IMPORTANT NOTICE REGARDING CLIENT PRIVACY

Maintaining your trust and confidence is a high priority. That is why we at SGL Financial (“SGL”) want you to understand how we protect your privacy when we collect and use information about you, and the steps that we take to safeguard that information. SGL includes individuals who are insurance agents, investment adviser representatives, or both. Investment advisory services are offered through SGL Financial, LLC, an SEC registered investment adviser. Insurance products and services are offered separately through individually licensed and appointed agents in appropriate jurisdictions.

Privacy Statement

Various laws exist to protect consumers concerning the privacy of their non-public information. Investment Advisers are required by law to inform their clients of their policies regarding privacy of client information. Insurance agents and firms are also subject to certain laws and procedures assuring the confidentiality of client information. SGL affiliated individuals have agreed to be bound by professional standards of confidentiality and privacy that are even more stringent than those required by law. Federal law gives customers the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information.

SGL has always taken great measures to protect and safeguard information we gather on our clients. As a financial company, we can choose if or how we share your personal information. Please read this notice carefully to understand what we do.

Types of Information Collected

We collect nonpublic personal information about you from the following sources:

• Information we receive from you on applications or other forms, such as your name, address, phone number, Social Security Number, date of birth, account numbers, tax documents, other investments, and net worth; and
• Information about your transactions with us or with your custodian(s), such as buys, sells, gains, losses, fees, and/or holdings. Such information may be obtained from paper statements or via electronic download directly from your custodian.

SGL’s web servers may collect domain names and/or IP addresses of users to measure what pages and features are accessed by our visitors. This information helps us administer the site, improve content and gather broad demographic information for aggregate use.

SGL may use “cookies” or similar files or scripts throughout its website to enhance your convenience in using our websites, to improve search functionality or to hold information that you would otherwise need to re-key. “Cookies” are text files collected by a user’s web browser. If you do not wish to accept “cookies” from our website, you may configure your web browser so that it does not accept “cookies”; however, you may lose certain functions available on our website.

Use of Personal Information

We do not sell your personal information to anyone.

We do not disclose or share nonpublic personal information about you to third parties, unless one of the following limited exceptions applies or you have specifically asked us to do so:

• We disclose personal information to companies that help us process or service your transactions or account(s) (such as TD Ameritrade, various insurance firms, or others, as applicable).
• We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted under law, for example, to cooperate with regulators or law enforcement authorities.

SGL restricts access to your personal and account information to those employees who need to know that information in order to provide services to you. We maintain physical, electronic, and procedural safeguards to guard your nonpublic personal information.

Changes to Privacy Policy

In the future, SGL may offer new and different programs that necessitate a change in this Policy. SGL reserves the right to change its privacy policy at any time without prior notice. Any changes to the privacy policy will be posted on our website at www.sglfinancial.com under the Privacy section and will be effective immediately upon posting.

Governing Law and Jurisdiction

This Policy, and SGL’s collection and use of customer information, shall be governed and interpreted in accordance with the laws of the United States, the State of Illinois, or any other applicable jurisdiction. Any disputes arising out of this Policy shall be adjudicated in a court of competent jurisdiction in the Eastern District of the State of Illinois.

Phishing Scams

SGL does not send emails to customers requesting billing, login or password information. If you receive an email purporting to be from SGL that asks you to provide personal or account information, or login and passwords, do not provide such information unless you have first verified that the website or email is from SGL. Such emails may be fraudulent and used in connection with scams known as phishing. SGL asks that you report any suspicious emails or websites to SGL.

Disposal of Information

SGL has taken steps to reasonably ensure that the privacy of your nonpublic personal information is maintained at all times, including in connection with the disposal of information that is no longer required to be maintained. Such steps shall include whenever possible, shredding paper documents and records prior to disposal, requiring off-site storage vendors to shred documents maintained in such locations prior to disposal, and erasing and/or obliterating any data contained on electronic media in such a manner that the information can no longer be read or reconstructed.

Contact and Modifying Personal Information

If you should ever decide to close your account(s) or become an inactive client, we will continue to adhere to the privacy policies and practices as described in this notice.

Should you have any questions about the privacy and protection of your records, please contact us and we will be happy to discuss this matter with you.

You may request copies of or have SGL make changes or corrections to personal information in SGL’s possession by contacting SGL at support@SGLfinancial.com.

You may opt out of receiving further communications from us or others through any of the following methods:

• Send an email to support@SGLfinancial.com
• Send a request by mail to: SGL Financial, 1130 W Lake Cook Road, Suite 150, Buffalo Grove IL, 60089.
• Call: 847-499-3330

Please note that you cannot opt out of receiving any notifications or disclosures that we are required by Federal law to provide to you.