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Privacy Policy Disclosure

As a member of the financial services industry, JaaFal is extremely sensitive to the desire of retirement plan sponsors and plan participants to maintain the privacy of their valuable information. Indeed, we share the same desire for privacy with respect to our own information and data as well as the information and data of our customers, participants and business partners. To demonstrate our dedication to respecting the privacy of your information, we have developed this Privacy Policy to disclose what types of information we may collect from you and how we might use that information. This Privacy Policy applies to JaaFal, Inc. and its following subsidiaries and affiliates (unless otherwise indicated, collectively referred to as "JaaFal," the "JaaFal Group" or "we", "us" or the like):

For purposes of this Privacy Policy, the term "Web Site" refers to each of the web pages contained in all the web sites owned, operated or controlled by us.

As described below, some of your nonpublic personal information is disclosed to affiliated and carefully selected nonaffiliated third parties and used by us and such third parties. By accepting the Terms of Service or this Privacy Policy, you expressly consent to our use and disclosure of your nonpublic personal information in the manner disclosed below. Please note in particular that by accepting the Terms of Service or this Privacy Policy, you acknowledge and agree that the Pennsylvania Electronic Transactions Act ("PETA") applies to the transactions conducted on or through the Web Site and that you and JaaFal may conduct any transactions contemplated herein by electronic means. This means that you expressly agree to receive communications and disclosures from JaaFal, including those relating to privacy matters, via electronic mail, the Web Site or other electronic means. Because of the rapidly evolving legal and business environment surrounding privacy on the Internet, please be aware that JaaFal must reserve the right to modify this Privacy Policy at any time, in which event we will provide you with reasonable notice. Please bear in mind that this Privacy Policy only addresses our use and disclosure of information we collect from you. To the extent that you disclose information or data to other parties or other web sites on the Internet, including web sites that you may reach through JaaFal's Web Site, different rules or policies may apply. Unless specifically noted below, we treat the nonpublic personal information of our former customers in the same manner as that of our existing customers.

What Nonpublic Personal Information of Mine Does JaaFal Collect?

JaaFal collects information through interactive questionnaires, applications or other forms, such as our interactive retirement benefits plan design tool and our registration or enrollment application forms. We may also offer additional tools or request other information from you from time to time, such as, for example, in connection with investment yield calculators or your investment portfolio diversification and investment objectives. Should you wish to not reveal this kind of information, you should abstain from completing the applicable questionnaire or form. Please be aware, however, that certain information is required in order for us to provide products and services. If you elect not to share required information, you may not be able to receive such products and services.

If you voluntarily send us any correspondence, such as emails or letters, we may retain and use such correspondence and information in a file specific to you.

In order to measure the usefulness and efficiency of our Web Site, we automatically track certain information from all visitors to our Web Site. The types of information we might track may include the Internet address that you just came from, which Internet address you go to, what browser you are using and your computer's unique Internet Protocol address.

Like most interactive web sites, we use "cookies" on certain pages of our Web Site. "Cookies" are small data files that are stored on your hard drive which store certain information accessible to our Web Site, such as your password and any information content preferences you may voluntarily set at our Web Site. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on our Web Site and you may be required to reenter your password more frequently during a session.

If you are a plan participant, we collect much of your nonpublic personal information directly from your plan sponsor or employer as required to provide you with the products and services requested by your plan sponsor or employer.

In addition, we collect nonpublic information about you from your transactions and experience with us, our affiliates or others.

How Does JaaFal Use My Information?

If you are a retirement plan sponsor or benefits professional, we use the information you provide in response to our plan design questionnaires or other applications or forms in order to assist you in designing, developing, managing and servicing a retirement plan for your employees and plan participants or clients, including in selecting products and services we offer to include in your plan or your client's plan, and to provide the services and products you request.

If you are retirement plan sponsor, plan participant or benefits professional, we use the information you provide for purposes that are compatible with the reasons we requested it or you provided it. For example, we use the information you provide to try to fulfill your request for information about certain products and services, to conduct trades through your account and to evaluate your financial needs and goals.

We may use your email address, your mailing address and phone number to contact you regarding administrative notices, new product offerings and communications relevant to your use of our Web Site or products and services offered by JaaFal and its affiliates.

