We care about your privacy. We believe you have a right to know what we do with the information we gather about you in connection with the products you seek or have from us.

We also want to assure you that we are safeguarding this important information. Our privacy policy is based on the laws governing privacy and on our own high standards of protecting privacy.

We protect your non-public personal financial information and your health information (together called "NPI"). We do not sell your NPI. We do not share your NPI with companies outside of the Zurich family that would use the information to market their own products or services.

We need NPI about you so that we can determine your insurability and offer products and services to meet your specific needs at a fair price. We collect NPI about you from different sources including:

• Applications or other forms you complete that contain information such as your social security number, your assets and income, and your property information
• Medical professionals who have provided care to you and insurance support organizations regarding your health
• Telephone calls with you
• Data we collect when you visit our web sites
• Third parties that provide NPI to us with your authorization
• Your business dealings with us, our affiliates, and others
• Consumer reporting agencies, governmental agencies, and similar bodies.

We will share your NPI only with authorized employees, representatives, affiliates, and trusted third parties whose services are required to assure the highest level of service to you. Examples of third parties include medical exam providers, third party administrative staff, and reinsurers. We will not disclose NPI about you or about other customers or former customers, except as authorized by law, as described in this privacy statement, or as otherwise communicated to you.

Your financial NPI as well as the financial NPI of other customers and former customers may also be shared with financial institutions, securities broker-dealers, and insurance producers, but only in order to make our products and services available to you.

We may also share financial NPI about you or about other customers and former customers within the Zurich family of companies in order to better serve you and offer you worthwhile products and services. These affiliates may include: life insurers, property and casualty insurers, securities broker-dealers, and insurance producers. The law allows us to share your financial information with our affiliates to market products or services to you. You cannot prevent those disclosures.

Examples of NPI that we may share include:

• NPI from your application or other forms, such as: your name, address, social security number, assets income, and beneficiaries
• NPI about your transactions with us, our affiliates or others, such as: your policy coverage, premiums, and payment history
• Health information
• Information from consumer reporting agencies, such as your credit history.

Important Note:

Your health NPI and information on your credit report will not be shared with our affiliates or third parties that would use the information to market their own products or services.

Disclosures of NPI are also permitted without your authorization for some purposes. These may include:

• To insurance companies, agents, support organizations, and others to: perform marketing or services on our behalf, or to detect or prevent criminal activity, fraud, or material non-disclosure in connection with insurance transactions
• To an insurance regulatory agency
• To a law enforcement or other governmental agency pursuant to law
• As otherwise permitted or required by law
• In response to a facially valid administrative or judicial order, including a subpoena
• As part of a proposed or consummated sale, transfer, merger, or consolidation of all or part of the business
• To an affiliate as described above
• To a customer or policyowner
• To an assignee of a policy under the terms of the assignment.

When state law is more protective of individuals than federal privacy laws, we will protect your NPI in accordance with state law, consistent with the requirements of federal preemption.

You have the right to view and correct any NPI we may collect about you. If you believe any of the information we have collected about you is wrong, we would welcome your help in making corrections. Please contact us as shown below if you wish to view or correct this information.

Please be aware that information obtained from a report prepared by an insurance support organization may be retained by the insurance support organization and disclosed to other persons.

We will protect your NPI. We will restrict access to your NPI by maintaining physical, electronic, and procedural safeguards. The only employees who are authorized to access your NPI are those who need to have it to provide products or services to you.

This policy statement may be changed at any time. We will notify you if we make any changes in this policy statement which broaden when we may share your NPI.

Above all, we value your trust and your confidence in our ability to manage and protect your NPI. You have our word that we will protect your NPI as if it were our own.

If we provide more than one financial product or service to you, you may receive more than one privacy statement from us. We do this in order to ensure that you receive a notice of our privacy practices.

If you have questions or concerns about our privacy policy or would like a more detailed explanation of our privacy practices, please contact us through any of the ways listed below. Please include your name and policy number when contacting us.

Zurich American Life Insurance Company
Attention: Compliance Office
13810 FNB Parkway
Omaha, NE 68154
USA
GLCompliance@zurichna.com

E-mail submissions over the Internet may not be secure and are subject to the risk of interception by third parties. Please consider this fact before e-mailing any personal or confidential information.

Zurich American Life Insurance Company (formerly known as Kemper Investors Life Insurance Company)