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Privacy Statement

Since it was founded in 1974, RINET Company, LLC (“RINET”, “we”, “us”) has conducted its business with the goal of providing the highest degree of service to its clients with the utmost regard for ethical standards, fiduciary duties and compliance with applicable law. We are committed to protecting the confidentiality, integrity and security of any nonpublic personal information (“Information”) of our clients and prospective clients and preventing unauthorized access to, or use or disclosure of such Information.

We require a certain amount of Information about you in order to provide you with investment products, financial advice or other services. We limit the collection and use of such Information to the minimum we require in order to provide you with high-quality services and products. We will not share Information about you with third parties, other than sub-advisors approved by you and/or RINET’s Investment Committee (collectively, “Approved Sub-Advisors”), your accountant and your attorney, except (i) for the specific purposes listed below, to the extent necessary to conduct our business, (ii) as required or otherwise permitted by law or (iii) as you may permit in writing.

This privacy policy and notice (the “Policy”) applies to individuals who obtain financial products or services from RINET primarily for personal, family or household purposes, regardless of whether such individuals have a customer relationship with us. A copy of this Policy will be provided to: (i) individuals who obtain a financial product or service from us that is to be used primarily for personal, family or household purposes, before we disclose any Information about any such individuals to any nonaffiliated third party, unless such disclosure is required or permitted by law; (ii) individuals who become RINET customers, not later than when a customer relationship is established; and (iii) all existing customers on an annual basis during the continuation of the customer relationship.

The Types of Information We Collect: We obtain most Information directly from you when you apply for, use or access our financial products or services. We may verify this Information or obtain additional Information from certain government agencies. The types of Information we gather include basic personal information such as your name, address, phone number, email address, social security number, assets and income, as well as information related to your transactions with RINET, our affiliates or others, such as your account balances, transactions history and claims you make.

Steps We Take To Safeguard Your Information: We require our employees to safeguard the confidentiality of your Information. Each employee is required to comply with this Policy and our established procedures, and we restrict access to Information about you to those employees who need to know the Information to administer our products or services. We also maintain physical, electronic and procedural safeguards that comply with applicable laws to guard your Information.

Disclosure of Information: We may disclose all of the Information we collect about you when directed to do so by you or your Approved Sub-Advisor, when we believe it is necessary for the conduct of our business, or where disclosure is required or permitted by law. For example, we may disclose Information to attorneys and other professionals, for audit or research purposes, or to law enforcement officials to aid in preventing fraud, money laundering, or other matters. We may also disclose Information to third party service providers: (i) to enable them to provide business services for us or Approved Sub-Advisors, such as performing computer or data-related maintenance or processing services; (ii) to facilitate the processing or servicing of your transactions; (iii) to assist us in offering products or services to you or your Approved Sub-Advisor; or (iv) for credit review and reporting purposes. Unless otherwise directed by you, RINET requires all third parties who receive Information about you— other than your accountant, attorney and Approved Sub-Advisor—to sign confidentiality agreements. We do not make any disclosures of Information to other third parties that may want to solicit your business.

Further Information: We reserve the right to change this Policy, and will inform you of any substantive changes. If you have any questions regarding this Policy, please call 617.488.2700 or e-mail info@rinetco.com.