Protecting privacy is a top priority at Connect2A.com,LLC ("Connect2A"). Connect2A implements robust privacy protections, high-level security, and fair information practices to protect members’ and their clients’ personal information. This statement describes the policies that govern the collection, maintenance, use, and disclosure of personal information about our members and their clients. This is a short description of the Connect2A privacy policy. Click on any of the links for more details.

Connect2A fully discloses our privacy policy and information practices. We describe in detail what member and client information we collect, how we use it, and how we disclose it. As Connect2A evolves and offers new services, this policy will be updated to reflect the changes. However, our strong commitment to privacy, security, and fair information practices will never change.

Providing accurate and up-to-date information is a basic feature of Connect2A service. We permit and encourage members and clients to review their information and to make any necessary corrections.

Connect2A maintains all personal data with appropriate and high-level physical, electronic, and managerial safeguards to insure the security and confidentiality of the data against foreseeable risks. Security is designed to prevent unauthorized use, access, disclosure, destruction, and change of data.

Connect2A fully describes all sources, uses, and disclosures of member and client data. We do not collect, use, or disclose any information about a member or client without their express written approval. We do not sell, trade, rent, or otherwise disclose our member or client lists or information to unaffiliated third parties.

All Connect2A employees and members receive training in privacy and security. We choose backoffice partners who will meet our standards for privacy and security. We will work with members and clients to obtain a fair and rapid resolution of any complaints or disputes about privacy.

Connect2A.com may provide hypertext links to other Web sites. Please be aware that once you leave this web Site and enter another web site, you may be subject to different privacy practices and policies over which Connect2A.com has no control and for which Connect2A.com is not responsible. Please use prudence in utilizing such links and in disclosing any personal information on those sites.

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Purposes

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Information collection and Sharing from Members and Clients

Registration Form: The basic way that Connect2A obtains information about a Member is through the registration process. When you register, you are asked to provide your name, address, email address, telephone number, and telefax number, zip code, and credit card number. You are also given an initial user name and password. You can change your Connect2A user name and password. You can supply a hint question and answer to be used in case you forget your password.

Personal Information Form: The way that Connect2A obtains information about a Member’s Potential Client is for the Potential Client to complete the Connect2A.com personal information form which requires providing personal and financial data and answering a set of questions which help develop the Potential Client’s goals and objectives. The Potential Client accesses the system with a user name and password that is initially provided to them by a Member (the "Initial Member"). After the Potential Client’s initial login, the Potential client may select their own Connect2A password. The Potential Client can supply a hint question and answer to be used in case the Potential Client forgets their password. Only the Potential Client has access to their password after they have changed it.

The data collected in the personal information form can then be shared and used in desktop software solutions only with the Initial Member that provided the Potential Client with their initial username and password.

Potential Clients information will not be tracked for transactions and changing values. Potential Clients only have access to the personal information form, which can be updated and changed by them as they please.

The Initial Member of a Potential Client can select to make a Potential Client a Tracking Client. Connect2A will then track the Tracking Client’s financial information. The Initial Member can also terminate tracking a Tracking Client ‘s financial information at any time. A Tracking Client’s data is only made available to the Initial Member. Additional Members can also be granted access to a Tracking Client’s data. Additional Members are added by the Client upon the client selecting to share the data and entering that members Username. The data can be shared among the Members, each Member can print reports, and use the data in desktop software solutions. Once a Potential Client becomes a Tracking Client, the only information the Client can update his or her own personal information and to add additional advisors.

If any Member of a Tracking Client desires, a Member may select to make the Tracking Client a member of the Private Advisor Client Network ("PACN"). Granting membership or access to the PACN allows the PACN Client to have full view and access to their personal, estate, tax, and financial information, which is tracked by Connect2A and capable of updating and changing the same. Once an a Tracking Client is made a PACN Client, a small monthly user fee per PACN Client (Billed in advanced Quarterly) will be charged to each of the PACN Client’s Members.

Weblogs

Connect2A maintains standard web logs that automatically record basic information about everyone who visits our website. These logs contain:

The Internet domain from which you access Connect2A (e.g., aol.com, xyz.edu).

Your IP address. Your computer is automatically assigned an IP address when you surf the Internet. Static IP addresses are potentially identifiable, but dynamic addresses are usually not identifiable.

The type of browser (e.g., Internet Explorer or Netscape) and operating system (e.g., Windows 98) you use.

The date and time you visited Connect2A.

The pages that you visited here.

The address of the website you linked here from.

Connect2A uses web log information to help us design our website, to identify popular features, and for other managerial purposes. We will not make any attempt to identify individuals from web logs unless we determine that we need to identify a user who maybe attempting to break into or damage our website. In this case, we may share web log information with law enforcement agencies if we believe that we have evidence of a violation of computer security or related laws.

