The IMA Financial Group, Inc.

PRIVACY POLICY NOTICE
Effective July 1, 2001
Revised March 13, 2008

The IMA Financial Group, Inc. and its insurance brokerage subsidiaries, IMA, Inc., IMA of Kansas, Inc., IMA of Colorado, Inc., IMA of Texas, Inc., and Towerstone, Inc. (collectively referred to in this notice as “we”, “us”, or “our”) provide insurance brokerage services and sell insurance products and services to commercial businesses and to individuals for personal, family and household purposes. The IMA Financial Group, Inc. and all of its subsidiaries are collectively referred to in this notice as the "IMA Group". "You" refers to each of our individual customers who have purchased an insurance product through us for personal, family, or household purposes.

WHY YOU ARE RECEIVING THIS PRIVACY POLICY NOTICE
Title V of the Gramm-Leach-Bliley Act ("GLBA") and state regulations implementing GLBA generally prohibit us from sharing nonpublic personal information about you with a non-affiliated third party unless we provide you with a notice of our privacy policies and practices, such as the types of information that we collect about you and the categories of persons or entities to whom it may be disclosed. In compliance with the GLBA, we are providing you this notice about our privacy policies and practices. This notice does not apply to our commercial business insurance customers.

THE PERSONAL INFORMATION THAT WE COLLECT
We collect and maintain your personal information so we can provide personal insurance brokerage services and sell personal insurance products to you, as well as process your insurance claims. The types and categories of information we collect about you includes:

• Information we receive from you on applications for insurance coverage and other forms to provide insurance brokerage services to you (such as your name, home address, social security, telephone number, and financial information such as the fair market value of property you wish to insure);
• Information that we generate to service your account (such as loss claim information);
• Information we receive from a consumer reporting agency such as motor vehicle and driver data, credit history, and employment information; and
• Information about your transactions with us and our affiliates such as your policy coverage, premium payment history, the premium you pay and claims information.

INFORMATION SHARING PRACTICES WITHIN THE IMA GROUP
We may share nonpublic personal information about you within the IMA Group, as permitted by law, to enable us to service and maintain your account and provide information to you about products and services of the IMA Group. The circumstances under which disclosure within the IMA Group is permitted by law include disclosure to our subsidiaries TrueNorth, Inc. and TrueNorth Securities, Inc. to provide information to you about those subsidiaries' investment management and securities brokerage services.

SHARING INFORMATION OUTSIDE THE IMA GROUP
We do not disclose any nonpublic personal information about you to non-affiliated third parties, except as permitted by law. The circumstances under which disclosure to non-affiliated third parties is permitted by law include disclosures to insurance companies to obtain any insurance coverage requested by you or to process insurance claims. The circumstances under which disclosure to non-affiliated third parties is permitted by law also include disclosures to companies that perform marketing and other services for us, such as electronic enrollment service providers, and to other financial institutions with which we have joint marketing agreements, such as banks, securities broker-dealers, registered investment advisors, and insurance providers.

HOW WE PROTECT YOUR PERSONAL INFORMATION
We take great care to ensure that your personal information is kept safe from unauthorized access and would never share your personal information in violation of any regulation or law. The only employees or companies who can access your personal information are those who use it to service your account or provide services to you or to us. We diligently maintain physical, electronic and procedural safeguards that comply with applicable federal standards to guard your private personal information and to assist us in preventing unauthorized access to that information.

To fulfill our privacy commitment, we adhere to company-wide practices to safeguard the information we maintain about you. These include:

• Adopting policies and procedures that put in place physical, electronic and other safeguards to keep your personal information safe;
• Limiting access to personal information to those employees who need it to perform their job duties;
• Requiring third parties that perform services for us to agree by contract to keep your information strictly confidential;
• Protecting information of our former clients to the same extent as our current clients.

OUR POLICY REGARDING DISPUTE RESOLUTION
Any controversy or claim arising out of or relating to our privacy policy, or the breach of our privacy policy, shall be settled by arbitration in accordance with the rules of the American Arbitration Association, and judgment upon the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof.

RESERVATION OF RIGHT TO DISCLOSE INFORMATION IN UNFORESEEN CIRCUMSTANCES
In connection with the sale or potential sale or transfer of all or part of our company or its assets, we reserve the right to sell or transfer your information to a third party entity that (1) concentrates its business in a similar practice or service; (2) agrees to be our successor in interest with regard to the maintenance and protection of the information collected; and (3) agrees to the obligations of this privacy policy.

This notice is for information only. No reply is necessary.