In the course of our business relationship with you, we collect information about you that is necessary to provide you with our products and services. We treat this information as confidential and recognize the importance of protecting it. This notice is being provided to you pursuant to law so that you will know our policy regarding the information we collect. We value your confidence.

How and Why We Obtain Personal Information

We collect and maintain personal information about you to provide you with the products or services you request and to service your account, respond to inquires from you or your representative or to fulfill legal and regulatory requirement. We may collect nonpublic personal information about you from any of the following sources:

- From you or your representative on applications or forms (for example, name, address, Social Security number, birth date, assets and income)

- From transactional activity in your account (for example, trading history and balances)

- From other interactions with us (for example, discussions with our customer service staff)

How We Protect Your Information

To insure your privacy, we employ extensive information protection controls in keeping with industry standards and practices. We regularly adapt these physical, electronic, and procedural controls to respond to changing requirements and advances in technology. For example, we make extensive use of firewall barriers, encryption techniques and authentication procedures.

Within Benefit Management, Inc., we restrict access to information to those who require that access in order to provide services to you. We may share the personal information that we collect about you with the following entities:

- Our affiliated service providers, if you request its services

- Government agencies and law enforcement officials, as required by law (for example, for tax reporting or under court order)

- Other organizations, with your consent or as directed by your representative

We do not otherwise disclose any nonpublic personal information about you to anyone.

Account Access

For your convenience, we offer several options for accessing your account information. You can review your information independently using your statement or, for 401(k) accounts, through our automated telephone or Internet services. You may also e-mail, write or call us with your request for information.

If you decide to close your account or are a former customer, your information is treated in the same manner as the information of current customers.