We may aggregate some or all of the information described above in an effort to improve our marketing and promotional efforts, to statistically analyze Web Site usage, to improve our content and product offerings and to customize our Web Site's content, layout, and services. This information is compiled and analyzed on an aggregated basis, and we do not generally track an individual's nonpublic personal information, although we may do so for our own internal purposes and for any purposes permitted by law.

We may use your nonpublic personal information to determine, and if necessary enforce, your compliance with the Terms of Service. We may also use your nonpublic personal information as otherwise permitted by law.

What Categories of Information Does JaaFal Disclose and to Whom is it Disclosed?

We will not sell, rent or disclose nonpublic personal information about you to any entity that is not a member of the JaaFal corporate family ("third parties"), except as permitted by law. The confidentiality of your nonpublic personal information will continue to be maintained consistent with this privacy notice even if you decide to close your account(s), your account becomes inactive, or when you otherwise cease to do business with us.

In order for JaaFal to offer you quality products and services, we work with our affiliated companies and some third parties. We may disclose to these entities nonpublic personal information about you as necessary to provide these products and services to us for your benefit or directly to you. JaaFal is committed to taking all reasonable precautions to ensure that its subsidiaries, affiliates, agents and these third parties respect the privacy of your nonpublic personal information and use it only for its intended purposes. The following describes the categories of parties to whom we may disclose your nonpublic personal information:

JaaFal Subsidiaries, Affiliates and Alliance Partners. We will share much of our data, including nonpublic personal information about you as described above, with our subsidiaries, affiliates and alliance partners that are directly or indirectly involved in providing products and services to our customers, plan sponsors and plan participants. Examples of such parties include our regional offices, JaaFal Advisors, Inc. and JaaFal Securities LLC. To the extent that these entities obtain access to your information, we will endeavor to ensure that they will treat it with the same care and confidentiality as they treat information they obtain from their other users. We usually require our subsidiaries, affiliates and alliance partners to follow privacy practices no less protective than our practices described in this Privacy Policy.

Co-Brand Service Providers. JaaFal may offer a number of co-branded services and products with nonaffiliated third parties, such as mutual fund analysis companies, investment advisors, human resource service providers and financial calculator tool developers. If you are eligible to choose to use these optional services, we may provide your nonpublic personal information to the co-brand provider offering such services or products in order to permit you to obtain or use the applicable products or services. Because we do not control the privacy practices of these third parties, you should evaluate their practices before deciding to obtain or use their products or services. In addition, a co-brand provider may directly ask you for certain information to assist it in providing you with products or services.

Suppliers and Service Providers. We use some nonaffiliated third party suppliers and service providers to directly or indirectly provide products and services to our customers, plan sponsors and plan participants, and we may need to share your nonpublic personal information with them in order to permit them to provide the products and services. In some instances, the third party supplier or service provider may collect information directly from you. You should note, however, that you may not be able to obtain a particular product or service without us or you providing the information requested. These third party suppliers and service providers are usually bound by law, contract or trade custom to only access and use your information in accordance with the purpose it has been provided. We do not permit any third party supplier or service provider to sell or lease your information to third parties.

In Accordance With Law. JaaFal expressly reserves the right to disclose or report any of your information to any third party as permitted by law, including, without limitation, in circumstances where we reasonably deem it necessary to comply with applicable laws, rules and regulations, to cooperate with government or industry regulators and law enforcement officials, to perform any necessary credit checks or collect or report debts owed to us, to protect our rights or property or upon the reasonable request of a mutual fund in which you have chosen to invest.

Marketing. We may disclose nonpublic personal information we collect, as aggregated or otherwise, to nonaffiliated third parties who perform marketing services on our behalf or to other financial institutions with whom we may have joint marketing arrangements in order to make a variety of financial services available to you. These third parties are usually bound by law, contract or trade custom to only access and use your information in accordance with the purpose it has been provided. We would not permit any of these third parties to sell or lease your information to third parties.

Because we already limit the sharing of your nonpublic personal information as outlined above, no action is necessary on your part to limit such sharing.

What Kinds of Security Procedures Does JaaFal Keep In Place?

We restrict access to nonpublic personal information about you to those persons who have a reasonable business need to know that information to provide products or services to the applicable plan sponsor, participant or benefits professional. JaaFal maintains physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

A Special Note on Children.

Children are not eligible to use our services and we ask that minors under the age of 13 do not submit any personal information to us.

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