PRIVACY PROTECTION POLICY

At RWI, protecting the privacy and the confidentiality of client personal information has always been of utmost importance. RWI values our client's business and the trust placed in it. In order to offer financial products and services, RWI employees must collect, maintain and use certain personal information. To help better understand how personal information is protected by RWI, the following describes RWI practices and policies with respect to the privacy of client personal information.

Types of Personal Information Collected and Why

The primary reason RWI collects and maintains client information is to serve its clients and administer the products and services requested from it. The type of personal information collected by RWI varies according to the products or services request, and may include:

  1. Information included on applications and related forms (such as name, address, telephone number, Social Security number, assets, income, medical and health information);
  2. Information about transactions (such as insurance premiums and policy numbers);
  3. Information from third parties (such as agents, employers, other insurers or health care providers);
  4. Information about client activity with us (such as products or services purchased, account balances and payment history);
  5. Information from client employers, benefit plan sponsors, or associations for any of Reliance Worldwide Investments' products (such as name, address, Social Security number, age and marital status);
  6. Information from consumer reporting agencies (such as credit relationships and history);
  7. Information from other unrelated companies' sources (medical information, demographic information);
  8. Information from visitors to the Reliance Worldwide Investments web site (such as that provided through on-line forms, site visitorship data and on-line information collection devices know as "cookies"); and,
  9. Information from governmental agencies and independent reporting companies in connection with applications for insurance or other products or services.
Access to, and Dislcosure of, Client Personal Information

Only authorized employees and agents, trained in the proper handling of personal information, have access to client personal information. RWI will refer to and use the information to issue and service investment products, insurance policies or other products. Except as noted below, RWI will not disclose client personal information without client authorization. RWI may, without prior consent and only as permitted by law, provide information to:

  1. Agents, Registered Representatives, Investment Banking Representatives and other applicable employees acting in the capacity of their employment;
  2. Unrelated service providers relied upon for administrative and transaction processing services; and other service providers all of whom agree to keep the information confidential;
  3. Organizations conducting industry research who agree to keep the information confidential;
  4. State Insurance Departments or other governmental agencies and regulatory bodies, as required by law; in response to a valid summons, court order, search warrant or subpoena, or to protect RWI's legal interests.
Protection of Confidentiality

In order to protect the confidentiality of client personal information, RWI commits to the following:

RWI, and its clearing firm Hilltop Securities, will safeguard and keep confidential, pursuant to company security procedures, any personal information provided to it or that is obtain on a client's behalf. In order to prevent others from gaining unauthorized access to personal information, RWI and Hilltop Securities have established security standards and procedures designed to safeguard this information. Access to personal information is granted only to employees who need to know that information to provide products or services to clients. RWI and Hilltop Securities also maintains physical, electronic and procedural safeguards to maintain the confidentiality of client personal information. RWI and Hilltop Securities will limit the use of personal information to the extent necessary to provide products and services and to administer their business. If outside organizations are hired to provide support services, they will be required to maintain the confidentiality of personal information to the same extent that RWI and Hilltop Securities does.

Information about transactions will be shared only as permitted by law and only to the extent necessary to bring products and services that may help meet client's changing financial needs.

Treatment of Former Client's Personal Information

Privacy protection and information security practices apply equally to current and former clients. However, neither RWI nor Hilltop Securities will provide annual notice of Hilltop Securities' Privacy Protection Policy to clients after they terminate their client relationship. The length of time personal information regarding former customers is kept will be governed by state law; however, it is eventually removed from RWI and Hilltop Securities records and destroyed.

Modifications to Privacy Protection Policy

RWI retains the right to modify this Policy at any time after providing reasonable notice of the change(s). Any change(s) or updates of will become effective immediately upon mailing notice of the change(s) to RWI clients. Questions or concerns regarding RWI'S and Hilltop Securities' Privacy Protection Policy should be addressed to:

Reliance Worldwide Investments, LLC
900 Tri-State Parkway, Suite 900
Gurnee, IL 60031

(847) 920-7060

clientrelations@rwiadvisors.com