CUSTOMER PRIVACY NOTICE

You are receiving this Customer Privacy Notice because our records indicate that you are a customer of Securities America. Your servicing representative is an

independent consultant associated with Securities America.

FACTS WHAT DOES SECURITIES AMERICA DO WITH YOUR PERSONAL INFORMATION?

Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing of

your personal information. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this

notice carefully in order to better understand what we do.

What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:

• Social Security Number, Date of Birth, and Income

• Assets and Investment Experience

• Account Transactions and Retirement Assets

• Tax Reporting and Investment Performance Information

When you are no longer our customer, we continue to share your information as described in this notice.

How? All financial companies need to share customers’ personal information to run their everyday business. In the next section, we list the reasons

financial companies can share their customers’ personal information, the reasons Securities America chooses to share, and whether you can limit

this sharing.

The most current version of the Securities America Customer Privacy Notice is available online at www.securitiesamerica.com.

Reasons we can share your personal information Does Securities

America share?

Can you

limit this

sharing?

For our everyday business purposes

To administer, manage and service customer accounts, process transactions and provide related services for your accounts, it

is necessary for us to provide access to personal information with companies affiliated with Securities America and to certain

nonaffiliated companies. We may share your personal information:

to process your transactions, maintain your account, respond to court orders and legal investigations, or report to credit bureaus

or government entities

with parent and Affiliate companies of Securities America, Inc. including but not limited to:

• Securities America Advisors, Inc.

• Securities America Financial Corporation

• Arbor Point Advisors, LLC

• Ladenburg Thalmann Financial Services Inc. and its affiliated companies.

with nonaffiliated entities that perform services for us or function on our behalf (such as check printing services, clearing brokerdealers,

investment companies, and insurance companies)

with third-party administrators and vendors for the purposes of providing current and future information on your account (such as

transaction history, tax information and performance reporting).

Yes No

For our marketing purposes

To offer our products and services to you

Yes No

For our Affiliates to market to you

Affiliate companies that you do not have an existing relationship with

Yes Yes

For non-affiliates to market to you No We don’t

share

For joint marketing with other financial companies

Federal and certain state laws give us the right to share your information with banks, credit unions, retirement plans and other

financial companies where a formal agreement exists between us and them to provide or market financial products or services to

you. However, we will not share your information with these financial companies for marketing purposes if your financial advisor

is not affiliated with them without your consent, but we may share information with these financial companies where necessary to

service your accounts.

Yes No

For customers of financial institutions and Securities America

If you are a customer of a bank, credit union, or other financial institution program with which we have a networking agreement

(such as under a bank or credit union investment services program) and the financial institution terminates its relationship

with us, we will permit the financial institution to retain copies of your personal information so your account can continue to

be serviced at the financial institution. If you do not want the financial institution to disclose your personal information to

another brokerage or investment advisory firm (“New Firm”), you may request that we and/or your financial institution limit the

information that is shared with the New Firm.

Yes Yes

For clients of independent registered representatives and Securities America

If your financial advisor terminates his or her relationship with us and moves to a New Firm, we or your financial advisor may

disclose your personal information to the New Firm, unless you instruct us not to. If you do not want us or your financial

advisor to disclose your personal information to the New Firm when your financial advisor terminates his or her relationship

with us, you may request that we and your financial advisor limit the information that is shared with the New Firm.

Your personal information may also be shared with certain entities that are owned, controlled by or affiliated with your financial

advisor, such as an independent insurance agency, accounting firm or independent investment advisory firm.

In the event your financial advisor (or his/her estate) agrees with an unaffiliated financial advisor to sell all or some portion

of his/her securities, advisory or insurance business, your personal information may be shared with the acquiring financial

advisor and his/her New Firm.

If your primary address is in a state that requires your affirmative consent to share your personal information with the New Firm

(such as California, Massachusetts, Maine, New Mexico, North Dakota, or Vermont), then you must give your written consent

before we will allow your financial advisor to take any of your personal information to that New Firm.

Yes Yes

Who we are

Who is providing

this notice?

Securities America, Inc. and its Affiliates (collectively Securities America). Our Affiliates covered under this privacy notice include the

following entities:

• Securities America Advisors, Inc.

• Securities America Financial Corporation

• Arbor Point Advisors, LLC

• Ladenburg Thalmann Financial Services Inc. and its affiliated companies.

