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The Guardian Corporate Family2 ("Guardian") culture is based on an unwavering belief in integrity and fair dealing. We take pride in treating our customers and each other with dignity and respect. Protecting our customers' personal information is very important to us. We want you to know how we collect, use, safeguard and permit access to your customer personal information.
If you own more than one product, you may receive multiple copies of this statement. If you decide to opt out, you need only respond once.
Customer Personal Information We Collect
Information we collect will be different for each of the products or services we provide to you. There are four types of customer personal information we collect:
- Information we get from you on applications or other forms, such as your name, address, date of birth, phone number, and e-mail address;
- Information such as your policy coverage, premiums, payment history, investment transfers and account balances that we get about your transactions with us, our affiliates (i.e., companies related to us by common ownership or control) and non-affiliates;
- Credit related information such as your creditworthiness and credit history that we get about you from credit reporting agencies and other companies we work with, and from companies who give us marketing information;
- Information from online forms that you fill out on Guardian Corporate Family Web sites3 and from online information collecting devices.

How We Use Your Customer Information
Guardian asks for only the customer personal information necessary to deliver superior products and services to you. This information is used to provide you with the product or service you have applied for, to offer you additional products and services, to evaluate and pay claims for benefits, and to assist in managing your accounts.
Our Information Sharing Practices
This is how we may disclose the four types of customer information:
Within The Guardian Corporate Family

- We may share information about you with our affiliates in order to process your application or claim, administer your account, provide you with a service you ask for, or to administer our business.
- We may share your information with our affiliates to give you information about other products and services that may be of interest to you, under joint agreement with one or more financial institutions where applicable. To do this, we develop marketing programs for ourselves and our affiliates based on information you give to us in your application, from other forms, and in surveys.
- We may use that information along with non-credit information from outside sources, to develop marketing programs. The products and service offers are developed under strict conditions designed to safeguard the privacy of your information.
- We may also share your credit information with our affiliates about our transactions and experiences with you (such as your account balance and payment history). You may tell us not to share other credit information such as credit history, information shown on consumer credit reports, and income and asset information with our affiliates except as permitted by law. To find out how to do this, please read the "Opt Out" section at the end of this statement.
- We may also share your information with your agent, broker or representative. If your agent, broker or representative is a Guardian agent, broker or representative, he or she is bound by agency contract and our rules to abide by the Guardian corporate privacy policy. Your agent, broker or representative may use your information to service your existing policy, account or contract; provide a service requested by you or to offer you additional products and services.

Outside the Guardian Corporate Family

- We may share information about you with non-affiliates (companies or persons that are not related to us by common ownership or control) in order to process your application or claim, administer your account, provide you with a service you ask for, or to administer our business. We require these non-affiliates to keep your information confidential.
- We may also share customer information with non-affiliates such as broker-dealers, fiduciary service providers, and non-financial service companies to send you information about other products and services that you may want to buy, under joint agreement between Guardian and one or more financial institutions where applicable. We try to offer this information only to customers who may benefit from them. To do this, we develop marketing programs for ourselves and our affiliates based on information you provide in your application, on other forms, and in surveys. We may give customer information to other financial companies with which we have joint marketing agreements. We may also use that information, along with non-credit information from external sources, to develop marketing programs.
The programs that bring you product and service offers are carefully designed to safeguard the privacy of your information. We require these non-affiliates to keep your information confidential. Please see the "Opt Out" section on how to be excluded from certain types of non-affiliate disclosures.
- We may also share your information if the law permits or requires us to do so. (e.g. government agencies, self-regulatory agencies, or in response to a subpoena).

Health4 Information Confidentiality

- If the product you apply for requires that we get health information about you, we ask you to complete a separate authorization as part of the application process. We will not disclose your health information to anyone without your authorization unless the law permits or requires us to do so.
- Our contractual relationships with health care providers, as well as state and federal laws require the providers to keep your information confidential.
- Guardian (including its affiliates and authorized agents), participating health care providers and payers (including selffunded employers) require access to group plan members' medical information for a number of necessary reasons. These reasons include underwriting, claims payment, fraud prevention, case management programs, delivery of care, quality assessment, utilization review, complying with state and federal requirements, data collection and reporting, accreditation, and statistical research. The authorization you sign, and federal and state laws, permit these disclosures.

