PRIVACY OF CONSUMER AND CUSTOMER INFORMATION

The Mutual Capital Group, Inc. (formerly known as Tuscarora Wayne Mutual Group Inc.), Tuscarora Wayne Insurance Company and the other members of its group of affiliated companies, Lebanon Valley Insurance Company, Keystone National Insurance Company, and the Tuscarora Wayne Mutual Foundation (collectively, “TW” or “us” or “we”) recognize that the personal privacy of consumers and customers is very important. Whether an individual is already our customer or policyholder or is a consumer applying for insurance with one of our companies, maintaining the confidentiality of the non-public personal information (that is, information that can used to identify an individual consumer or customer) is a priority.

WHO THIS POLICY APPLIES APPLY TO

This privacy policy applies to applicants for our policies, our policyholders, and to claimants or beneficiaries under insurance products or services obtained from us, primarily for personal, family or household purposes.

This privacy policy does not apply to products or services obtained for business, commercial or agricultural purposes.

HOW TW COLLECTS AND USES PERSONAL INFORMATION

We may gather public and non-public personal information from a variety of sources.

We may gather information including:

• name, address, social security number
• income information
• account balances, premiums and payment history
• bank account and routing numbers and other bank information, if you choose to make payments by certain types of electronic funds transfer
• other information about the insured and the insured’s property

We may gather this information from:

• you when you provide it
• applications or other forms completed (paper or on-line),
• information provided by agents,
• other members of our affiliated group of companies,
• consumer reporting agencies and credit bureaus
• property inspection services
• other sources

We collect and use non-public personal information as necessary to meet our customers’ insurance needs, to process certain types of payments, and to provide quality service.

ACCESS TO PERSONAL INFORMATION

• We have security practices and procedures in place to protect the confidentiality of non-public personal information in accordance with this privacy policy.  Only authorized employees are given access to non-public personal information. “Authorized employees” means employees who we determine need access to that information to provide consumers and customers with our products and services.

SHARING NON-PUBLIC PERSONAL INFORMATION

We reserve the right to disclose all non-public personal information we collect to the extent permitted or required by law. For example, our disclosure of non-public personal information may include disclosure:

• required by statues, regulations, court orders, subpoenas or other similar legal process
• as necessary to perform our underwriting review for an applicant for insurance (such as performing a credit check, having a property inspected, etc.)
• as necessary to service a customer’s policy, collect payments,  or effect a customer- requested transaction
• to other affiliated and non-affiliated parties as permitted by law

For example, we may disclose information about customers and consumers to the following types of third parties:

• Our affiliated companies
• Your agent or broker
• Parties who perform a business, professional or insurance function for us, including our reinsurance companies
• Independent claims adjusters, appraisers, investigators and attorneys who need the information to investigate, defend or settle a claim involving you
• Businesses that help us with data processing or marketing
• Businesses that conduct scientific research, including actuarial or underwriting studies
• Other insurance companies, agents or consumer reporting agencies as reasonably necessary in connection with any application, policy or claim involving you
• Insurance support organizations, which are established to collect information for the purpose of detecting and preventing insurance crimes of fraudulent claims
• Medical care institutions or medical professionals to verify coverage or conduct an audit of services
• Insurance regulatory agencies in connection with the regulation of our business
• Law enforcement or other governmental authorities to protect our legal interests or in cases of suspected fraud or illegal activities
• Authorized persons as ordered by a subpoena, warrant or other court order or as required by law
• Certificate holders or policyholders for the purpose of providing information regarding the status of an insurance transaction
• Lienholders, mortgagees, lessors or other persons shown on our records as having a legal or beneficial interest in your policy

We will disclose non-public personal information to non-affiliated third parties only upon the agreement by that party to use the information only for the purpose for which it is disclosed.

OPTING OUT FROM DISCLOSURE

Under certain circumstances, if we wish to disclose a consumer’s information to a third party that is not our affiliate, we are required by law to provide the consumer with an option to direct us not to share the consumer’s information.  That is called “opting out.” If we must permit a consumer to opt out of any proposed disclosure of a consumer’s information, we will give the consumer an initial privacy notice, a notice of the consumer’s right to opt out, and a reasonable opportunity to exercise the right to opt out before we make the disclosure.

DISCLOSURES UNDER THE FAIR CREDIT REPORTING ACT

PERSONAL INFORMATION ABOUT YOU, INCLUDING INFORMATION FROM A CREDIT OR OTHER INVESTIGATIVE REPORT, MAY BE COLLECTED FROM PERSONS OTHER THAN YOU IN CONNECTION WITH THIS APPLICATION FOR INSURANCE AND SUBSEQUENT AMENDMENTS AND RENEWALS. SUCH INFORMATION AS WELL AS OTHER PERSONAL AND PRIVILEGED INFORMATION COLLECTED BY US OR OUR AGENTS MAY IN CERTAIN CIRCUMSTANCES BE DISCLOSED TO THIRD PARTIES WITHOUT YOUR AUTHORIZATION. CREDIT SCORING INFORMATION MAY BE USED TO HELP DETERMINE EITHER YOUR ELIGIBILITY FOR INSURANCE OR THE PREMIUM YOU WILL BE CHARGED. WE MAY USE A THIRD PARTY IN CONNECTION WITH THE DEVELOPMENT OF YOUR SCORE. YOU MAY HAVE THE RIGHT TO REVIEW YOUR PERSONAL INFORMATION IN OUR FILES AND REQUEST CORRECTION OF ANY INACCURACIES. YOU MAY ALSO HAVE THE RIGHT TO REQUEST IN WRITING THAT WE CONSIDER EXTRAORDINARY LIFE CIRCUMSTANCES IN CONNECTION WITH THE DEVELOPMENT OF YOUR CREDIT SCORE.  THESE RIGHTS MAY BE LIMITED IN SOME STATES. PLEASE CONTACT YOUR AGENT OR BROKER TO LEARN HOW THESE RIGHTS MAY APPLY IN YOUR STATE OR FOR INSTRUCTIONS ON HOW TO SUBMIT A REQUEST TO US FOR A MORE DETAILED DESCRIPTION OF YOUR RIGHTS AND OUR PRACTICES REGARDING PERSONAL INFORMATION.

WHEN NOTICE OF THIS POLICY WILL BE PROVIDED?

Notice of this privacy policy will be provided to our customers not less than annually.

POLICY REVISIONS

We reserve the right to change this policy at any time.  If we make material changes, we will post them on this web site, and provide you with other notice as required by applicable law.

STATE SPECIFIC PROVISIONS

For Vermont Residents.  We will not share your information with our affiliates or others for marketing purposes without your consent.