The Great-West Family of Companies

Great-West Life & Annuity Insurance Company
The Great-West Life Assurance Company (US operations)
First Great-West Life & Annuity Insurance Company
Alta Health & Life Insurance Company
Advised Assets Group, Inc.
Alta Agency, Inc.
BenefitsCorp, Inc. ‡
GWFS Equities, Inc. ‡
BenefitsCorp, Inc. of Wyoming ‡
Canada Life Insurance Company of America
Canada Life Insurance Company of New York
The Canada Life Assurance Company (US operations)
EMJAY Corporation
FASCore, LLC
Great-West Benefit Services, Inc.
Greenwood Investments, LLC
GW Capital Management, LLC
GWL Properties Inc.
Maxim Series Fund, Inc.
National Plan Coordinators of Delaware, Inc. ‡
National Plan Coordinators of Washington, Inc. ‡
NPC Administrative Services Corporation ‡
NPC Securities, Inc. ‡
Great-West Healthcare Holdings, Inc. *
Great-West Healthcare, Inc. *
Great-West Healthcare of Arizona, Inc. *
Great-West Healthcare of California, Inc. *
Great-West Healthcare of Colorado, Inc. *
Great-West Healthcare of Florida, Inc. *
Great-West Healthcare of Georgia, Inc. *
Great-West Healthcare of Illinois, Inc. *
Great-West Healthcare of Indiana, Inc. *
Great-West Healthcare of Kansas/Missouri, Inc.
Great-West Healthcare of Massachusetts, Inc. *
Great-West Healthcare of New Jersey, Inc. *
Great-West Healthcare of North Carolina, Inc. *
Great-West Healthcare of Ohio, Inc. *
Great-West Healthcare of Oregon, Inc. *
Great-West Healthcare of Pennsylvania, Inc. *
Great-West Healthcare of Tennessee, Inc. *
Great-West Healthcare of Texas, Inc. *
Great-West Healthcare of Washington, Inc. *
One Orchard Equities, Inc.
Orchard Capital Management, LLC
Orchard Series Fund
Orchard Trust Company
P.C. Enrollment Services & Insurance Brokerage, Inc.‡
Westkin Properties Ltd.

‡ www.gwrs.com
* www.greatwesthealthcare.com

Revised 4/1/2004 (standard + CA)

The Great-West Family of Companies protects your privacy. We have strict policies in place to keep your personal information private. We will only share it with our affiliates, third parties with whom we do business, and in other ways permitted by law.

Types of Information We Collect. We collect and store nonpublic personal information. It comes from sources, such as the applications or other forms that you complete (for example, your name, your Social Security number, and your address). It can include information from business you have conducted with Great-West, our affiliates, and with other parties with whom we do business (such as your account balance, your contributions, and your premiums). It also may include information we receive from consumer and insurance reporting companies, such as credit reports and your health information.

Security of Your Information. We have strict procedures to protect your privacy. They include physical, administrative, and technical safeguards that are updated as new technologies are introduced.

Access to Information. The only employees who have access to your personal records are those who need it to conduct your business, or to provide you with products or services.

Our Information-Sharing Practices. We limit the types of information we share and the companies we share it with. Our main reasons for sharing are to help you do business with us and to expand your choices of services and products. What we share depends on the types of products or services you request such as information:

• from applications and other business forms (for instance, your name, address, Social Security number, assets and income)
• about your business with us, our affiliates, or with others (for example, your policy or contract coverage and benefits, premiums or contributions, and payment history)
• about your relationship with us (such as the products or services you purchased, your account balances, and payment histories)
• from your employer, benefit plan sponsor, or related to any group product in which you participate (for instance, your name, address, Social Security number, age, and marital status)
• from consumer and insurance reporting organizations, including the Medical Information Bureau (such as your credit relationships and financial or health history)
• from other third-party sources (including health and demographic information)
• from visitors to Web sites of the Great-West Family of Companies (such as information you provide through online forms, site visit data, and from electronic “cookies”)

Sharing of Health Information. We won’t share your health information, unless such sharing is permitted or required by the Health Insurance Portability and Accountability Act (“HIPAA”). For a description of how we use and share your health information, please contact our Privacy Officer, in writing at the address noted below to request a HIPAA Notice of Privacy Practices. You may also view the HIPAA Notice on our Web site at www.greatwesthealthcare.com.

Sharing Information with Other Parties. You may authorize us, in writing to share your information with other parties. Your information may be shared, however, without your authorization, with our affiliates and other third parties as permitted by law and you cannot prevent these disclosures. We do not share your information for any purpose that requires us to offer you the ability to opt-in or opt-out.

Our affiliates include our securities broker-dealers, our registered investment advisers and mutual fund companies, our HMOs, insurance companies and agencies and our trust company. Your information may be shared to serve you more efficiently or to make it easier for you to do business with us. The law allows us to share your financial information with our affiliates for marketing purposes.

We may also share your information with vendors and financial institutions. Vendors perform services for us such as processing transactions, responding to customers, providing information about products or services or maintaining and developing software. Financial institutions such as banks, insurance companies, securities brokers or dealers have marketing agreements with us. We have agreements with these parties requiring them to comply with strict policies to protect the privacy of your information. They are not allowed to use the information we provide for any purpose other than that specified or purposes otherwise permitted by law.

Other disclosures that may be made without your authorization, if applicable, include but are not limited to:

• To detect or prevent fraud & other criminal activity;
• To a medical professional for eligibility, notification or audit purposes;
• In response to an inquiry from a government agency or regulator;
• For purposes otherwise permitted or required by law;
• In response to a subpoena or court order;
• To a group policy holder to report claims experience or for an audit;
• In connection with a sale, merger or consolidation of all or part of our business;
• To a government agency to determine your eligibility for benefits they may have to pay for;
• To a professional peer review committee to evaluate the conduct or services of a medical professional;
• To a certificate holder or policyholder to provide information about the status of an insurance transaction.

Our Treatment of Information about Former Customers. Protecting your privacy goes beyond our relationship with you as our customer. If this relationship ends, we will not share your personal information with third parties except as law permits.

Customer Access to Information. You may access your information by submitting a written request that describes the information and we will respond within 30 business days or as required by applicable state law.

Customer Right to Correct, Amend or Delete Information. You may submit a written request to us to correct, amend or delete any personal information in our possession. We will respond to your request within 30 business days or as required by applicable state law.

If we refuse your request, we will explain why and you will have the right to file a statement of disagreement. If you have questions, please contact the Privacy Officer at the address below.

We reserve the right to revise our privacy policy as needed. If changes are made, we’ll send you a revised notice and post the new policy on the www.gwla.com Web site as well as on the sites of members of the Great-West Family of Companies.

Privacy Officer
Great-West Life & Annuity Insurance Company
8525 East Orchard Road
Greenwood Village, CO 80111

TOP