We recognize that protecting the privacy of the confidential personal information we collect about you is an important responsibility. The following information will help you understand our privacy policy and how we will handle and maintain confidential personal information as we fulfill our obligations to protect your privacy. "Personal Information" refers to the nonpublic financial information obtained by Riverplace Capital Management in providing you a financial product or service.

Information We Collect

We collect personal information to help us serve your financial needs, offer new products or services, provide customer service and fulfill legal and regulatory requirements. The type of information that we collect varies according to the product or services involved, and may include:

• Information we receive from you on applications and related forms (Such as name, address, social security number, assets and income)
• Information about your transactions and relationships with us and our affiliates (such as products or services purchase and account balances)
• Information we receive from third parties in order to issue and service your accounts

We may disclose all of the information, as described above, to companies or individuals that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements.

Information Disclosed in Administering Your Accounts

We will not disclose any personal information about current or former clients, without their authorization, to non-affiliated third parties except as permitted or required by law. We do not sell any personal information about you to any third party. In the normal course of business, personal information may be shared with persons or entities involved in servicing and administering products or services on our behalf. Some of these include: your agent or broker, companies that perform marketing services on our behalf or other financial institutions with whom we have joint marketing agreements, and other service providers and affiliates assisting Riverplace Capital Management.

Procedures to Protect Confidentiality and Security of Your Personal Information

We have procedures in place that limit the access to nonpublic personal information about you to those employees, representatives and service providers who need to know that information in order to perform services or market products to you on behalf of Riverplace Capital Management and our affiliates. We educate our employees on the importance of protecting the privacy and security of confidential personal information. We also maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

We will update our policy and procedures where necessary to ensure that your privacy is maintained and that we conduct our business in a way that fulfills our commitments to you. If we make any material changes in our privacy policy, we will make that information available to our customers through written communication.