Other important information

Use and disclosure of health information

To the extent you provide health information to Securities America for the purpose of applying for insurance products, such information will not be disclosed to

nonaffiliated companies for any purpose, except:

to underwrite or administer your insurance policy or related claims

as required by law

as authorized by you

To limit our

sharing

You may limit the sharing of your personal information (“Opt-Out”) by calling 1-800-747-6111.

Please note:

When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any

time to limit our sharing.

In the event you decide to Opt-Out, your decision will be recorded as limiting the sharing of personal information for all applicable options. In other

words, if you Opt-Out your personal information will not be shared: (i) with your financial advisor’s new broker-dealer in the event he or she leaves

Securities America or an Affiliate and joins a New Firm or sells his/her securities, advisory or insurance business to a nonaffiliated company; (ii)

with affiliated entities of your financial advisor or any bank or credit union that your financial advisor is affiliated with; and (iii) with Affiliates of

Securities America that you do not already have an existing relationship with for the purpose of marketing products or services to you.

In addition, Securities America and its Affiliates (where applicable) have signed the Protocol for Broker Recruiting (“Protocol”) which allows

the financial advisor servicing your account to take certain limited information in the event he/she leaves Securities America or an Affiliate and

joins another firm which has also signed the Protocol. The information your financial advisor can take is limited to your name, your address,

your phone number, your email address and the title of your account. If you choose to Opt-Out Securities America or an Affiliate will notify your

financial advisor of your decision to keep your personal information confidential and that you do not want your personal information shared by

your financial advisor with his/her new firm.

Questions? Go to www.securitiesamerica.com

What we do

How do Securities

America and its Affiliates

protect my personal

information?

To protect your personal information from unauthorized access and use, we use security measures that comply with applicable state

and federal laws. These measures include computer safeguards and secured files and buildings.

We train our employees and financial advisors in the proper handling of personal information. We require companies that help

provide our services to you to protect the confi

confidentiality of personal information they receive.

How do Securities

America and its Affiliates

collect my personal

information?

We collect your personal information, for example, when you:

open an investment account or an advisory account

apply for insurance

seek advice about your investments

share information about your investment or retirement portfolio

We also collect your personal information from others such as credit bureaus, affiliates, or other companies.

Why can’t I limit all

sharing?

Federal law gives you the right to limit only

sharing for Affiliates’ everyday business purposes—information about your creditworthiness

Affiliates from using your information to market to you

sharing for non-affiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

Other important information

Use and disclosure of health information

To the extent you provide health information to Securities America for the purpose of applying for insurance products, such information will not be disclosed to

nonaffiliated companies for any purpose, except:

to underwrite or administer your insurance policy or related claims

as required by law

as authorized by you

To limit our

sharing

You may limit the sharing of your personal information (“Opt-Out”) by calling 1-800-747-6111.

Please note:

When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any

time to limit our sharing.

In the event you decide to Opt-Out, your decision will be recorded as limiting the sharing of personal information for all applicable options. In other

words, if you Opt-Out your personal information will not be shared: (i) with your financial advisor’s new broker-dealer in the event he or she leaves

Securities America or an Affiliate and joins a New Firm or sells his/her securities, advisory or insurance business to a nonaffiliated company; (ii)

with affiliated entities of your financial advisor or any bank or credit union that your financial advisor is affiliated with; and (iii) with Affiliates of

Securities America that you do not already have an existing relationship with for the purpose of marketing products or services to you.

In addition, Securities America and its Affiliates (where applicable) have signed the Protocol for Broker Recruiting (“Protocol”) which allows

the financial advisor servicing your account to take certain limited information in the event he/she leaves Securities America or an Affiliate and

joins another firm which has also signed the Protocol. The information your financial advisor can take is limited to your name, your address,

your phone number, your email address and the title of your account. If you choose to Opt-Out Securities America or an Affiliate will notify your

financial advisor of your decision to keep your personal information confidential and that you do not want your personal information shared by

your financial advisor with his/her new firm.

Questions? Go to www.securitiesamerica.com

What we do

How do Securities

America and its Affiliates

protect my personal

information?

To protect your personal information from unauthorized access and use, we use security measures that comply with applicable state

and federal laws. These measures include computer safeguards and secured files and buildings.

We train our employees and financial advisors in the proper handling of personal information. We require companies that help

provide our services to you to protect the confidentiality of personal information they receive.

