Nevo Financial is 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 independent financial services professional, directly as an individual customer, or whether Nevo Financial provides services to your employer or plan sponsor.

The privacy policies of Nevo Financial are reviewed at least annually. Our printed and online notices are then updated to reflect any changes.

Nevo Financial Privacy Policy

How and why we obtain personal information

Nevo Financial 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. Nevo Financial 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 Nevo Financial provides them with recordkeeping services (for example, payroll, human resources, or benefits information)
• Transactional activity in your account (for example, deposit history and balances)
• Other interactions with Nevo Financial (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 Nevo Financial)

How we protect information about you

Nevo Financial 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 Nevo Financial, 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

Nevo Financial does not share personal information about our customers with unaffiliated third parties for use in marketing their products and services without your expressed permission. 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 Nevo Financial’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 Nevo Financial as a financial reference in applying for credit with another institution), or as permitted or required by law (for example, for fraud prevention)

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

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

If Nevo Financial LLC provides workplace services to your employer or plan sponsor, such as payroll, human resources or benefits recordkeeping services, Nevo Financial LLC 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 Nevo Financial LLC through your independent financial services professional, we may exchange information we collect with your independent financial services professional or with others they may authorize.

If you transact business through Nevo Financial LLC’s life services, we may validate and obtain information about you from a third-party support organization, such as a credit service bureau. The support organization may further share your information, as permitted by law. We may also share information about you to learn if you qualify for services, to process claims, to prevent fraud, or otherwise at your direction, as permitted by law.

How we share information about you within Nevo Financial LLC

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

Additionally, if you interact with Nevo Financial LLC directly as an individual customer (including joint account holders) or if Nevo Financial LLC provides services to your employer or plan sponsor, we may exchange certain information about you with Nevo Financial LLC affiliates, for their use in marketing products and services as allowed by law.

Information collected from independent financial services professionals’ customers is not shared with Nevo Financial LLC affiliates for marketing purposes, except with your consent and as allowed by law.

Privacy Online

Privacy, security, and service in Nevo Financial LLC’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 Nevo Financial LLC accounts and systems from unauthorized access.

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

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

Cookies and similar technologies

Nevo Financial LLC and our third-party service providers may use cookies and similar technologies to support the operation of Nevo Financial LLC 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 Nevo Financial LLC 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. Nevo Financial LLC 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 Nevo Financial LLC website, or if you delete cookies, you may experience some inconvenience in your use of Nevo Financial LLC 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 Nevo Financial LLC 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 Nevo Financial LLC websites

Nevo Financial LLC 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 Nevo Financial LLC 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 Nevo Financial LLC products and services may be of interest to you. These service providers may collect information about your activity on Nevo Financial LLC 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 Nevo Financial LLC and not for their own purposes.

Advertising on non-Nevo Financial LLC websites

Nevo Financial LLC also advertises our products and services on websites not affiliated with Nevo Financial LLC 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.

Nevo Financial LLC and these third-party online advertising companies may use the data collected, along with other information we have about you and your Nevo Financial LLC relationships, to serve relevant ads to you. The advertisements may be relevant to your interests, as determined by your activity on Nevo Financial LLC and non-Nevo Financial LLC 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 Nevo Financial LLC 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.asp.

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

Connecting with Nevo Financial LLC on social media sites

Nevo Financial LLC 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 Twitter handle. 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.

Nevo Financial LLC Mobile apps

Nevo Financial LLC 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

Nevo Financial LLC websites are not directed to individuals under the age of thirteen (13). Nevo Financial LLC does not intentionally collect information on Nevo Financial LLC 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.

Nevo Financial LLC 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. Specific Internet addresses, mailing addresses and telephone numbers are listed on your statements and other correspondence.

The Nevo Financial LLC Privacy Policy is provided on behalf of:

Budget Genie™

NevoPay™

NevoMoney™

Other companies owned by Nevo Financial LLC using the Nevo Financial LLC name to provide financial or payment services to customers

Nevo Financial LLC Privacy Policy

Protecting your personal information is an important priority for the Nevo Financial LLC. The Nevo Financial LLC’ privacy policy is designed to support this objective. Nevo Financial LLC collects non-public personal information concerning you in the following ways:

• Information provided by you or your representative on applications or other forms furnished to Nevo Financial LLC or through other interactions that you or your representative have with Nevo Financial LLC
• Information arising from your transaction activity in or accounts with Nevo Financial LLC
• Information Nevo Financial LLC receives from a consumer reporting agency

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

Nevo Financial LLC does not disclose any non-public personal information about you, except as permitted by law. For example, Nevo Financial LLC have entered into a number of arrangements with Nevo Financial LLC to provide for investment management, distribution and servicing of Nevo Financial LLC.

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

Please read the Nevo Financial LLC Privacy Policy in conjunction with the Privacy Policy for the Nevo Financial LLC companies of which you are also a customer.

The Nevo Financial LLC Privacy Policy is provided on behalf of the Nevo Financial LLC family of financial services and products.

Effective August 10, 2015