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Online Privacy Notice

Aspire Financial Services, LLC (Aspire) is committed to safeguarding customers’ financial and other personal information. This Online Privacy Notice (OPN) applies to all Aspire websites (collectively, Sites) that link to this notice. This OPN explains how Aspire collects, uses, and shares information from or about visitors to Aspire’s Sites (Visitors). A Visitor’s use of a Site reflects the Visitor’s agreement to the collection and use of information as described in this OPN. In addition to the terms of this OPN, depending on a Visitor’s relationship with Aspire, the Visitor may also receive and be covered by the Aspire Customer Privacy Notice and/or other privacy disclosures governing accounts and interactions. All Visitors should read this OPN and all other applicable notices and disclosures carefully.


COLLECTING INFORMATION

When a Visitor visits a Site, Aspire may collect certain categories of information from the Visitor. Some of the collected information may be personally identifiable information. For example, a Visitor may provide, and Aspire may collect, personally identifiable information on forms, surveys, applications, or other online fields. Aspire may also collect information that does not personally identify the Visitor or customer and may use this information for business purposes such as offering products/services, research, marketing, analyzing trends, and other purposes consistent with applicable laws. This information may include aggregated and de-identified data that Aspire creates or compiles from various sources such as accounts and transactions.

When a Visitor visits a Site, Aspire may collect information about a Visitor from the Visitor’s online browsing transactions, including the Visitor’s preferences, the pages the Visitor visited, the time and duration of the Visitor’s visit, and technical information about the Visitor’s computer and operating systems, such as the Visitor’s Internet Protocol (IP) address, domain name, system configuration, and settings. Aspire may place cookies, Flash® Objects, Web Beacons, or other technologies on a Visitor’s hard drive for security purposes and/or to personalize the Visitor’s experience. These technologies also allow Aspire the ability to monitor the use of the Sites in order to improve the design and functionality of the Sites to better serve Visitors.

Cookies

Cookies are pieces of information stored directly on the Visitor’s computer. Cookies allow Aspire to offer a Visitor more relevant products/services and to collect technical and navigational information such as browser type, time spent on the Sites, and Site pages visited. When a Visitor visits a Site, Aspire may use cookies to monitor the visit. When a Visitor applies for a product/service on a Site, Aspire may use cookies to remember the Visitor and to personalize the Visitor’s experience and provide the Visitor with information on products/services that may fit the Visitor’s needs. A Visitor may disable and/or delete cookies by following his/her browser’s instructions for doing so. If a Visitor disables and/or deletes cookies, the Sites, or part of the Sites may not function as intended.

Flash Objects

Aspire may use Flash® Objects (sometimes referred to as local shared objects) as a part of our online authentication process and/or to facilitate viewing of certain Site content. Deleting cookies does not delete Flash® Objects. A Visitor can find information about how to delete and disable Flash® Objects by visiting http://kb2.adobe.com/cps/526/52697ee8.html, (which is not an Aspire Site). If a Visitor deletes and/or disables Flash® Objects, the Sites, or parts of the Sites, may not function as intended.

Other Technologies

Aspire may use Web Beacons to capture information such as IP address, time, Web browser, time zone and domain. Disabling cookies will prevent Web Beacons from tracking a Visitor’s activity. Aspire may use other technologies to capture Visitor-specific data to help Aspire understand how Visitors use the Sites and to assist Aspire in resolving Visitors’ questions about the use of the Sites.

Online Surveys and Promotions

From time to time, Aspire may offer a Visitor the opportunity to participate in a survey or promotion. Visitors are not required to participate in surveys or promotions. Aspire may use the information gathered in surveys or promotions to better serve Visitors and customers and/or to inform Visitors and customers of Aspire’s products/services.

Online Planning Tools

Aspire may make available, either on Aspire’s Sites or through a hyperlink to a third-party website, a variety of retirement planning tools. Visitors are not required to use the planning tools or enter information into the planning tools. The information a Visitor enters into planning tools may be stored for the Visitor’s future access and use. Third- party planning tools may be subject to alternative privacy policies of the third party and may not be subject to Aspire’s privacy policies. Visitors should carefully review the applicable privacy policies of third parties.

Online Contact Us Option

Some Sites may provide a way for a Visitor to send Aspire a question or comment online. Aspire may collect the information provided by the Visitor, such as the Visitor’s name, email address, telephone number, company, and information included in the Visitor’s question or comment. Aspire may use this information in responding to the Visitor and for other purposes as allowed by law.

Online Account Access

If a Visitor has an account with Aspire and accesses the account online, Aspire may maintain information about the visit for security purposes, to personalize the Visitor’s browsing experience, and to personalize the products/services Aspire offers. Online access to Aspire’s recordkeeping system requires entry of a unique account number and personal identification number. Aspire further protects access to account information using physical and electronic security measures that comply with federal law including computer safeguards and secured files and buildings.


Using and Sharing Information

Aspire may use the information collected to remember a Visitor’s preferences the next time he/she visits a Site, to improve a Site, to monitor the use of a Site for marketing or security purposes, or for other purposes permitted by law. Aspire may share information with Aspire’s affiliates and/or with unaffiliated third parties for these purposes. Aspire will abide by the privacy policies and elections made by individuals as described in the Aspire Customer Privacy Policy.

Additional Information Social Media

Aspire may participate on social media platforms such as Facebook, Twitter, and LinkedIn. These social media platforms enable online sharing and collaboration among users. Any content an individual posts or makes available on a social media platform is subject to the terms of use and privacy policies of that social media platform, which should be reviewed carefully for information about users’ rights and obligations.

Accuracy of Information

If a Visitor who has an account with Aspire discovers that information on his/her account is incomplete, inaccurate, or outdated, the Visitor should notify Aspire immediately at the telephone number, mailing address, or Contact Us option on the Contact page of Aspire’s Site.

Links to Other Sites

Aspire may provide links to third-party websites. If a Visitor follows a link to a website not controlled by Aspire, the Visitor should review the third party’s privacy policies and other terms, as they may be different from the ones that apply to Aspire Sites. Aspire does not guarantee, and is not responsible for, the privacy or security of third-party websites. Aspire is not responsible for the accuracy, completeness, reliability, or suitability of third-party websites’ information.

Online Privacy for Children

Aspire’s Sites are not intended for use by children under the age of 13 and are not intended to collect data from children under the age of 13. Aspire does not knowingly collect information from children under age 13 without parental consent. If a Visitor is under the age of 13, the Visitor should not enter his/her personal information.

Caution Recommended

No transmission of information via the Internet is entirely secure. Visitors should therefore always use caution when submitting any personally identifiable information online.


Changes to this OPN

This OPN is subject to change. Visitors are encouraged to review it periodically. If Aspire makes changes to the OPN, the “Last Revised” date of the OPN will be updated. Changes to the OPN will be effective when a revised OPN is posted on the Site. A Visitor’s use of the Site following changes to the OPN indicates his/her acceptance of the revised OPN.

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