Our goal is to maintain your trust and confidence when handling your information. Therefore, keeping your information secure and ensuring your understanding of how that information is used, is an important aspect of building and maintaining that trust.

Rationale for Collection of Information

Personal information is collected to enable us to provide products and services to you and to improve and conduct our business. For example, we collect personal information to:

• Help us better evaluate your financial needs
• Process your requests and transactions more efficiently
• Keep you informed about new and existing products and services that may be of interest to you
• Ensure that you are provided with effective and efficient customer service
• Assess quality of our products and services

Protection of Personal Information

The company is committed to securing the privacy and confidentiality of your personal information. We maintain your personal information and data in accordance with strict standards of security and confidentiality.

We have ensured that employees who have access to your personal information maintain and protect the confidentiality of that information and must follow established procedures. Additionally, employees are required to acknowledge their responsibility to maintain the confidentiality of customer information through an oath of secrecy renewed annually.

When we use other companies to provide services on our behalf, they are required to protect the confidentiality of any personal information they may have access to. They are required to sign a legally binding confidentiality agreement which limits their use of the personal information of customers.

We also maintain physical, electronic and procedural safeguards that meet required standards to protect your personal information from unauthorized use. This includes the use of industry level encryption browser, installation of firewalls, monitoring of our systems and other security enhancements.

Disclosure of Information

• In order to verify or complete a transaction.
• To a third party performing a function on behalf of the company
• To comply with any law, regulation or an order of the Court.
• If you or any authorized person on the account gives us written permission to do so.

Sharing Information with Our Parent or Affiliates

We may share your personal information with our parent company or affiliates as required or permitted by applicable law. This would be strictly for the purpose of marketing a suite of products and services tailored specifically to meet your needs. For example, we may share information with our parent or affiliated companies in order to:

• Provide you with products and services that you have requested
• Service your account
• Process transactions relating to your account

We may share your name, contact information and information about our transactions and experiences with you with our parent or affiliates so that they or we may offer products or services that may be appropriate for you and to conduct business.

Sharing Information with Nonaffiliated Third Parties

We commit that we will not rent or sell your personal information to any third party. However, we may share your personal information with companies that we hire to perform services for us, such as vendors that provide data processing, computer software maintenance and development, transaction processing and marketing services. We assure you that any company with whom we share your information, have agreed to limit the use of such information to the purpose for which it was provided through the use of a duly signed legally binding confidentiality agreement.

Finally, we may disclose personal information to others, including nonaffiliated companies and regulatory authorities, as either required or permitted by applicable law. For example, we may disclose personal information to:

• Comply with investigations by regulatory authorities or law enforcement agencies
• Protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liabilities