Backoffice Partner Privacy Standards

Connect2A may contract with other companies to assist in supporting our core features and functions, such as account consolidation, shopping, news, and online bill payment. When necessary for these services to function, we exchange Member and/or Client information with these companies. These are our backoffice partners. We require that our backoffice partners treat our customers' data under the same high privacy and security standards that Connect2A uses. This means that personal information provided to our backoffice partners is not sold, rented, or shared by them except as necessary to accomplish the purpose of the disclosure. It also means that our backoffice partners will not use personal data for marketing to our customers.

Advertisers and others

The only advertising currently on Connect2A is advertisements placed by our Member’s for their clients or by Sponsor’s for their affiliates. Connect2A never shares any personal information with any sponsor. Connect2A makes no representations or warranties about, and has no liability or responsibility toward its Members or the Member’s Potential Client, Tracking Client, or PACNJ Client in connection with, any of these other companies or their privacy policies. We urge our Members and the Member’s Clients to read the privacy policy of any website before providing any personal information.

Cookies

Connect2A will update this policy from time to time as we add new services and new features. Changes on our website will require additional descriptions about the flow of data. However, our strong commitment to privacy, security, and fair information practices will never change.

We will tell our Members and their clients about changes in this policy by making changes on this page, which will always contain a version number and date, making it easy to see when changes have taken place.

Some of the information that you routinely access through Connect2A.Com originates with a clients’ bank or other financial services organization and then appears on your Connect2A screen. Connect2A helps you to pull together personal data from a comprehensive list of sources, but the data only flows one way. If you find an error in the Financial data that is being tracked, you will likely have to go back to the source of the data in order to ask for a correction. We are not responsible for and cannot change information supplied to us by independent organizations. For personal and financial data collected from a client, Connect2A only passes and tracks the information for the Client’s Team of Professional Members and if applicable, the client.

A Member or their client can terminate his or her service with Connect2A at any time. When service is terminated, Connect2A will make every effort to remove all personal financial information from our system. We will promptly stop the tracking and collection of financial information from banks, other financial institutions, and other sources.

However, all customer records cannot be erased as easily or as quickly. Billing and payment information for those Connect2A services that require payment cannot be discarded casually. This information must be retained if questions or disputes arise. In addition, accounting policies and tax laws require that some records be maintained for several years. Some other transactions records may also be essential in the event of a question or dispute about an activity involving a Member or Client request, account, or transaction. These records may also be retained for several years.

Like other Internet and computer service organizations, Connect2A maintains several types of backups to its records. The backups permit us to restore service in the event of a natural disaster, equipment failure, or other problem. Backups provide important protections for everyone because they lessen the risk of loss of valuable data. Removing a Member or client from our main files does not remove that Member's or client’s record from any of the backup systems. It may take months before backup records are completely recycled and all traces of a Member's or Client’s registration and financial data are completely removed. Of course, backup records remain subject to the same protections as other Connect2A records.

Connect2A recognizes that the information you provide is personal and valuable. Connect2A believes the service we provide to our Members and their clients should make their lives easier, without the fear that personal information will end up in the wrong hands.

Connect2A uses the information collected about Members and their clients to assist the Members and their respective clients and no one else. We use personally identifiable information about our Members and their clients only in defined and responsible ways. We use your information internally to respond to your requests, provide support, maintain your account, and for similar purposes.

We do not share a Member’s or client’s information with third parties except when we have informed Members and/or their clients about the disclosures, when we have prior consent, or when required by law.

Some personal information maintained by Connect2A may be used on occasion by outside auditors, consultants, and others hired by Connect2A to assist in carrying out financial or operational activities. We permit these uses or disclosures only when necessary. All recipients must agree in writing to safeguard personal information, to use it only for an authorized purpose, and to return it or destroy it upon completion of the activity.

In addition, it is possible that Connect2A could be required to disclose personal information in response to valid legal process, such as a search warrant, subpoena, or court order. All record keepers face the possibility that disclosure of their records may be compelled in some civil, criminal, or administrative matters. Disclosures may also be appropriate to protect Connect2A's legal rights or during emergencies if physical safety is believed to be at risk. We think that these events are unlikely, but they are possible. We will take reasonable steps to limit the scope and consequences of any of these disclosures.

If we receive a subpoena demanding disclosure of your records, we will make all reasonable efforts to notify you of the subpoena when possible.

On Connect2A is committed to protecting your privacy and to making your online experience enjoyable, secure, comfortable, and valuable. If you have a question or comment about Connect2A's privacy policy, you may send a message to Privacy@connect2A.Com. You can also send snail mail to: Connect2A.Com, LLC, Privacy Officer, 8500 Keystone Crossing, Suite 555, Indianapolis, Indiana 46240.

If you have a complaint or dispute about this privacy policy, please let us know immediately. You may send a message to Privacy@connect2A.Com. You can also send snail mail to: Connect2A.Com, LLC, Privacy Officer, 8500 Keystone Crossing, Suite 555, Indianapolis, Indiana 46240.

We will do everything that we can to resolve any problems that a customer has identified. We will respond promptly to all complaints and disputes, and we will inform customers about their right to appeal if we have been unable to resolve the problem.

Last update April 4, 2001.