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Privacy Disclosure

At Benefit Service Company, maintaining our customers’ trust and confidence is of paramount importance. We are committed to safeguarding your personal information. Please read this notice to learn more about our privacy policies. This notice describes the privacy policies of Benefit Service Company. Other companies and businesses that are part of Benefit Service Company may have their own policies and you will receive their policies separately. These privacy policies apply to individuals who obtain or apply for a financial product or service for personal, family, or household purposes, or have done so in the past, from Benefit Service Company.

I. Information That We Collect

As part of providing you with our services we obtain nonpublic personal information about you which may include the following:

• Information we receive from you on applications, questionnaires, or other forms including name, address, social security number, assets and income, and other information we may receive from your representative.
• Information about your transactions with us, our affiliates, or others, such as balances, payment history, parties to transactions and account usage.
• Information about you from other Benefit Service Company affiliates, credit reporting agencies and other third parties providing information regarding your credit worthiness, credit history and other information.

II. Information That We Share

We use or share information in a limited and controlled manner. We use or share your information in order to identify and protect you against fraud, enable us to complete transactions quickly and efficiently, determine the right services to meet your needs and to provide you with proper customer service. Examples of customer information that we may share include:

• * Information we receive from you, such as your name, address, social security number, assets, and income, as provided, for example, on account applications.
• * Information about your transactions with us, our affiliates and others, such as balances, payment history, parties to transactions, and account usage.
• * Information we receive from affiliates, credit reporting agencies and other third parties not affiliated with us, such as your creditworthiness and credit history. Depending on the type of relationship you have with Benefit Service Company, we may share information with other Benefit Service Company affiliates, as well as with unaffiliated third parties as set forth below.

A. Sharing Information with Benefit Service Company

We share information about you with other Benefit Service Company affiliates as permitted by law in order to provide you with other financial tools and services. We may share identification information and transaction experience with Benefit Service Company affiliates. Our affiliates provide a wide range of financial services and include broker-dealers, investment advisers, financial planners and insurance brokers, among others. We may share customer information so that they can provide you services and products that may be of interest or value to you. We may share experience and non-experience nonpublic personal information about you to Benefit Service Company affiliates.

B. Sharing Information With Third Parties Not Affiliated With Benefit Service Company

We disclose information to unaffiliated third parties in limited circumstances and in
accordance with applicable law. Please be assured that whatever the reason for sharing your personal information, we take steps to assure that those parties respect your privacy by limiting the use of the information to the purpose for which it was disclosed. These
unaffiliated third parties may include:

• * Companies that perform services for your account that we do not provide ourselves. Such services may include account valuation, preparation of account statements, determination of fees and printing services.
• * Companies that will help protect your account from fraud.
• * Companies that provide services and products necessary to effect a transaction that you request or to service your account such as clearing firms, mutual fund companies and insurance companies.
• * Government agencies, courts, parties to lawsuits, regulators in response to subpoenas or otherwise as required by law. In such cases, we share only the information that we are required or authorized to share. We do not share information with nonaffiliated companies who intend to market their products to you. For example, we will not sell names and addresses to marketing companies. If the representative servicing your account leaves our company to join another broker/dealer or financial services firm, the representative may be permitted to retain copies of your information so that he or she may assist with the transfer of your account and continue to service your account at their new company. The representative’s use of your information will be governed by the new company servicing your account.

III. Confidentiality and Security

The security of your account information is important to us. Only those persons who need your information to perform their job have access to it. In addition, we maintain physical, electronic and procedural security measures that comply with federal regulations to protect your information. Our employees have limited access to your personal information based upon their responsibilities. All employees are instructed to protect the confidentiality of your personal information as described in these policies, which are strictly enforced.

IV. Former Customers

If you end your relationship with Benefit Service Company, we will continue to adhere to the policies and practices described in this notice. If you close your account, we may share information with any new broker-dealer or custodian that you select for purposes of transferring your account. To the extent we dispose of any information once you end your relationship with Benefit Service Company, we will do so in accordance with applicable state and federal law.

FINRA Public Disclosure Program
The Financial Industry Regulatory Authority (“FINRA”) Conduct Rule 2280 requires us to provide you with the following information:

The FINRA Public Disclosure Program Address, Hotline Number and
Facsimile Telephone number are:

Public Disclosure
FIRNA
P.O. Box 9401
Gaithersburg, Maryland 20898-9401
Telephone: 800.289.9999
Fax: 301.212.8137
The FINRA Website address is: www.finra.org/index.htm

FINRA’s Public Disclosure Program publishes an investor brochure that is available by contacting Public Disclosure at the above telephone number or address. If you have any questions or concerns regarding your account, please feel free to contact your Representative.