Privacy Policy

Our Commitment to Privacy

Secure Group Investments and the Secure Group Funds are committed to maintaining the confidentiality, integrity, and security of personal information about our current and prospective customers.

Please note that certain details of this policy may depend on whether you deal with us through an investment professional, directly as an individual investor, or whether Secure Group provides services to your employer or plan sponsor.

The privacy policies of Secure Group Investments and the Secure Group Funds are reviewed annually. Our printed and online notices are then updated to reflect any changes.

 

Secure Group Investments Privacy Policy

How and why we obtain personal information

Secure Group takes great care to protect personal information about you and when we use it, we do so with respect for your privacy. We may use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; or to fulfill legal and regulatory requirements. Secure Group may collect public and non-public personal information about you from any of the following sources:

  • You or your representative on applications or forms (for example, name, address, Social Security number, birth date, assets and income)
  • You or your employer or plan sponsor if Secure Group provides them with recordkeeping services (for example, payroll, human resources, or benefits information)
  • Transactional activity in your account (for example, trading history and balances)
  • Other interactions with Secure Group (for example, discussions with our customer service staff or information you enter into our websites)
  • Information from consumer reporting agencies (for example, to assess your creditworthiness for margin products)
  • Information from other third-party data services (for example, to verify your identity and to better understand your product and service needs)
  • You or your representative regarding your preferences (for example, your choice of electronic statement delivery, or the screen layout you specify if you use our Internet sites)
  • Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into Secure Group)

 

How we protect information about you

Secure Group considers the protection of personal information to be a foundation of customer trust and a sound business practice. We employ physical, electronic and procedural controls and we regularly adapt these controls to respond to changing requirements and advances in technology.

At Secure Group, we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you.

 

How we share information about you with third parties

Secure Group does not share personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:

  • Unaffiliated service providers (for example, printing and mailing companies, securities clearinghouses, marketing service providers, and other entities who may provide services at Secure Group’s direction)
  • Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)
  • Other organizations, with your consent or as directed by your representative (for example, if you use Secure Group as a financial reference in applying for credit with another institution), or as permitted or required by law (for example, for fraud prevention or to respond to a subpoena)

Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by Secure Group.

Based on the nature of your relationship with Secure Group, we may exchange information with other third parties as described below:

  • If Secure Group provides workplace services to your employer or plan sponsor, such as payroll, human resources or benefits recordkeeping services, Secure Group may exchange any information received in connection with such services with your employer or plan sponsor or others they may authorize.
  • If you conduct business with Secure Group through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.
  • If you transact business through Secure Group’s life insurance companies, we may validate and obtain information about you from an insurance support organization. The insurance support organization may further share your information with other insurers, as permitted by law. We may also share medical information about you to learn if you qualify for coverage, to process claims, to prevent fraud, or otherwise at your direction, as permitted by law.

 

How we share information about you within Secure Group

We may share personal information about you with various Secure Group corporate affiliates including internal service providers which perform, for example, printing, mailing, and data processing services.

Additionally, if you interact with Secure Group directly as an individual investor (including joint account holders) or if Secure Group provides services to your employer or plan sponsor, we may exchange certain information about you with Secure Group financial services affiliates, such as our brokerage and insurance companies, for their use in marketing products and services as allowed by law.

Information collected from investment professionals’ customers is not shared with Secure Group affiliates for marketing purposes, except with your consent and as allowed by law.

 

Privacy online

Privacy, security, and service in Secure Group’s online operations are just as critical as in the rest of our business. We use firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect Secure Group accounts and systems from unauthorized access.

When you interact with us through online channels (for example, websites and mobile applications) owned and controlled by Secure Group Investments (“Secure Group websites”), Secure Group manages personal information in accordance with all of the practices and safeguards described previously.

When you visit Secure Group websites, we may collect technical and navigational information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on Secure Group websites. We use this information for a variety of purposes, such as maintaining the security of your online session, facilitating site navigation, improving Secure Group website design and functionality, and personalizing your experience on Secure Group websites. Additionally, the following policies and practices apply when you are online.

Cookies and similar technologies

Secure Group and our third-party service providers may use cookies and similar technologies to support the operation of Secure Group websites. Cookies are small amounts of data that a website exchanges with a web browser or application on a visitor’s computer or mobile device. Cookies help us to collect information about visitors to Secure Group websites, including date and time of visits, pages viewed, amount of time spent on our sites, or general information about the device used to access the site. Secure Group cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie when on a Secure Group website, or if you delete cookies, you may experience some inconvenience in your use of Secure Group websites. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences.

Both Secure Group and third-party service providers we hire may use cookies and other technologies, such as web beacons or pixel tags, in online advertising as described below.

