Privacy Statement for customers acquired from a Countrywide affiliated company - New York

YOUR PRIVACY AT CW INSURANCE

The Opportunities You Deserve, the Privacy You Expect
For more than 50 years, the affiliated insurance companies of CW Insurance*, a member of Countrywide Financial Corporation Group of California, have been trusted providers of insurance and other financial products and services to the customers of CW Insurance. The Countrywide family of companies is now part of the Bank of America family of companies.

Our primary focus is on empowering you to meet your financial goals by offering a wide range of products and services. This notice explains how we protect and use your information in a safe, secure and responsible manner.  When used in this policy, “we,” “our,” and “us” refer only to the Countrywide family of companies specifically identified in the section titled “Benefits to sharing within our family of companies and the other Bank of America companies” below and do not refer to the other Bank of America companies. This policy does not explain how the other Bank of America companies manage customer information and what actions you can take regarding how the other Bank of America companies use and share your information. Please visit bankofamerica.com/privacy for more information on the policy of the other Bank of America companies.

We may offer you products and services at a lower cost or with greater convenience by sharing limited information within our family of companies, within the Bank of America companies, and with carefully selected business partners.

Your Protection is Our Priority
We strive to safeguard your data. We do this by:

• setting policies and procedures for carefully handling your information;
• limiting employee access to sensitive information;
• requiring service providers who do business with Countrywide to comply with privacy laws;
• protecting against unauthorized access to customer data using data encryption, authentication, and virus detection technology;
• auditing company security practices; and,
• conducting background checks on all employees and providing privacy training.

About Our Websites
We design many features of our website so new visitors may anonymously learn about our products and services without revealing their identity. For new visitors, we use “cookies”, GIFs or similar devices to collect limited data (such as the date, time and areas of our website visited and the website the new visitor came from). When you select one of our products or services or respond to marketing materials sent to you directly, we will try to identify your browser and may combine information from “cookies”, GIFs or other similar devices and other information collected online with any other data we maintain about you. By improving the marketing and content of our website and making your online experience more convenient, we are able to better serve our customers’ financial needs.

How We Obtain Information
To issue and service your policy or other product, comply with government regulations, improve our products and services, and better understand your financial needs, we collect and maintain customer and former customer data. We collect information:

• you provide us on applications and other forms (such as your name and address, phone, Social Security and account numbers, health history and beneficiary information);
• about your transactions with us (such as your insurance coverage, and transaction and claims history);
• about your loss or health history from an insurance support organization or other consumer reporting agencies; and
• about your property from business partners and service providers (such as property inspection companies).

Information We Disclose and to Whom We May Disclose Information
We disclose the information that is collected as described above. We may share information as follows:

• We may disclose all data we collect with companies performing services on our behalf (such as the vendor who prepares and mails our insurance documents and data processors). These service providers agree to keep the information confidential and not use it for any other purpose;
• We may disclose all data to third parties (such as our agents, insurance support organizations and other consumer reporting agencies, regulators and insurance carriers). Information disclosed to insurance support organizations may be retained by such organizations and disclosed to other persons;
• We may disclose health information to determine eligibility for coverage, to process claims, to prevent fraud, and as authorized by you or as otherwise authorized or permitted by law; and
• We may disclose all information we collect as permitted or required by law (such as disclosures to state insurance authorities and law enforcement agencies).

Additionally, to provide you with valuable products and service offerings, we may share this information (such as the expiration date of your policy) within our family of companies and share limited information with business partners who are obligated to maintain the confidentiality of your information.

Benefits to Sharing Within Our Family of Companies and the Other Bank of America Companies
To offer and recommend valuable products and services, we may share customer and former customer information within our family of companies and the other Bank of America companies.  The other Bank of America companies include financial service providers, such as a brokerage company and a credit card company, and non-financial companies such as operations and servicing subsidiaries.

The Countrywide family of companies are:

• New Home Loans – Countrywide Bank, FSB offers new home loans, home equity loans and lines of credit and many refinancing options.
• Home Loan Servicing – Countrywide Home Loan Servicing LP provides industry-leading customer service and easy access to your home loan account information.
• Insurance – CW Insurance Agency (or Countrywide Insurance Group of companies*) offers a wide variety of insurance products and services.
• Loan Closing Services – The LandSafe family of companies offers title and escrow services, title insurance, credit reporting, property appraisals and flood zone determinations.
• Investments – Countrywide Investment Services, Inc.^± offers investment planning, mutual funds, IRAs, Roth IRAs, IRA and 401(k) rollovers, stocks, bonds and fixed and variable annuities.
• Banking – Countrywide Bank, FSB offers savings, CDs, money market accounts, new home loans, home equity loans and lines of credit, and many refinancing options.

