Our Privacy Commitment to You

Allen & Company of Florida, Inc. recognizes the importance of safeguarding the personal information of our customers. Therefore it is the policy of Allen & Company and our affiliates that customer information must be protected in accordance with all applicable federal, state and local laws and regulations. We share a commitment to protect your privacy and the confidentiality of your personal and financial information.

COLLECTION OF INFORMATION

As providers of products and services that involve compiling personal ­ and sometimes, sensitive - information, protecting the confidentiality of that information has been, and will continue to be, a top priority throughout Allen & Company. We believe that you should know about the information we collect, the measures we take to safeguard it, and the situations in which we might share information with select business partners. This brochure explains how Allen & Company handles ­ and protects ­ the personal information we collect.

Allen & Company must collect a certain amount of information to provide customer service, offer new products or services, evaluate benefits, administer our products, and fulfill legal and regulatory requirements. Specific examples may not apply to all customers, and the information we collect varies accordingly. Examples include:

• Information on your account application and related forms, such as name, address, date of birth, Social Security number, gender, marital status, assets, income, and investment options elections;
• Information about your relationship with us, such as products or services purchased, account balances, and payment history;
• Information provided by your employer, benefits plan sponsor or association regarding any group product you may have, such as name, address, Social Security number, age, income, and marital status;

SHARING AND USE OF INFORMATION

We may share the personal information described above for business purposes with the following companies not affiliated with us:

• Financial service institutions, such as mutual fund companies, securities brokers, clearing brokers and banks, with whom we have joint agreements (such as agreements to market financial services or products that they jointly offer, endorse or sponsor with us);

  Or

• Companies under contract to perform services for us or on our behalf .

We will share personal information with non-affiliated companies only when they agree to uphold and maintain our privacy standard when handling a customer’s personal information.

Also we may disclose personal information with non-affiliated companies and regulatory authorities as permitted by applicable law. For example, we may disclose personal information to cooperate with regulatory authorities and law enforcement agencies and as necessary to protect our rights or property. Except as describe in this privacy policy, we will not use your personal information for any other purpose unless we describe how such information will be used at the time you disclose it to us or we obtain your permission to do so.

MAINTAINING ACCURATE INFORMATION

We continually strive to maintain complete and accurate information about you and your accounts. If you ever believe that our records contain inaccurate or incomplete information about you, please let us know immediately. We will correct any inaccuracies as quickly as possible.

PROTECTING THE INFORMATION

We are committed to maintain the security of our customers’ personal information. To ensure such information is used only in the manner we have described in this policy, we have instituted the following safeguards;

• Employees are required to comply with our established privacy policies and procedures, which exist to protect the confidentiality of customer information. Any employee who violates our privacy policies will be subject to a disciplinary process.
• Employees access the information only on a business need-to-know basis, such as administration procedures and customer services requested.
• We use manual and electronic security procedures to maintain the confidentiality of the information we collect and to guard against its unauthorized access. Such methods include locked files, user files, user authentication, encryption and firewall technology.

OUR CONTINUING COMMITMENT

We will continue to provide this notice at the frequency required by law and will notify customers at least annually. We will continue to follow the policies set forth in this notice even when a customer relationship no longer exist. However, that party will no longer be entitled to an annual notice.