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 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 through whom we clear and settle securities transactions.
• Third party investment advisory firms with whom we have relationships for the management of 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.

Collection of Data

Our site uses technologies of third-party partners [such as NextRoll] to help us recognize your device and understand how you use our site(s) so that we can improve our services to reflect your interests and serve you advertisements about the [products and/or services] that are likely to be of more interest to you. Specifically, [NextRoll/these partners] collect information about your activity on our site(s) to enable us to:

• measure and analyze traffic and browsing activity on our site(s);
• show advertisements for our products and/or services to you on third-party sites;
• measure and analyze the performance of our advertising campaigns;
• Cross-Device
• We may share data, such as hashed email derived from emails or other online identifiers collected on our site(s) with [NextRoll/ our advertising partners]. This allows our partners to recognize and deliver you ads across devices and browsers. To read more about the technologies used by [NextRoll/our partner] and their cross device capabilities please refer to NextRoll’s Privacy Notice.

Opting-Out

Our partners [such as NextRoll] may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason you can use the following third party tools to decline the collection and use of information for the purpose of serving you interest based advertising:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform http://www.youronlinechoices.com/
• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

Changes to this Privacy Policy
We reserve the right to modify or supplement this Privacy Policy statement at
anytime. If we make any material change, we will update our website to include
such changes.

Date of last revisions: 11 May 2020