Former Customers
If you decide to end your relationship with a member of the Guardian Corporate Family or if your account or policy becomes inactive for some other reason, we will continue to treat and safeguard your information as described in this statement.
Confidentiality and Security
Guardian uses strict standards of security and confidentiality to protect customer personal information that we have about you. Only employees who are trained in the proper handling of your information and who must have that information to perform their jobs will be allowed to see and use your information. We have physical, electronic, and procedural safeguards that comply with applicable federal and state regulations to keep your personal information safe.
Your Rights
- Guardian will send you a copy of our privacy statement at least once each year for as long as you are our customer.
- We will tell you how you may advise us not to send you offers for additional products or services from non-affiliates. Customers can contact Guardian at any time to opt out. Customers may also revoke their opt out at any time.
- We will work to maintain complete and accurate information about you and your accounts. Should you ever believe that our records contain inaccurate or incomplete information about you, please write to us. You may ask Guardian to update, correct or delete information that you believe is incorrect or incomplete. Guardian will promptly investigate your request and take steps to correct any wrong information.
- To contact Guardian write to: Guardian Corporate Family Privacy Office, The Guardian Life Insurance Company of America, P.O. Box 780, Cooper Station, New York, NY, 10276-0780 or call 1-800-441-6455.
Opt Out

- If you would like to continue to receive information regarding additional products and services, no action is necessary at this time.
- If you do not want us to disclose your personal information to non-affiliates you can tell Guardian not to make those disclosures ("opt out"), other than disclosures permitted by law. If you want information shared between Guardian affiliates to be limited to transaction and experience information and not other credit-related information, you may opt out. To opt out of disclosures, please complete the "Opt Out Disclosure Card" (below) and detach and send it to the Guardian Corporate Family Privacy Office, The Guardian Life Insurance Company of America, P.O. Box 780, Cooper Station, New York, NY, 10276-0780. You can also call toll-free from a touch-tone telephone to opt out at 1-866-246-5292. If you would like to opt out by telephone, it is necessary to enter your social security number using
a touch tone phone. If you would prefer not to enter your social security number, please submit your opt out by mail.

Please note: If you have opted out last year you do not need to do so again.
This notice is being sent to individual customers of the Guardian Corporate Family and group plan sponsors only. (Group plans are plans of coverage in which one or more individuals are covered under a group policy or contract at group rates). If you are an individual customer of the Guardian Corporate Family, all opt out provisions are addressed to you. If you are a group plan sponsor, the opt out provisions do not apply to you or individuals in your group. Guardian does not share individual group plan participant information with non-affiliates except as necessary to facilitate the group policy transaction. Therefore, the "opt out" provisions do not apply to group plans.
FAQ

- Why is the Guardian Corporate Privacy Statement being sent to me?
This notice is being sent to you because the federal law requires that we send you a copy of our corporate privacy statement each year. This notice does not constitute a change in Guardian's privacy protection standards.
- Have Guardian's practices changed with respect to protecting my personal information?
No. This notice describes the practices that are permitted by law, Guardian's privacy protection standards and practices are more restrictive than what the law permits.
- I have received several copies of the Corporate Privacy Statement. Do I have to opt out more than once?
No. If you own more than one Guardian product, you may receive more than one notice at this time. However, if you opt out one time, it will be entered into a centralized database, which is accessed by all business lines; therefore, all products and services will respect your opt out request.
- I am a group plan sponsor, should I opt out for plan participants?
No. The law requires us to send a group plan sponsor a copy of our corporate privacy statement. Group plan participant information will not be shared among affiliates or non-affiliated companies. Therefore, opt out provisions do not apply to group planholders or group plan participants.

1 The practices and policies contained in this privacy statement are subject to change. We will communicate any material change to you when required by applicable law. The practices and policies contained in this privacy statement replace all previous statements on the same subject matter.
2 The Guardian Corporate Family includes the following affiliated companies:
* The Guardian Life Insurance Company of America, Berkshire Life Insurance Company of America, First Commonwealth, Inc., Corporate Financial Services, Inc., Guardian Asset Management Corporation, The Guardian Insurance and Annuity Company, Inc., The Guardian Trust Company, FSB, Innovative Underwriters Inc., Family Service Life Insurance Company, Inc., Sentinel American Life Insurance Company, Guardian Investor Services LLC, Guardian Baillie Gifford Limited, Managed Dental Care of California, Park Avenue Life Insurance Company, Managed DentalGuard, Inc. (Texas), RS Investment Trust series funds, RS Variable Products Trust, series funds. This statement also represents Guardian Corporate Family privacy practices with joint venture partners, including but not limited to, HealthNet,
One Health Plan, Choice Guard, DentalGuard Preferred and DentalGuard Preferred Select.

3 Our websites, including www.GuardianLife.com and www.theberkshire.com, provide information regarding insurance and financial products and services, they are not intended for children. If we become aware that information is or has been submitted or collected from a child under the age of thirteen, we will delete this information.
4 Health information means any information or data except age or gender that relates to the past, present or future physical, mental or behavioral health or condition of an individual or a member of the individual&s family; the provision of health care to an individual; or payment for the provision of health care to an individual.

5 In the course of providing products and services to our customers, we collect and retain a customer's social security number for identification purposes and to comply with federal tax reporting requirements. We do not sell social security numbers or lists of social security numbers. We ask you to disclose your social security number to help us process your opt out request. We have found that when a customer's social security number is provided, fulfillment of the opt out request is expedited. However, you are not required to disclose your social security number on the opt out request form. In the alternative, we ask that you provide the account number for one of the products that you own. Your opt out request will be honored whether or not you include your social
security number on the opt out request form.
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