Advertising on Secure Group websites

Secure Group advertises on its own websites (including our mobile applications), and when we do, we may use information about your relationship with us, such as the types of accounts you have, to tailor advertisements about Secure Group and third-party products and services that may be of interest to you.

We may also use third-party service providers to help us determine which Secure Group products and services may be of interest to you. These service providers may collect information about your activity on Secure Group websites using cookies and other technologies to analyze, for example, pages visited, search engine referrals, browsing patterns, and responses to advertisements and promotions. Such service providers may only collect and use such information for purposes specified by Secure Group and not for their own purposes.

Advertising on non-Secure Group websites

Secure Group also advertises our products and services on websites (including mobile applications) not affiliated with Secure Group and we contract with third-party advertising companies to display these ads. These third-party advertising companies may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, Internet protocol address, and pages visited.

Secure Group and these third-party online advertising companies may use the data collected, along with other information we have about you and your Secure Group relationships, to serve relevant ads to you. The advertisements may be relevant to your interests, as determined by your activity on Secure Group and non-Secure Group websites. These are known as “interest-based advertisements.”

You may opt-out of receiving interest-based advertisements from online advertising companies by clicking on the AdChoices icon (which appears on all Secure Group interest-based ads) and following the opt-out instructions. For more information about interest-based advertising please see http://www.networkadvertising.org/managing/opt_out.aspOpens in a new window.

Non-Secure Group websites and mobile applications are not subject to Secure Group’s Privacy Policy. You may visit the individual sites for additional information on their privacy practices.

Connecting with Secure Group on social media sites

Secure Group provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide by interacting with us via social media, such as photographs, opinions, or social media account ID. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is also subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Secure Group Mobile® apps

Secure Group Mobile® applications (“apps”) allow you to access your accounts, trade securities, move money, and access news and research using wireless or mobile devices. Our privacy practices apply to any personal information or other information that we may collect through the apps.

Protecting children’s privacy online

Secure Group websites are not directed to individuals under the age of thirteen (13). Secure Group does not intentionally collect information on Secure Group websites from those we actually know are under 13, and we request that these individuals do not provide personal information through the sites.

 

Additional information

If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.

Secure Group offers several options for accessing and, if necessary, correcting your account information. You can review your information using your statements, or through our automated telephone or Internet services. You may also write or call us with your request for information. If you transact business through Secure Group’s life insurance companies, you are entitled to receive, upon written request, a record of any disclosures of your medical record information. If we serve you through an investment professional, please contact them directly. Specific Internet addresses, mailing addresses and telephone numbers are listed on your statements and other correspondence.

The Secure Group Investments Privacy Policy is provided on behalf of:

  • Secure Group Brokerage Services LLC
  • Secure Group Distributors Corporation
  • Secure Group Workplace Services LLC
  • Secure Group Investments Institutional Operations Company, Inc.
  • Secure Group Investments Institutional Services Company, Inc.
  • Secure Group Management Trust Company
  • Secure Group Personal Trust Company, FSB
  • Secure Group Stock Plan Services, LLC
  • Secure Group Investments Life Insurance Company
  • Empire Secure Group Investments Life Insurance Company
  • Secure Group Insurance Agency, Inc.
  • FIAM LLC
  • National Financial Services LLC
  • Strategic Advisers, Inc.
  • Other companies owned by Secure Group Investments using the Secure Group name to provide financial or payroll services to customers

 

Secure Group Funds Privacy Policy

Protecting your personal information is an important priority for the Secure Group Funds. The Funds’ privacy policy is designed to support this objective. The Funds collect non-public personal information concerning you in the following ways:

  • Information provided by you or your representative on applications or other forms furnished to the Funds or through other interactions that you or your representative have with the Funds
  • Information arising from your investments in or accounts with the Funds
  • Information the Funds receive from a consumer reporting agency

The Funds employ physical, electronic, and procedural controls to safeguard your information. For example, the Funds authorize access to your personal and account information only for personnel who need that information in order to provide products or services to you.

The Funds do not disclose any non-public personal information about you, except as permitted by law. For example, the Funds have entered into a number of arrangements with Secure Group Investments to provide for investment management, distribution and servicing of the Funds.

If you decide to close your account, the Funds will continue to adhere to the privacy policies and practices as described in this notice.

Please read the Secure Group Funds Privacy Policy in conjunction with the Privacy Policy for the Secure Group Investments companies of which you are also a customer.

The Secure Group Funds Privacy Policy is provided on behalf of the Secure Group Investments family of mutual funds, including those advised by Strategic Advisers, Inc.

 

Effective May 2018