Privacy Policy

Protecting your privacy is very important to us. We are strongly committed to safeguarding the information you provide us and to use it responsibly. Because of our commitment to you, we have adopted and adhere to the following policy regarding the privacy of your personal information.

Collection of Information

We may collect nonpublic personal financial information about you from some or all of the following sources:

• Information we receive from you on applications, new account forms, and fact-finding questionnaires.
• Your transactions with us, our affiliates, and those product sponsors with whom we have vendor agreements or other arrangements for the provision of services to you.
• Information we receive from non-affiliated third parties, including, but not limited to consumer reporting agencies.
• Affiliated and unaffiliated product sponsors with whom we have selling relationships and whose products you own.

Disclosure of Information

We will not share nonpublic personal information concerning our potential, current, or former customers with affiliated or unaffiliated third parties, except as permitted by law. Nor will we share this information for marketing purposes, except as permitted by law.

Generally, we may disclose customer nonpublic personal information to affiliates and non-affiliated third parties that provide services to us or have contracts with us to supply the products or services that you have requested through us.

Examples of third parties with whom we may share your information include:

• Insurance companies, mutual fund companies, insurance support organizations, and other product sponsors to effect purchases and sales and allow for the servicing of your account.
• Your agent or broker/dealer;clearing agencies through whom we clear and settle securities transactions.
• Third party investment advisory firms with whom we have relationships for the management of customer advisory accounts.
• Businesses, like banks and other financial institutions with whom we have an agreement for the marketing and sale of products and services.
• Regulatory or law-enforcement authorities.
• Record keeping companies.

Where we share your nonpublic personal information with third parties for the purposes noted above, we ensure that there are contractual restrictions on their use and disclosure of that information.

Protection of Information

We have security practices and procedures in place to prevent unauthorized use or access to your nonpublic personal information. Within our corporation, your information is only available to those individuals requiring access to process or service your transactions with us, and those fulfilling compliance, legal or audit functions on our behalf. We maintain physical, electronic, and procedural safeguards to ensure the protection of your nonpublic personal information in accordance with state and federal privacy regulations.