If You Were Notified of a Data Security Incident that occurred at Keenan & Associates Between August 21, 2023 and August 27, 2023, a Class Action Settlement May Affect Your Rights.

What is this Lawsuit about?

Between August 21, 2023 and August 27, 2023, an unauthorized user accessed information relating to certain of Keenan’s customers, including names, dates of birth, Social Security numbers, passport numbers, driver’s license numbers, health insurance information, and medical information, such as general health information, in a Data Security Incident.

The Plaintiffs claim that Defendant failed to adequately protect their Personally Identifying Information (PII) and that they were injured as a result. The Defendant, Keenan & Associates, denies any wrongdoing, and no court or other entity has made any judgment or other determination of any wrongdoing or that the law has been violated. Defendant denies these and all other claims made in the Action. By entering into the Settlement, the Defendant is not admitting that it did anything wrong.

How do I know if I am in the Settlement?

If you received Notice of this Settlement, you have been identified by the Settlement Administrator as a Class Member. More specifically, you are a Class Member, and you are affected by this Settlement, if you were notified by Keenan that your PII was or may have been affected in the Data Security Incident.

What does the Settlement provide?

The Settlement will provide Class Members with the opportunity to select and make a claim for three years (i.e., 36 months) of Credit Monitoring and Insurance Services (i.e., CMIS), and one of following cash Settlement Payments:

Pro rata Cash Fund Payments in amounts to be determined in accordance with the terms of the Settlement; or
Cash Payments of up to $10,000 per Class Member for reimbursement of certain Documented Losses (“Documented Loss Payment”).

In addition, Keenan has agreed to take certain remedial measures and enhanced security measures as a result of this Action.

YOUR RIGHTS AND OPTIONS IN THIS SETTLEMENT

Submit a Claim Form Deadline: OCTOBER 30, 2025	You must submit a Claim Form to receive the benefits provided by the Settlement, including CMIS and either a Documented Loss payment or a Cash Fund Payment. If you submit a Claim Form, you will give up your right to sue Keenan in a separate lawsuit about the legal claims this Settlement resolves. You will be bound by this Settlement.
Exclude Yourself From This Settlement Deadline: OCTOBER 15, 2025	You can exclude yourself from the Settlement (opt-out) by submitting the written Request for Exclusion or otherwise notifying the Settlement Administrator in writing. If you opt-out of the Settlement, you will not receive a Settlement Payment. You will, however, preserve your right to personally sue or be part of a separate lawsuit against Keenan for the claims this Settlement resolves. If you file a Request for Exclusion, you cannot also submit a Claim Form as part of this Settlement.
Object to or Comment on the Settlement Deadline: October 15, 2025	You may object to the Settlement by writing to the Court about why you do not think the Settlement should be approved. You can also write the Court to provide comments or reasons why you support the Settlement. If you object, you may also submit a Claim Form to receive Settlement Benefits, but you will give up your right to sue Keenan in a separate lawsuit about the claims this Settlement resolves.
Go to the Final Fairness Hearing Date: November 14, 2025	You may choose to attend and speak at the Final Fairness Hearing where the Court will hear arguments concerning approval of the Settlement. You are not required to attend the Final Fairness Hearing.
Do Nothing	If you do nothing, you will not receive the CMIS Settlement Benefit or any of the monetary Settlement Benefits, and you will give up your right to sue Keenan in a separate lawsuit for the claims this Settlement resolves.