Protecting Your Privacy

* a printable version of this information is included in the PDF file available on the SEC disclosures page.

Our Pledge to You

We consider it a privilege to serve your financial needs and we value the trust you have placed in us. As we serve your financial relationship, we are committed to safeguarding your customer information.

Here is our privacy pledge to you:

1. Your privacy is a top priority.
2. The accounts and services you use are provided in a secure environment.
3. We collect information in order to service and administer your customer relationship.
4. Your customer information is shared only in limited ways and is carefully controlled.
5. We will work together with you to protect the security of your customer information, and to keep your information accurate and current.

Please read the information below to learn more about our privacy policies. We take pride in our integrity and responsive personal service.

A note about this information:
The privacy policies described in this publication 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.

As described below, you will find our policies and practices for collecting, disclosing, and safeguarding "nonpublic personal information," which may include financial or other customer information. This notification replaces all previous statements of our consumer privacy policy, and may be amended at any time. We'll keep you informed of changes as required by law.

This publication describes the privacy policies of DirectAdvice, Incorporated.

1. Your privacy is a top priority.

We are committed to your privacy. We take great care to protect the security of your customer information and to control how it may be used. In addition, we will provide annual notification of our privacy policies and procedures to keep our customers informed about this issue.

2. The accounts and services you use are provided in a secure environment.

We use sophisticated technology and security measures to protect your customer information. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard nonpublic personal information. We transfer all personal information over secure connections to ensure that others cannot view or intercept your confidential information as it is transmitted over the Internet or stored in our databases. Our security system protects your communications through industry-standard SSL (Secure Socket Layer) encryption of data.

We are careful to limit access to your nonpublic personal information. Our employees have limited access to customer information based on their responsibilities. This access enables them to resolve any customer service issues that may arise.

In addition, nonaffiliated third parties may be given access to customer information under certain circumstances. For example, a third party who provides a specialized service on our behalf may access only the information necessary to perform that service. Or, in cases when you authorize us to provide your customer information to others, we limit access only to the specified information, and only for the purpose you have authorized.

3. We collect information in order to service and administer your customer relationship.

In the course of serving or administering your customer relationship, we collect a variety of nonpublic personal information which is provided by you, as well as other sources, and may include:

When you register for an account on our site, you will complete a detailed questionnaire that includes certain personal and financial information about you including your name, date of birth, income, assets, goals, other financial information based on your household situation, and e-mail address. We collect this detailed information about your household situation in order to provide you with financial advice that is personalized to your unique goals and circumstances. We will only use your email address to provide you with customer service and to deliver information that will be helpful to you as a customer or is required by law or regulation.

We also use cookies to collect information. A cookie is a small data file that some web sites write to your hard drive when you visit them. A cookie cannot read data off your hard drive or read cookie files created by other sites. In order to protect your privacy, we do not use cookies to store or transmit any personally identifiable information about you on the Internet. We use cookies for two purposes only: to track how you found us, and to identify your session so we can provide real-time customer service. We use your IP address to track generic marketing information about the domain through which you visited us.

The information we collect is based on the services we may provide to you. This information is used or shared as described in the section that follows.

4. Your customer information is shared only in limited ways and is carefully controlled.

We use or share customer information in a limited and carefully controlled manner. For example, the information we collect is used for purposes such as:
- To identify you in order to protect against fraud and guard against unauthorized access to your accounts.
- To enable us to provide you with quality customer service.
- To better serve your relationship by understanding which services may be the right match for your needs, and telling you about new offers that may be of interest to you.
- To help ensure that our information about you is current and accurate.

Examples of categories of customer information that we may share include:
- Information we receive from you, such as your name and address, as provided, for example, on a financial planning questionnaire.
- Information about your transactions with our affiliates, others, and us.

This customer information may be shared with authorized users, including both affiliates and nonaffiliated third parties, in order to provide you with the services and financial choices that are most likely to be of value to you. These sharing policies and practices are described in this section.

With affiliates:

We may share customer information with our various administrative and service departments who use customer information as part of their data processing requirements to service your accounts.

With third parties not affiliated with us:

We may share the customer information we collect, as described earlier in this section, on a limited basis with certain nonaffiliated third parties. We may also share this information with those who perform marketing services on our behalf, or financial institutions with whom we have joint marketing agreements. And we may share customer information with other nonaffiliated third parties as permitted by law.

The third parties with whom customer information may be shared include:
- Companies that provide services necessary to effect a transaction that you request or to service your account.
- Companies or others that provide specialized services on our behalf, such as programming contractors, credit bureaus, or companies that help us market our services.
- Financial service providers, such as registered investment advisors or banks.
- Government agencies, courts, parties to lawsuits, or regulators to whom we may provide information about you and your transactions. For example, federal and state laws give people involved in lawsuits or other legal proceedings the right to obtain records and customer information from us. In such cases, we share only the information that we are required or authorized to share.

5. We will work together with you to protect the security of your customer information, and to keep your information accurate and current.

As described above, we use a combination of safeguards such as employee training and accountability, strict privacy policies and rigorous security standards to protect your nonpublic personal information.

You can help to maintain your privacy by taking such precautions as protecting your account numbers and passwords and not disclosing confidential information to unknown callers.

To ensure that the personal financial information you provide to us in the questionnaire is accurate and current, you may review and change this information online at any time by logging in and updating it in the questionnaire. The only information we do not allow you to change is your date of birth, which we restrict for fraud protection. You may also have any of the personally identifiable information that we collect about you in the registration process changed in our database, or have your account deactivated at any time by contacting our customer service department.

Privacy is a partnership. Because privacy matters, we pledge to work together with you to protect and control the security of your confidential financial information.

Thank you for this opportunity to serve you. Your relationship and trust are very important to us. Please be assured that we will abide by our policies and procedures to protect your information.