Privacy Statement

Last Revised 2/14/2017

1. Our Commitment to Privacy
Your privacy is very important to Synovus Securities, Inc. (“Synovus”, “our”, “we”, and/or “us”). Because we collect certain types of information about the users of our online software applications (the “Service”), we believe you should fully understand the conditions of our collection and use of such information. This Privacy Statement discloses what information we collect, how we use it, and how to correct or change it. By using the Service, you consent to our collection and use of your personally identifiable information as described in this Privacy Statement.

This Privacy Statement addresses the following topics:
2. Security Precautions
We employ various measures to secure your personally identifiable information and financial information. When you or your Consultant sends information to us via the Service, communication is encrypted. E-mails sent to us are not secure and we make no representation that any data contained in an e-mail sent to us will be secure. Thus, if your communication contains sensitive or confidential information or financial information, you should send it to us via regular mail or SECUREMAIL. Except as otherwise set forth in this Privacy Statement, we restrict access to customer data to those employees who need to know that information to provide products or services to you.

3. Personal Information Collected
We collect a very limited amount of personally identifiable information about you via your use of the Service. At this time, we only collect directly your email address, a response to a security question, as well as necessary account information and login credentials for use with the account aggregation function. However, your Consultant collects extensive information from you concerning you, your family and your finances. The data collected includes, but is not limited to, name, address, phone number and information required to calculate a net worth statement. This data is normally entered by you or the Consultant into and stored in the Service and used by your Consultant to generate financial, retirement and estate plans.

4. Use and Disclosure of Your Personal Information
Your personal information will be handled by Synovus in accordance with Synovus’ Privacy Notice which can be found at www.synovus.com/?id=1.

5. Changing Your Information
With respect to account aggregation information, just log into the Service and make whatever changes and deletions you desire to the accounts you have established. All other information can only be changed or removed through your Consultant. Please contact your Consultant if you want to change or remove information concerning you that is stored in the Service.

6. De-Identified and Aggregated Data
We may, from time to time, collect de-identified data from our users to prepare analyses, reports and other materials regarding (i) how users use the Service, (ii) the types and volume of assets managed within the Service, and (iii) other matters which may be useful to the financial consultant community. This data may be aggregated with other users’ data for such purposes. At no time will any of this data contain personally identifiable information or be used in any way to directly market goods or services to you except as described in Synovus’ Privacy Notice.

7. Cookies
How We Use Cookies. We may use website “cookies” to help you navigate the Service more easily, as well as to help us improve our website and service to you. A “cookie” is a small data file that our website can send to your computer, which may then be stored on your hard drive to help the Service “remember” information about your visit, for example, what pages you have accessed. We may collect information about the date and time you access the Service, what pages you viewed and how long you spent on our site. A cookie cannot retrieve other data from your computer or pass on computer viruses. Cookies will identify your browser, but will not provide any personal information about you. Our policy is never to store any personal information in a cookie. We use two different types of cookies with our website:

“Non-Persistent” cookies track the way you click through the Service on a single visit. These non-persistent cookies are deleted when you close your browser.

“Persistent” cookies enable us to remember you when you return to the Service. Your web browser will send cookie information from your previous visits back to us when you re-access the Service. Persistent cookies remain on your computer after you close your browser.

Disabling Cookies. You can set your computer to refuse to accept cookies. However, if you do so, you may not be able to obtain some services online and may find the Service harder to navigate.

8. Other Websites
The Service may contain links to third party websites and include embedded videos that are hosted by such third parties. We are not responsible for the privacy practices or the content of these other websites. These third parties may use web measurement and customization technologies (such as cookies) in conjunction with the provision of this content or functionality. If you use a link to another website or view an embedded video, you should consult the privacy notice for the site you visit. We have no control over the information that is submitted to, or collected by, other websites and we are not responsible for the content of any linked site or any link contained in a linked site, or any changes or updates to such sites, or any embedded video. This Privacy Statement applies solely to information collected by us or otherwise stored in the Service.

9. Web Server Logs
We use web server logs to count the number of people who visit our website, average time spent on the site, pages viewed and other relevant statistics each day. We do not capture any personally identifiable information about you or your e-mail address on our web server logs. We only use the information on our web server logs in aggregated form to better understand the use of our site and to help us improve the content of the site.

10. Children’s Online Privacy
The Service is not intended for use by children under the age of 13 and we do not knowingly collect information on the Service from children under the age of 13.

11. Revisions to This Privacy Statement
We may modify, amend, add or delete the terms of this Privacy Statement at any time. If we make changes to the Privacy Statement, we will post the revised Privacy Statement on this website and change the “Effective” date at the top of the Privacy Statement. Checking the “Effective” date above will allow you to determine whether the Privacy Statement has been changed since your last visit to our website. Your only remedy, if you do not accept the terms of this Privacy Statement, is to discontinue use of the Service.

12. Questions Regarding Synovus’ Online Privacy Practices
If you have any questions regarding Synovus’ online privacy practices, you can contact us at P.O. Box 120, Columbus, GA 31902 or 1-800-695-0987.