Privacy Policy

Collection of information

De Novo Corporation's main purpose in collecting information from clients and potential clients is for communication. However, personal non-public information is required for several of our products:

• Contracts and related forms, which include a customer’s name, address, social security number, information about the existing retirement accounts a customer holds, and information about a customer’s investment goals;

• Retirement account history, including information about the transactions and balances in a customer’s accounts; and

• Correspondence, whether written, telephonic, or electronic between a customer and De Novo Corporation or service providers to De Novo Corporation.

Disclosure of client information

We do not sell your personal information to anyone. We do not disclose personal information to third parties who are not affiliated with De Novo Corporation or have not executed a marketing or service agreement, unless one or more of the following circumstances exists:

• As Authorized – If you request or authorize the disclosure of the information (either directly to your account representative at De Novo Corporation or to the custodian of any self-directed account that you may set up as part of your contract with De Novo Corporation).

• As Permitted by Law – For example, sharing information with companies that maintain or service customer accounts for De Novo Corporation is permitted by law and is essential for us to provide clients with necessary or useful services with respect to their accounts. Furthermore, we may disclose or report personal information, such as account and transaction data, where we believe in good faith that disclosure is required or permitted under law (e.g., to cooperate with regulators, receivers, or to resolve client disputes).

• Outside Counsel – De Novo Corporation products/contracts generally include consultation with outside counsel. Your information will be available to the outside counsel in order to facilitate prompt communication and completion of your contract.

Security of client information

We train our staff to safeguard personal information of our clients, and they are required to use such information for business purposes only. De Novo Corporation maintains the following policies and procedures regarding privacy with its staff:

• Sensitive information stored electronically in our databases, such as Social Security Numbers, birth dates, credit card numbers, etc. is encrypted. Access to this information is controlled.

• Paper files containing sensitive information are kept in secure areas where access is closely controlled and monitored.

• Staff receives training on the types of information we can and cannot disclose to individuals and/or organizations outside De Novo Corporation.

Questions

Privacy and security are very important to De Novo Corporation. Maintaining privacy and security means not disclosing specifics on all of our internal practices. Should you have any questions, feel free to contact us.

It is important that you review and understand these official terms and conditions. These terms and conditions are binding and set forth the obligations of De Novo Corporation.