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OUR COMMITMENT TO PRIVACY

This is the Privacy Policy for CNL Securities ("CSC"), a registered broker/dealer and member of the Financial Industry Regulatory Authority (“FINRA”) and Securities Investor Protection Corporation (“SIPC”). This Privacy Policy addresses CSC's privacy practices with respect to the limited circumstances whereby it may collect personal non-public information. Other businesses operated by affiliates of CSC may have separate privacy policies, which can be found by a clearly labeled link from the home page of each such Web site(s). This Policy is designed to assist you in understanding how we collect, use and safeguard the personal information you provide to us and to assist you in making informed decisions when using our products, services and Web Site. This statement will be continuously assessed against new technologies, business practices and our customers' needs.

We are proud of our privacy protection practices and procedures and we want you to know how we protect your information and use this information to service your account. Please take a moment to review our privacy policy as described herein. Please take note that your privacy is not for sale. Simply put, CSC does not and will not sell your personal non-public information to anyone, for any reason, at any time.

By using our Web site or submitting documents to us containing personal non-public information, you consent to our collection of your personal information as described in this Privacy Policy. If we change our privacy policies and procedures, we will post those changes on our Web site to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Where required to do so by law, we also will provide you with a notice by mail or email of any changes to this Privacy Policy.

Users who are not resident to the United States should not submit their personal information to our Web site or by submitting documents containing such information unless they agree that their personal information will be treated in accordance with United States laws and the terms of this Privacy Policy. If you have any questions about the use of your personal information, please contact us at cscprivacypolicy@cnl.com before submitting your personal information.

WHAT INFORMATION DO WE COLLECT?

You may provide us with two types of information: (1) personal information you knowingly choose to disclose to us through documents submitted to CSC or its affiliates and over the Web site and (2) Web site-use information collected as you and others browse and use our Web site.

Personal Information Submitted by You

When you submit documents to CSC or its affiliates, when you register on our Web site, and/or when you choose to request forms or information through our Web site, you may be asked to give personal information. For example, you may be asked to provide the following information:

  • Name
  • Postal or legal address
  • Email address
  • Home and business phone number
  • Other personal information (i.e., mother's maiden name)

When you invest in a product offered by or distributed through CSC, or if you register to use our services, request forms or information, or otherwise complete online forms or submit information, we may collect any information you provide in such documentation or communication.

Email Information

In addition to providing the foregoing information collected through your submission of documents to CSC or its affiliates or your use of our Web site, if you choose to correspond further with us through email, we may retain the content of your email messages together with your email address and our responses.

Web Site Use Information and "Cookies"

Similar to other commercial Web sites, our Web site utilizes a standard technology called "cookies" and Web server logs to collect information about how our Web site is used. Cookies are a feature of Web browser software that allows Web servers to recognize the computer used to access a Web site. They are small pieces of data that are stored by a user's Web browser on the user's hard drive. Cookies can remember what information a user accesses on one Web page to simplify subsequent interactions with that Web site by the same user or to use the information to streamline the user's transactions on related Web pages. This makes it easier for a user to move from Web page to Web page and to complete commercial transactions over the Internet. Cookies should make your online experience easier and more personalized. Information gathered through cookies and Web server logs may include the date and time of visits, the pages viewed, time spent at our Web site, and the Web sites visited just before and just after our Web site. This information is collected on an aggregate basis. None of this information is associated with you as an individual. If your browser is set to reject cookies, you may still use our site, but your ability to use or navigate some areas of our site will be impaired.

HOW DO WE USE THE INFORMATION THAT YOU PROVIDE TO US?

Broadly speaking, we use your personal information for purposes of administering our business activities, providing customer service, making other products and services available to you and target ads to you on other websites. Occasionally, we may also use the information we collect to notify you about important changes to our Web site, new services and special offers we think you will find valuable. You will be given the opportunity to notify us on the Web site of your desire not to receive these offers. We use Web site browser software tools such as cookies and Web server logs to gather information about our Web site users' browsing activities in order to constantly improve our Web site and better serve our customers. This information assists us to design and arrange our Web pages in the most user-friendly manner and to continually improve our Web site to better meet your needs.

