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PRIVACY STATEMENT

For all Users of our Site:

This policy statement describes Deferral.com's agreement with each user of the Deferral.com web site (the "Site") to treat certain information on a private basis. Deferral.com reserves the right to revise its privacy statement from time to time, but will publish such changes on the Site before doing so. You should check the Site on a regular basis for updates and changes.

The Site is used to host and operate an online record keeping system (the "System") for certain types of supplemental benefits, most of which are not qualified plans under ERISA (often called "nonqualified plans"). While many nonqualified plans do not hold assets for their participants, some plan sponsors elect to use life insurance, mutual funds, securities and other assets to pay or deliver plan benefits.

Our System stores data for plans and for assets that employers may elect to hold or provide in connection with their plans, including information about the plan sponsor and personal information about the plan's participants. For plans that allow online enrollment or that allow for participants to make investment allocations or other elections, our System will track this information, as well.

Plan sponsors own the records (including participant data of their employees) maintained in the database in our System for their plans. Deferral.com owns the database architecture, structure, design and technology, along with other technology used for the Site. We do not sell individual nonpublic personal information for targeted advertising or other similar uses, and we use password access restrictions for nonpublic information in our databases. If you believe any of your nonpublic information is in error, please contact your plan administrator to arrange for any necessary corrections or clarifications.

If you are a participant in a Plan for which data is stored on our Site, we collect nonpublic information from you, your employer, your plan sponsor (along with its brokers, advisers and, if applicable, insurers) and plan administrator to enable such parties to manage your benefit plan, to collect and provide information pertaining to your participation, transactions and/or choices relating to your plan account, and to manage assets (if any) your plan sponsor chooses to hold or provide to pay or deliver benefits under your plan. Information collected from you (or others on your behalf, such as your plan administrator) will include your name, address, date of birth, social security number, benefit plan account information and, depending on the type of benefit plan, information pertaining to your compensation, retirement benefits, assets that may be used to fund, deliver or measure benefit payments, and your transactions pertaining to the plan (such as investment allocations).

We do not disclose nonpublic personal information to nonaffiliated third parties, except to the extent reasonably required to perform services on the Site, to allow any successor to our business to continue performance of services on the Site (for example, if Deferral.com's business were to be sold), as required by law or to the extent that such information already is publicly available from sources other than Deferral.com. For example, we disclose personal information for purposes of managing (or permitting your plan administrator, sponsor and other appropriate parties to manage) your benefit plan and related transactions, assets and services in accordance with applicable law. Also, nonpublic information with regard to your plan is reported to your plan sponsor, employer and administrator, and some of this information may be used for federal, state or local income tax reporting purposes. Many benefit plans require the support and services of financial intermediaries (such as security and insurance brokers), insurance companies, consultants and other service providers in the ordinary course of plan management and plan transaction activity. These unaffiliated third parties may need access to your nonpublic information to enable them to perform services or provide or manage assets that relate to your plan. The privacy policies of your employer, plan sponsor, plan administrator and any financial intermediary, insurer or other service provider used in connection with your plan (for example, a securities broker and/or insurer) also will govern how your personal information may be used and disclosed. Further information regarding these policies may be obtained from your plan administrator.

This policy was most recently updated on October 31, 2005.

 

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