VANSON FINANCIAL’S PRIVACY POLICY

As providers of products and services that involve compiling personal – and sometimes, sensitive – information, protecting the confidentiality of that information has been, and continues to be, a top priority at Vanson Financial. 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 policy explains how Vanson Financial handles and protects the personal information we collect. "VF" or "Vanson Financial" refers to Vanson Financial and its employees and affiliates.

The information we collect and the extent to which we use it will vary depending on the product or service involved. In fact, in certain cases, we may not collect or share some of the types of information noted below. For example, in a number of cases, VF has an agreement with distributors or plan sponsors that limits the sharing of information about its clients with any other company. These agreements continue to be honored.

Our privacy promise derives from basic principles of trust, ethics and integrity:

1. We collect only the client information necessary to consistently deliver responsive products and services.

Vanson Financial collects information that helps serve your life planning and financial needs; provide high standards of client service; develop and offer new products or services for our clients and potential clients; and fulfill legal and regulatory requirements. The information collected generally varies depending on the products or services you request and may include:

• Information provided on applications and related forms – for example, name, address, Social Security number and annual income.
• Responses from your employer, benefit plan sponsor, or association regarding any group products we may provide – for example, name, age, address and Social Security number.
• Third party reports, such as consumer credit history, demographic and/or medical information if relevant to your product or service.
• Information about your relationships with us, such as products or services purchased, and account balances (if applicable), which we may obtain in writing, during telephone or Internet transactions or from documents you have provided VF with a copy of.

1. We maintain safeguards to ensure information security.

We have implemented security standards and processes – including physical, electronic and procedural safeguards – to ensure that access to client information is limited to employees and affiliates who may need it to do their jobs. They are required to adhere to this policy and respect the confidentiality of all client information they come in contact with, in the course of performing their duties at Vanson Financial.

2. We limit how, and with whom, we share client information.

First and foremost, we do not sell list of or clients, nor do we disclose client information to marketing companies, with the exception of companies we may hire to provide specific services for us, as described below.

Except as required to settle you estate, or with your joint account owners, Vanson Financial never shares your financial information with any of your beneficieries, family members, or relatives unless directed to do so by you, in writing.

Under no circumstances do we share medical information for marketing purposes.

We will share client information only for the following reasons:

When you have requested a life insurance product or additional insurance products. Information you provided to obtain an insurance product may subsequently be shared with other insurance companies as necessary to provide additional insurance products that you have subsequently requested.

We may be required by law or regulation to disclose information to third parties – for example, in response to a subpoena; to prevent fraud; and to comply with rules of, or inquires from, industry regulators. I some cases, we may share information we collect – for example, name, address, age and Social Security number with other businesses such as your broker-dealer, insurance companies and wholesalers, or banks to process or service a transactions you have requested, to facilitate enhanced client services or to inform you of VF products or services you may find useful. These other firms may have a privacy policy that differs from the one stated in this notice. If that is the case, you will receive a separate privacy notice from them directly. The VF employee or affiliate with whom you work to obtain financial products and services may use personal information about you in his or her own files to advise you of other products in connection with helping you with your overall financial strategy.

Vanson Financial will not share information about you with other firms that may be used to make insurance underwriting or lending decisions about you, unless you so direct us, or unless we tell you beforehand and give you a chance to say no.

Furthermore, as permitted by federal and state laws, VF may share or exchange information with companies engaged to work with us, such as:

• Third-party administrators and vendors we are affiliated with or hired by us to effect, administer or enforce a transaction that you request or authorize.

• Financial services entities, such as banks credit unions, credit union service corporations, insurance companies, or securities broker-dealers, with which we have joint working agreements; and vendors who provide us with our marketing material development and mailing services. The information we share is described in Section 1.

Other than what is described previously, Vanson Financial will never share information about you with third parties to market products to you. We don’t sell mailing lists.

We uphold these privacy principles throughout Vanson Financial and with our business partners. Companies with which we share client information are required to maintain the confidentiality of that information.

We will reaffirm this policy annually in writing, as long as you maintain an ongoing relationship with Vanson Financial. While this policy may change from time to time, you can always review our current policy online at www.vansonfinancial.com and clients will always be mailed a copy whenever any material changes to the policy are made.

Revision April 24, 2001