Privacy and Security Policy

You can count on NextStep to provide you with the responsive, professional service you deserve, and to protect your privacy and security along the way. The statements below summarize NextStep’s procedures and policies with regard to information collected on client plans and their participants. These procedures and policies are subject to revision from time to time.

• We do not sell customer information to third parties.
• We do not share customer information with outside parties who may wish to market their products to you.
• Within the NextStep Defined Contribution, Inc. companies (NextStep), we safeguard your customer information carefully.

At NextStep, we value your relationship, and we commit to working diligently every day to honor the trust you place in us. We also believe that protecting your privacy is an integral part of the customer service we provide to you. NextStep is committed to protecting client information in every transaction, at every level of our organization.

How we Protect and Use Customer Information

We safeguard the security and integrity of customer information.
We are committed to protecting the security and integrity of client information through procedures and technology designed for this purpose.

• We limit access to participant information and employees are required to honor our code of conduct, which includes standards to protect participant privacy and confidentiality.
• We maintain policies and procedures regarding the proper physical security of workplaces and client records.
• We use technological means (such as backup files, virus detection and eradication software, firewalls, and other computer software and hardware) to protect against unauthorized access or alterations to customer data.

We collect and maintain client information as part of servicing our client plans and our relationship with you.
In the course of servicing client plans and their participants, we collect information about the plans, their service providers and the participants from a variety of sources, including the information the plan fiduciaries and participants provide to us on applications or forms, such as account information with other institutions and income levels.

Information may be used by NextStep, as well as by authorized third parties, for a number of purposes, such as:

• To protect client accounts from unauthorized access or identity theft
• To process participant requests such as loan applications
• To service client accounts by sending account statements

Although NextStep does share information with authorized third-parties, we do not share information with outside parties whose purpose is to market third-party products to our clients.

We may disclose the information we collect, as described above, with nonaffiliated third parties that are acting on our behalf, including companies that perform support services for NextStep, such as data processors, accounting services, technical systems consultants and programmers, or companies that help us inform you of NextStep products and services. Those third parties will be required to agree to protect the privacy and confidentiality of the client plans and their participants.

There are other situations when we may disclose to third parties the client information we collect as permitted or required by law. Third parties could include government entities, courts or other entities (in response to qualified domestic relations orders, subpoenas and other legal processes), and those with whom you have requested us to share information.

In addition, if some or all of NextStep’s business assets are sold or transferred, we generally would transfer the corresponding information regarding the relevant client plans, which we would ask that the transferee maintain in confidence. We also may retain a copy of such information solely for archive purposes.

Revisions to the NextStep Privacy Statements - From time to time, NextStep may, and reserves the right to, revise its privacy policies and procedures. We would change this statement accordingly and such revision shall be effective upon posting. A notice will be posted on this website when such revision is made, so we encourage you to review this privacy statement periodically.

Links - This website contains links to other sites. Each such site will have its own policy regarding privacy. NextStep is not responsible for those other sites’ policies and if you visit one of these sites, it is recommended that you review and understand the privacy policy on that site.

Your Consent - By using the NextStep websites, you consent to our use of the information that is collected or submitted as described in this privacy statement.

Original Privacy Statement posted April 10, 2009; revised September 14, 2009.