All of the companies in the Countrywide family follow the same policies and procedures described in this notice.

As we continue to expand our operations, we are continually looking for ways to enhance customer service through various efficiencies, which may include the use of resources overseas. Our mission is to respond to your insurance and other financial needs as quickly and effectively as possible.

Benefits to Sharing Outside Our Family of Companies
To make products and services available, often at a savings to you, we may prudently share some customer and former customer non-public personal information with business partners under an agreement requiring the partner to keep the information confidential and only use it for those offers.

You Have Choices
You may limit how we share your personal information. This is called a right to “opt out.” You have three options to consider.

1. Continue receiving valuable and convenient product and service offers
   You can enjoy the benefits of valuable product and service offerings without taking any action.
2. Opt out of information sharing to third parties outside the Countrywide family of companies
   This choice would stop us from sharing non-public personal information with our carefully screened business partners. This may limit our ability to inform you of valuable and convenient products and services from partner companies. This choice will not apply to the other Bank of America companies sharing with third parties.  With respect to how the other Bank of America companies share non-public personal information with third parties, you will need to express your preferences separately as described in the policy of the other Bank of America companies at bankofamerica.com/privacy.
3. Opt out of information sharing within the Countrywide family of companies and the other Bank of America Companies
   This choice would stop us from sharing certain non-public personal information across all of the Countrywide family of companies and the other Bank of America companies. This may limit our ability to offer conveniences such as a custom financial investment plan and other financial service offer.
   

For policies or products issued to multiple persons, we will apply an opt out by any person to all account holders on such product. If you opt out, we will continue to share non-public personal information with our service providers (such as the vendor who prepares and mails our insurance documents), with third parties as required or permitted by law (such as agents, insurance support organizations or regulators), and share transactions and experience information (such as the expiration date of your policy) within the Countrywide family of companies and the other Bank of America companies.

If you want to opt out, call us at 1-888-268-2987. Please have your policy or other financial product information available when you call.

In today’s dynamic market, opting out may mean missing timely information about products and services that help you accomplish your insurance and other financial goals. It’s something to think about carefully. We don’t want you to miss out on any opportunities.

How to Confirm the Accuracy of Your Information
We are committed to maintaining accurate and up-to-date information on all of our customers. We provide access to account information in various ways — including over the phone and through other communications about your insurance. If you believe that any of your information is incorrect, please notify us immediately using the customer service number provided on your insurance documents that you have received. We will respond in a timely manner to customers' requests to correct account or transaction information. However, in order to protect the confidentiality of your information, we may ask you to verify your identity and to provide other details to respond to your request.

Notification of Changes
The policies and practices in this notice replace all previous notices or statements about your privacy rights at CW Insurance. If we make any significant changes, we will notify you and only apply those new changes to future use of your information. If we make such changes, we will also revise the corporate privacy policy effective date, so that you can keep track of when those changes occur.

Protecting Your Identity
Identity theft is one of the fastest growing crimes in America. We understand the implications identity theft can have and take very specific steps to reduce the chance that identity thieves can damage the credit reputations of our customers. See www.countrywide.com and click on “privacy and security” for more information on identity theft and how to protect yourself.

If you think your identity has been stolen, affecting any of your loans or accounts with any of the affiliated companies of CW Insurance, please contact us immediately:

Phone:  1-877-CUFRAUD (283-7283)
E-Mail:  fraud_hotline@countrywide.com

You should also contact the three major credit bureaus and have them place a fraud alert on your file.

Equifax	Experian	TransUnion
1-800-525-6285	1-888-397-3742	1-800-680-7289
www.equifax.com	www.experian.com	www.transunion.com

For additional information, contact the Federal Trade Commission at www.consumer.gov/idtheft or call their hotline at 877-IDTHEFT.

Corporate Privacy Policy Notice Effective Date: July 1, 2008

*For purposes of this statement, the CW Insurance family of companies includes Balboa Insurance Company, Meritplan Insurance Company, Newport Insurance Company, Newport E & S Insurance Company, Balboa Life Insurance Company, Balboa Life Insurance Company of New York, CW Insurance Agency, and Balboa Warranty Services Corporation.