Privacy Policy Notice

In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA requires certain

financial institutions, such as investment advisor firms, to protect the privacy of client information. Federal law gives clients the right to limit some but not all sharing of your Personal Information. In situations where a financial institution does disclose client information to nonaffiliated third parties, other than permitted or required by law, clients must be given the opportunity to opt out or prevent such disclosure.

Commitment to Your Private Information

Systematic Wealth Management, Inc. (“Systematic”) recognizes that our relationships with current, former and prospective clients are based on integrity and trust. We are committed to safeguarding the confidential information of its current, former and prospective clients. Systematic holds all Personal Information provided by clients in the strictest confidence and it is the objective of the firm to protect the privacy your privacy. Systematic will not sell your Personal Information nor disclose your Personal Information to anyone unless it is required by law or at your direction.

Personal Information Systematic Collects

Systematic collects non-public Personal Information, to the extent of the law, about its clients and/or prospects from the following sources:

• Account Applications and other forms, which may include name, address, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.

• Social security, number or tax identification number, total assets, income, and accounts at other institutions.

• Account history, which may include information about the transactions and balances in accounts with Systematic and/or other institutions.

• Verification information you or a consumer reporting agency, may supply us to identify you in connection with a financial product or service, such as your demographic information, investment preferences, location information, or financial information; and

• Correspondence, which may include written, telephonic or electronic communications.

Why We Collect Your Information

We gather information about you so that we can:

• Help design and implement the investment and planning related services we provide you.

• Provide information, products or services you requested.

• Enforce our Terms of Use and any other agreements between you and Systematic.

• Detect and prevent fraud or other criminal activities.

• Comply with the Federal and State laws and regulations that govern us.

• To improve your website experience by remembering your preferences and repeat visits.

How We Handle and Share Personal Information, Permitted under Law

As emphasized above, Systematic does not sell Personal Information about current, former or prospective clients to third parties. Systematic restricts access to your personal and account information to employees who provide services to you;

We may share your non-public Personal Information, for example:

• With service providers who are authorized to use your Personal Information only as necessary to support our business operations, such as those who provide data storage, payment, custodial, technology support and services, client service, risk solution provision, analytics, and fraud prevention.

• In order to complete certain transactions or account changes that a client directs, it may be necessary to provide certain non-public Personal Information about that client to companies, individuals, or groups that are not affiliated with Systematic. For example, if a client asks Systematic to transfer assets from another financial institution, Systematic will need to provide certain non-public Personal Information about that client to the company to complete the transaction.

• With government entities, consumer reporting agencies or other third parties in response to subpoenas

In all such cases, Systematic will provide the third party with only the information necessary to carry out its assigned responsibilities and only for that purpose. In addition, Systematic requires these third parties to treat Systematic clients’ non-public information with the same high degree of confidentiality that Systematic does.

How We Safeguard Personal Information

Systematic seeks to protect Personal Information by implementing and maintaining reasonable physical, electronic, and procedural security measures and safeguards designed to protect Personal Information within our organization. Systematic provides employee training in the proper handling of Personal Information.

Although we cannot fully disclose all that we do to protect the personally identifiable information of our clients, here are just a few measures we take:

• We employ strong authentication and password protocols.

• We enforce inactivity timeouts on our computers.

• We maintain and regularly test our firewalls.

• We continuously update our anti-virus and anti-malware protection.

• We employ threat monitoring/intrusion detection.

• We utilize encryption to protect our client and employee data.

• We have mandatory training for all employees.

Cookie Policy

Systematic use cookies, pixels, and other tracking technologies for various purposes, such as monitoring our marketing campaign performance. Systematic also uses third-party analytics services (like Google Analytics) to gather this information for analysis.

A cookie is a small file that a website transfers to your computer to allow your browser to remember information about your session on that website. They are typically one-pixel, transparent images located on a webpage or in an email —or similar technologies may be used.

They may also be used when you are served advertisements, or you otherwise interact with advertisements outside of our online services. These are principally used to help recognize users, assess traffic patterns and measure site or campaign engagement.

Systematic’s site temporarily stores certain information about your visit to help us to better align our content and the website design with your needs. The information these cookies collect includes, but is not limited to:

• Your computer’s IP address

• The date and time you accessed the site

• The Universal Resource Locators (URLs) of the pages you visit on our website

• The domain and/or URL of the site you came from, if you clicked a link there that brought you to our website

We may share this information internally or third-party contractors as needed. This information is only used to improve the website and enhance our visitors’ experience.

Links to Other Websites

This site may contain links or references to other Websites. Please be aware that we do not control other Websites and that, in any case, this Privacy Policy does not apply to those Websites. We encourage you to read the privacy policy of every Web site you visit. We are not responsible in any way for the content of such Web sites.

Children

Our web site is not directed to children under the age of 18 years. By using our website, you represent and warrant that you are at least 18 years old.

We respect the privacy of children and do not knowingly collect or retain personally identifiable information or non-public information from children under the age of 18 through our website. However, we may process non-public information, on a child’s behalf, with permission from the parent or guardian.

To the extent we have unintentionally collected any non-public information on our website from a person under the age of 18 years old, you may request and obtain removal of this non-public information. You may make such request by emailing us at info@systematicwealth.us.

Your request must provide information to us that enables us to verify your identity and, as applicable, of your authorized representative, in order for us to respond to your request. Upon receiving a request pursuant to this Policy, we will confirm receipt within 10 days and provide you with information about how we will verify and process the request. We will take reasonable steps to verify your identity (or the identity and authority of your authorized representative) prior to responding to your requests.

Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Former Clients

Even if we cease to provide you with financial products or services, our Privacy Policy will continue to apply to you and we will continue to treat your non-public information with strict confidentiality.

Notice to Persons Accessing Systematic’s website Outside the United States

If you access Systematic’s website outside the United States, any information you provide to us through the Systematic website will be transferred out of that jurisdiction and into the United States. If you do not want your personally identifiable information to leave that jurisdiction, do not provide the information to us. By providing personally identifiable information to us, you explicitly consent to the transfer of your information to the United States.

Changes to this Privacy Policy Notice

Systematic will provide each client with an initial notice of the current Privacy Policy Notice when the client relationship is established. Additionally, Systematic may occasionally amend this Privacy Policy Notice at any time. If we decide to use Personal Information in a manner that is materially different from that stated at the time it was collected, we will notify you of such changes prior to implementing them by posting a revised Privacy Policy Notice with a new “Last Updated” date. Systematic shall also provide each client with the current Privacy Policy Notice at least annually.

We encourage you to check our website frequently to see when this Privacy Policy Notice was last revised and to be informed of how we are committed to protecting your information.

Any Questions

If there are any questions, regarding this Privacy Policy Notice, please contact us at info@systematicwealth.us