information of our former clients to the same extent as our current clients.
  

REQUESTS FOR YOUR INFORMATION
To the extent provided by applicable federal or state law, you may have certain rights to access and correct the information we have collected about you. Please contact the IMA Compliance Department at privacy.officer@imacorp.com for further information.

OUR POLICY REGARDING DISPUTE RESOLUTION
Any controversy or claim arising out of or relating to our privacy policy, or the breach of our privacy policy, 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.

RESERVATION OF RIGHT TO DISCLOSE INFORMATION IN UNFORESEEN CIRCUMSTANCES
In connection with the sale or potential sale or transfer of all or part of our company or its assets, we reserve the right to sell or transfer your information to a third party entity that (1) concentrates its business in a similar practice or service; (2) agrees to be our successor in interest with regard to the maintenance and protection of the information collected; and (3) agrees to the obligations of this privacy policy.

This notice is for information only. No reply is necessary.

© 2008 Towerstone, Inc. All rights reserved.