Thurston Springer Miller Herd & Titak

Privacy Notice

The Gramm-Leach-Bliley Act, passed in November, 1999, requires that all companies distributing financial and insurance products to the public, develop and publish a privacy policy. The Thurston, Springer, Miller, Herd & Titak, Inc. Privacy Policy deals with how and when we share and do not share customer information with unaffiliated third parties. The firm was fully compliant with the Gramm-Leach-Bliley Act by July 1, 2001. To accomplish this, we sent this privacy disclosure notice to all existing customers and will provide this notice to each new customer at the start of our business relationship. Thereafter, we will send this notice to all customers annually for the duration of our relationship.

At Thurston, Springer, protecting your privacy is very important to us. We value your trust and we want you to understand what information we collect, how we use it and how we protect it.

Every time you access our website using a browser, such as Netscape Navigator or Microsoft Internet Explorer, we encrypt it using Secure Socket Layer (SSL) technology. This technology is used to protect your communications through server authentication and data encryption. You can tell if you are visiting a secure area within our Web site by looking at a lock at the top of the screen. If the lock appears in a locked position, your session is taking place through a secure server.

Information We May Collect

We obtain nonpublic personal information to provide you products and services you have requested and to service your account. This information is obtained from the following sources:

• Information we receive from you on applications or other forms such as name, address, telephone number, social security number, income and assets
• Information about your transactions with us or others
• Information we receive from a consumer reporting agency

Information We Disclose and Parties To Whom We Disclose

We prohibit disclosure of nonpublic personal information about our customers or former customers to any non-affiliated third party.

We may disclose the personal information we collect to companies, such as insurance companies, mutual funds, annuity companies and financial services brokers that aid in fulfilling the service requested by a customer such as:

• Providing administrative, custody, customer assistance, or other services
• Preparing, printing and delivering statements and other documents

We may also disclose nonpublic personal information about you to nonaffiliated third parties as required by law.

If your Financial Advisor leaves us to join another Investment Advisor or Broker/Dealer that is a member of the Protocol for Broker Recruiting (to which our firm is a signatory), we may permit your advisor to retain certain contact information, limited to your name, address, email address, phone number and account title. If you object to such information being retained by your Financial Advisor or shared with your Financial Advisor's new firm, you may opt out by contacting our compliance department at 800-433-8049.

Our Security Procedures

We maintain procedures and technology designed to prevent unauthorized access to personal information. We restrict access to personal information to employees and service providers who need to know that information to provide products or services to you. Employees who violate our Privacy Policy are subject to disciplinary action.

Change in Privacy Policy

We reserve the right to modify or supplement this Privacy Policy at any time. If we make material changes, we will provide current customers with a revised notice that describes our new practices and if such practices so require, we will give them a reasonable opportunity to opt out of the disclosure of information under the revised Privacy Policy. Updated 10.10.2011

Why you should be a Thurston Springer client:

Your success is our success