How do Securities

America and its Affiliates

collect my personal

information?

We collect your personal information, for example, when you:

open an investment account or an advisory account

apply for insurance

seek advice about your investments

share information about your investment or retirement portfolio

We also collect your personal information from others such as credit bureaus, affiliates, or other companies.

Why can’t I limit all

sharing?

Federal law gives you the right to limit only

sharing for Affiliates’ everyday business purposes—information about your creditworthiness

Affiliates from using your information to market to you

sharing for non-affiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

2015

Questions? Go to www.securitiesamerica.com

What we do

How do Securities

America and its Affiliates

protect my personal

information?

To protect your personal information from unauthorized access and use, we use security measures that comply with applicable state

and federal laws. These measures include computer safeguards and secured files and buildings.

We train our employees and financial advisors in the proper handling of personal information. We require companies that help

provide our services to you to protect the confidentiality of personal information they receive.

How do Securities

America and its Affiliates

collect my personal

information?

We collect your personal information, for example, when you:

open an investment account or an advisory account

apply for insurance

seek advice about your investments

share information about your investment or retirement portfolio

We also collect your personal information from others such as credit bureaus, affiliates, or other companies.

Why can’t I limit all

sharing?

Federal law gives you the right to limit only

sharing for Affiliates’ everyday business purposes—information about your creditworthiness

Affiliates from using your information to market to you

sharing for non-affiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

2015

 

Broadridge Advisor Solutions
15050 Avenue of Science, Suite 200
San Diego, CA 92128

Telephone: 800.233.2834
Fax: 858.592.6267

Email: Sales@EmeraldTools.com

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Privacy Policy

Automatic Information and "Cookies"

When someone visits our website, our Web server recognizes only the visitor's domain name, not his or her E-mail address. This information is used to improve the content of our Web page and is then discarded. We do not partner with or have any special relationships with any advertising companies and your information is not shared with other organizations for commercial purposes.

In the process of interacting with our website, "cookies" are used to enhance your use of the website. However, we do not utilize any tracking cookies nor do we retain any information from your web browser to alert or otherwise enable our servers to personalize future visits to our website.

Information Collection

We do collect other contact information at various places on our website. This information may include:

To further illustrate such interaction for example, when a website visitor wants more information about a specific Emerald product or service some information may be requested and require submission prior to proceeding. This volunteered information is used only for the specific purpose for which it was given by the website visitor, and is not shared with other organizations for other purposes. Thus, persons who supply us with their postal address will only receive the information for which they provided us their address. Persons who supply us with their telephone number on line will only receive telephone contact from us with information regarding orders they have placed on line.

Outside of the website, Emerald will never request that you submit your username or password, credit card information or other personal information via email correspondence. If you ever receive an email that appears to be from Emerald requesting such information, it should be considered "phishing" and you should not respond.

If you do not want to receive E-mail from us in the future, please let us know by sending us e-mail at the above address, calling us at the above telephone number, or writing to us at the above address.

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. Any changes to our information practices will be posted to our website and we will provide a mechanism for those who so choose to opt out of these new uses. If you are concerned about how your information is used, you should check back at our website periodically.

If you would like to maintain the accuracy of any information we maintain, you may request a copy by sending us E-mail at the above address, calling us at the above telephone number, or writing to us at the above address.

We have appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected.

If you feel that our website is not following its stated information policy, you may contact us at the above addresses or phone number, The Direct Marketing Association's Committee on Ethical Business Practices at mgoldberger@the-dma.org, state or local chapters of the Better Business Bureau, state or local consumer protection office, The Federal Trade Commission by phone at 202.FTC-HELP (202.382.4357) or electronically at http://www.ftc.gov/ftc/complaint.htm.

Linking to/from Other Websites

Emerald's website may provide links to 3rd party websites. Those websites are maintained by 3rd parties and will be covered by their own independent Privacy Policies. Emerald encourages you to review those policies and determine whether their practices are adequate according to your standards.

Additionally, you may have come to Emerald's website by virtue of having accessed a 3rd parties website and followed a link resident on that site. Emerald's website is not bound by any 3rd party declarations of Privacy and is not bound by any terms that may be called out at such 3rd party websites.

Acceptance

By using Emerald's website, you accept the terms herein and consent to our use of information that you provide according to this Privacy Policy. Changes and or additions to this Policy are possible at any time so your regular review of these provisions is encouraged.