PRIVACY NOTICE

New Century Planning Associates, Inc. (referred to as “New Century”) maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, New Century attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

It is the policy of New Century to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to the client. New Century may disclose the client’s information if New Century is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with New Century, including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.): (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.

The disclosure of information contained in any document completed by the client for processing and/or transmittal by New Century in order to facilitate the commencement/continuation/termination of a business relationship between the client and a nonaffiliated third-party service provider (i.e., broker-dealer, investment adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for New Century (i.e., planning agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.

What do we do with your data?

We comply with Federal and State requirements related to the protection and use of your data. This means that we only share data where we are permitted or required to do so. We also may be required to obtain your authorization before disclosing certain types of personal data.

We may use your data in order to:

• Process transactions or claims
• Respond to your requests
• Prevent fraud
• Comply with regulatory requirements
• Share with you the related products and services we offer.

We do not sell personal data about current or former customers or their accounts. We do not share your personal data for marketing purposes. When affiliates (such as estate planning attorneys, college planners, long-term care planners, etc.) or outside companies perform a service on our behalf, we may share your personal data with them, if you direct us to do so. We require them to protect your personal data, and we only permit them to use your personal data to perform those services.

New Century permits only authorized employees and affiliates who have signed a copy of New Century’s Privacy Policy to have access to client information. Employees violating New Century’s Privacy Policy will be subject to New Century’s disciplinary process. Additionally, whenever New Century hires other organizations to provide services to New Century’s clients, New Century will require them to sign confidentiality agreements and/or the Privacy Policy.