ePlan Services, Inc. and ePlan Advisors, LLC

Privacy Statement

Respecting the privacy and security of our clients’ personal information is of paramount importance to ePlan Services. It is important for you to understand the private and secure treatment of your personal information, so we would encourage you to read this Privacy Statement carefully. This Privacy Statement is designed to inform you of the types of information we collect, how we use that information, and the circumstances under which we may share it among our family of affiliated companies and nonaffiliated third parties.

Protecting Your Personal Information

We do not sell customer information to anyone. We will only share customer information with others as detailed in this Statement, unless we provide you with additional notice or ask for your permission.

We only grant access to nonpublic personal information about you to employees and service providers so they can provide products or services to you, process and service your account, and administer business. We value your trust and carefully handle information we possess about you. All associates who have access to your personal information are bound by a code of conduct that requires that your information remain confidential. In addition, we maintain physical, electronic, and procedural safeguards to protect your information. We continually assess new technology for protecting information and, when appropriate, upgrade our information security systems. Even if you are no longer our customer, we will continue to treat your nonpublic personal information in the same way as if you were still a customer.

Information We Collect

We collect nonpublic personal information about you from the following sources:

How the Information Is Used

The sharing of information about you may be done to facilitate the services needed in order to properly and efficiently handle duties related to your account. These include:

Parties With Whom Information May Be Shared

References to “we,” “us,” or “our” are intended to apply to the affiliated firms ePlan Services, Inc. and ePlan Advisors, LLC. ePlan Services, Inc. primarily provides those services generally associated with a third party administrator of retirement plans. See our Services Agreement for specific services and fees as they relate to ePlan Services, Inc. ePlan Advisors, LLC is a Registered Investment Advisor with the primary responsibility of handling investment related duties for your account. See our Program Agreement or Form ADV for additional information about the services provided by ePlan Advisors, LLC. In order to provide the value and exceptional service we offer to you in handling your account, information is freely transferred and shared between ePlan Services, Inc. and ePlan Advisors, LLC as the needs arise in conjunction with the specific tasks being performed in relation to your account.

With regard to payroll processing and securities transactions, we utilize banking and brokerage services provided by unaffiliated firms. Virtually all transactions related to these services are not done at a level that specifies individual plan participants. In some cases, however, some information about you may need to be shared in order to provide a particular service related to your account. An example of this is if we have a bank we utilize cut a cashier’s check to you.

Depending on how your company’s plan came to us, we may share limited information with an unaffiliated firm. That is, for example, if a banking entity is involved, you may be considered to be their client as well as ours. We may share certain information with them as it relates to disclosures we make to them in conjunction with the overall arrangement that has been made. In most instances information supplied to a referral entity will not be individual participant specific but such disclosures may be if dictated by the business circumstance involved.

We may also disclose information we maintain about you to credit bureaus and similar organizations, when permitted by law. Such shared information may include a disclosure in connection with a subpoena or similar legal process, a fraud investigation, an audit or examination.

We are highly regulated by state and federal authorities. Client files, transaction histories, and other information that they deem necessary will be shared as they request in relation to audits or other oversight they partake.

Accuracy of Information

Keeping your information accurate and up to date is very important. We provide you with access to your account information through account statements, by telephone, or online from your PC or wireless devices. If your account information is ever inaccurate, incomplete, or in need of updating, please contact us and we will update your information. Note that some information updates may be done or have to be done through your employer. We will let you know that if you contact us for an update we are not able to do.

Privacy Statement Notice

We will provide notice of our Privacy Statement annually, as long as you maintain an account with us. We reserve the right to make changes to this Statement.