MidCountry Financial Corp. Consumer Privacy Policy

The MidCountry family of companies ("MidCountry") believes customer privacy is a cornerstone of our business. We greatly appreciate your business and the trust that you and others have placed in us. We strive to meet your financial needs while handling the information you provide us in a private, professional manner.

This Notice is provided on behalf of certain specific companies within the MidCountry Corporate Family (which may not be all of the MidCountry Corporate Family members with whom information about you may be shared as described in this notice). Those specific companies are:

The terms we, our, and us, when used in this notice, mean MidCountry Financial Corp. and its affiliates listed above. We are providing you with the Privacy Policy to explain how MidCountry protects and uses your personal information when and after you apply for, or obtain, financial products or services for personal, family, or household purposes. Examples of financial products or services used for personal, family, or household use are: loan accounts, deposit accounts, safe deposit boxes, IRAs, investment services, and insurance services.

This notice establishes the type of information we collect about you; with whom we share it and the measures we take to protect that information. The notice explains your rights and how you can exercise them. If you share an account relationship with someone else, such as a joint account holder or co-borrower, we suggest that you share this information with them to ensure that each of you is aware of our policy and your options.

First, we define some terms
Nonpublic personal information means information about you that we collect in connection with providing a financial product or service to you. Nonpublic personal information does not include information that is available from public sources, such as telephone directories or government records. We will use the term "information" to mean nonpublic personal information as defined in this section.

An affiliate is a company we own or control, a company that owns or controls us, or a company that is owned or controlled by the same company that owns or controls us.

A nonaffiliated third party is a person we do not employ or a company that is not an affiliate of ours. This is also known as an "other party."

Opt out means a choice you can make to prevent certain sharing of information. We will explain how you can exercise this choice below.

The information we collect
To provide you products and services that fit your needs, to comply with government regulations, and to better understand how we may assist you, we collect information about you, including nonpublic personal information. The nonpublic personal information we collect and disclose varies depending on the products and services you request and use. We collect information about you from the following sources:

• Information you give us on applications or other forms and other oral, written, or electronic communications
• Information about your transactions with us, such as account balance and payment history
• Information we receive from third parties, including consumer reporting agencies and persons providing services in connection with your transactions, such as appraisers and checking account verification companies, and in the case of insurance services, driving records and medical information
• Information we receive from an allotment-processing bank, such as allotment authorization information
• Information collected from our Internet websites, such as information you provide to us, and information necessary to manage your online session with us
• Information about your transactions with other parties to verify information provided by you, such as your income and employment history

The confidentiality, security, and integrity of your information are important to us
We restrict access to information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to protect this information. Our employees are also bound by our Code of Conduct which requires confidentiality and restricts access to information for legitimate business purposes only.

We may disclose information about you to our affiliates
By sharing nonpublic personal information with our affiliated companies we are able to provide you the highest level of customer service. The sharing of such information provides us with a complete and integrated knowledge of your full relationship with MidCountry and helps us detect and take measures to prevent potentially unusual account activity, unauthorized transactions, and fraudulent activity, and provide you the best price your relationship deserves. The MidCountry family of companies provides a variety of services, such as investment and insurance products, loans, leases, and deposit accounts.

Under applicable law, we are permitted to share your name, address, and facts about your transactions and experience with us (such as account balance, payment history, and other transactions on your accounts including types of insurance) among our affiliated companies. During the normal course of doing business, we will share such transaction and experience information among our affiliated companies to service your accounts and better meet your financial needs. Also, as a matter of normal business practice, we sell loans among our affiliate companies. You do not have a right to opt out of the disclosure of this information.

Other information we may share with our affiliates that are not taken from transactions and experiences:

• Information you provide us on an application or other forms, such as assets and income
• Information we receive from a credit reporting agency such as credit history and public records

You may opt out of the disclosure of the information listed directly above. Please see the information below which describes how to opt out of this information sharing among our affiliates.

Disclosure of information to third parties
We do not sell or disclose information about you to companies outside of the MidCountry Family, except as required or permitted by law. As an example, we are allowed to disclose information about you to:

• Credit reporting agencies, check printers, and other third parties which assist us in servicing your account(s) with us
• Financial service providers, such as allotment processing banks, payment processors, and insurance companies
• Government entities in response to subpoenas or other governmental information requests
• Financial institutions for the purpose of jointly offering financial products and services to you such as credit insurance
• Companies that perform marketing services on our behalf

Any such third party will be prohibited by a contractual agreement from disclosing or using the nonpublic personal information except as necessary in the ordinary course of business.

If you close your accounts or your relationship becomes inactive, we will continue to treat the information we have collected about you in accordance with this notice.

Insurance providers
Please note that insurance companies issuing your policies maintain personal information about you. Our privacy notice does not govern their use of information about you. You should review the privacy notices of your insurance providers to understand how they collect, use, and disclose information.

Other privacy protections
You may have other privacy protections under some state laws. We will comply with applicable state laws as to information about you. For example, certain state laws may restrict the types of information we may disclose about you or require us to provide you with an additional notice.

We will not use or share personally identifiable medical information for any purpose other than the underwriting or administration of your insurance account, policy, or claim, unless otherwise required or permitted by law.

Other information collectors
Our Internet sites may include links to the sites of our business partners or others. The privacy policies and customs of those sites may be different from ours. To the extent that you disclose your information to other parties or sites, you are subject to the privacy policies and customs of those parties or sites. We cannot be sure whether any third parties linked to or through our site have privacy policies similar to ours. Therefore, we cannot be responsible for the content or the privacy practices employed by anyone else.

Protecting children's information privacy
The online financial services offered through MidCountry Internet sites are not designed for, or directed toward, persons under age 18. We do not knowingly solicit or collect data from children, and we do not knowingly market to children online. We recognize that protecting children's identities and online privacy is important and that responsibility rests with us and with parents.

Notifying us of inaccurate information reported to consumer reporting agencies
Please notify us if you believe that we may have reported any inaccurate information about your accounts to consumer reporting agencies. Such notices are to be in writing and should include your complete name, current address, social security number, telephone number, account number, specific item of dispute, and why you believe the information reported is in error. Send your notice to
Pioneer Financial Services, Inc., 4700 Belleview Suite 300, Kansas City, MO 64112.

You may tell us not to share your information within the MidCountry Family (Opt Out)
We may disclose information about our transactions and experiences with you to affiliates. You do not have the right to opt out of the disclosure of this information. We may also disclose other information to our affiliates (that is, information beyond our transactions and experiences with you, such as information from applications and from a credit bureau), unless you tell us not to disclose this other information. Your decision to block the disclosure of your information will apply to information collected from all products and services you receive from us.

You may limit our affiliates in the MidCountry Family, as listed above, from marketing their products or services to you based on your personal information that we collect and share with them.  This information includes your income, your account history with us, and your credit score.  Your choice to limit marketing offers from our affiliates will apply until you tell us to remove your opt out.

If you have obtained one or more products or services jointly, an opt out instruction by any party will be effective for all of that party's information we have collected and for all information collected in conjunction with the product or service for all other joint parties. If one of you chooses to opt out, no information we have collected about you will be shared (unless allowed or required by law), nor will we share information about any other joint party collected in conjunction with the product or service.

If you have already sent us an opt out, then we will continue to apply your instructions. You do not need to return another opt out form.

If you wish to opt out of the disclosure of your information and limit marketing offers, you may do so by calling 1-800-962-4233.