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Privacy Promise

Effective Date: October 1, 2010*

ING is committed to protecting the privacy and confidentiality of your personal information.

As providers of products and services that involve compiling personal—and sometimes, sensitive—information, protecting the confidentiality of that information has been, and will continue to be, a top priority throughout the ING companies.

Whether you are a current customer, former customer, or potential customer, we believe that you should know about the information we collect, the measures we take to safeguard it, and the limited circumstances in which we may share your information.

1. We collect only the customer information necessary to consistently deliver responsive products and services.

The information we collect and the extent to which we use it will vary depending on the product or service involved.

The ING companies collect information that helps serve your financial needs; provide high levels of customer service; develop and offer new products or services for our customers and potential customers; and fulfill legal and regulatory requirements.

The information collected generally varies depending on the products or services you request and may include:

  • Information provided on applications and related forms—for example, name, age, address, Social Security number, and annual income.
  • Responses from your employer, benefit plan sponsor, or association regarding any group products we may provide - for example, name, age, address, Social Security number, and annual income.
  • Third-party reports, such as consumer credit history, motor vehicle records, demographic and/or medical information, if relevant to your product or service.
  • Information about your relationship with us, such as products or services purchased, and account balances.

2. We maintain safeguards to protect privacy and information security.

We have implemented security standards and processes—including physical, electronic and procedural safeguards. We limit access to customer information to employees, registered representatives or agents who may need it to do their job. These individuals are trained to respect the confidentiality of your personal information and understand their duty to safeguard it.

3. We restrict the sharing of customer information with anyone – even our affiliates – for use in marketing.

First and foremost, we do not sell or share customer information with outside parties who want to market their products to you.

As a provider of a wide variety of financial products and services, we may identify opportunities to enhance customer service or to offer you additional products and services offered by other ING companies.

However, an ING company will not share information about you with another ING company that could be used to make insurance underwriting or lending decisions about you, unless you direct us to or unless we notify you first and give you a chance to say no.

In addition, an ING company will not use certain personal information (such as income, account history or credit history) received from another ING company in order to market its products or services to you unless you direct us to, or unless we notify you first and give you a chance to say no.

Similarly, we will not share personal information with third-party financial services entities, such as banks, credit unions, credit union service corporations, insurance companies, or securities broker-dealers, for purposes of joint marketing unless you direct us to, or unless we notify you first and give you a chance to say no.

4. We share customer information as necessary for business, regulatory, and servicing purposes.

We will share customer information to facilitate or service a transaction you have requested, but only in accordance with federal or state law. For example:

  • When you apply for a life insurance product, the ING life insurance companies may use a common application to avoid multiple medical tests. In this way, the information you provide and authorize us to obtain may subsequently be used by one or all of these companies as necessary to determine—and offer to you—the product most appropriate for your needs.
  • In some cases, your information (for example, name, address, age, and Social Security number) may be provided to other ING companies such as our securities broker-dealers, our insurance companies and agencies, or our banks to process or service a transaction you have requested or to facilitate enhanced customer service.
  • We may share or exchange information with companies engaged to work with us, such as third-party administrators and vendors hired to effect, administer or enforce a transaction that you request or authorize; to develop or maintain software; to perform marketing research; or to provide us with demographic information to develop marketing plans. We require these companies to maintain the confidentiality of customer information and use it only for the purpose for which it was provided.
  • We may provide information to reputable consumer reporting agencies in connection with your application or renewal of insurance coverage.

We may also share customer information in accordance with, or as required by, law or regulation (for example, in response to a subpoena, to prevent fraud, and to comply with rules of, or inquiries from, industry regulators).

In a few cases, an ING company not listed in this notice may have a privacy policy that differs from the one stated in this notice. If that is the case, you will receive a separate privacy notice from that ING business if you are a customer.

In addition, the agent or registered representative with whom you work to obtain ING financial products and services may use the personal information about you in his or her own files to advise you of other products or to help you with your overall financial strategy.

We will reaffirm this policy annually in writing, as long as you maintain an ongoing relationship with any of the ING companies listed below. While this policy may change from time to time, you can always review our current policy online at www.ing.com/us.

In this notice, the words "you" and "customer" are used to mean any individual who obtains or has obtained a financial product or service from an ING company that is to be used primarily for personal, family, or household purposes.

*Following is a list of the ING companies that this notice applies to, as of October 1, 2010:

  • Directed Services LLC
  • ING America Equities, Inc.
  • ING America Insurance Holdings, Inc.
  • ING Capital Corporation, LLC
  • ING Financial Advisers, LLC
  • ING Funds Services, LLC
  • ING Investment Advisors, LLC
  • ING Investment Management Co.
  • ING Investment Management LLC
  • ING Investment Trust Co.
  • ING Investments, LLC
  • ING Investments Distributor, LLC
  • ING Life Insurance and Annuity Company
  • ING National Trust
  • ING USA Annuity and Life Insurance Company
  • Midwestern United Life Insurance Company
  • ReliaStar Life Insurance Company
  • ReliaStar Life Insurance Company of New York
  • Security Life Assignment Corporation
  • Security Life of Denver Insurance Company
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