SHARING INFORMATION WITH THIRD PARTIES

We may provide information collected on our Web site, Web site traffic patterns, related Web site information and as contained in documents submitted to CSC and its affiliates to our affiliates, and/or reputable third parties, for purposes, such as, targeted advertising, but this information will not include personally identifying data, except as otherwise provided in this Privacy Policy.

In the event that CSC or any of its affiliates and/or some of our assets are sold or transferred or used as security, the information collected on our Web sites may be transferred to third parties as part of that transaction. CSC may also provide such information or provide access to such information to our affiliates or to our business partners, vendors and/or service providers; however we will do so subject to appropriate confidentially agreements that obligate such partners, vendors and/or service partners to maintain and protect the confidentiality of such information.

If CSC is requested by law enforcement officials, our governing regulatory authorities or judicial authorities to provide information on individual users, we may, without your consent, provide such information. In matters involving claims of personal or public safety, CSC may provide your personal information to appropriate authorities without your consent or court process.

If you request CSC to share any personal non-public information with an outside person or entity (e.g. your attorney, accountant, family members, etc.) not currently authorized to receive such non-public confidential information, CSC will request written authorization from you and any other account holders to do so. A form titled "Authorization to Share Confidential Information" will be provided to the account owner(s) for completion. This form will authorize CSC to share information with specific parties that the account owners request be authorized to receive such information.

OPTING-OUT OF TARGETED ADVERTISING

In the event that you desire to opt-out from receiving targeted advertisements, you may do so by visiting the Network Advertising Initiative website opt-out page located at: networkadvertising.org/choices/ or the Digital Advertising Alliance opt-out page located at aboutads.info.

NOTICE OF CHANGES

Occasionally, we may also use the information we collect to notify you about important changes to our Web site. You will be given the opportunity to notify us of your desire not to receive these offers by clicking on a response box when you receive such an email or by sending us an email request at cscprivacypolicy@cnl.com.

HOW DO WE SECURE INFORMATION TRANSMISSIONS?

If you enter confidential personal information on our Web site, this information is not saved, captured or in any way otherwise stored by us.

Email that you may send to us may not be secure unless we advise you that security measures will be in place prior to your transmitting the information. For that reason, we ask that you do not send confidential information such as Social Security numbers to us through an unsecured email.

HOW DO WE PROTECT YOUR INFORMATION?

We know that security is a concern and we have developed and implemented administrative, technical and physical security practices and procedures designed to protect the confidentiality of your personal information and the security of our Web site. We will take measures which we believe are reasonable and appropriate to protect your information from unauthorized access or disclosure and accidental loss, alteration or destruction.

HOW CAN YOU ACCESS AND CORRECT YOUR INFORMATION?

You may request access to all your personally identifiable information that we collect by emailing cscprivacypolicy@cnl.com. Such requests will likely take at least 4 to 6 weeks to process. We may retain in our files information you have requested be removed from our databases in some circumstances, such as to resolve disputes, troubleshoot problems, enforce the Terms of Use of our Web Site, or as required by applicable law, rule or regulation. Further, such information is never completely removed from our databases due to technical constraints and the fact that we back up our systems and are required to retain certain information by law or regulation. Therefore, you should not expect that all of your information will be completely removed from our databases in response to your requests.

WHAT ABOUT OTHER WEB SITES LINKED TO OUR WEB SITE?

We are not responsible for the practices employed by Web sites linked to or from our Web sites nor the information or content contained therein. Often links to other Web sites are provided solely as pointers to information on topics that may be useful to the users of our Web site. Please remember that when you use a link to go from our Web site to another Web site, our Privacy Policy is no longer in effect. Your browsing and interaction on any other Web site, including Web sites which have a link to our Web site, is subject to that Web site's own rules and policies. Please read over those rules and policies before proceeding.

ADDITIONAL PRIVACY MEASURES YOU CAN TAKE

For those of our users who are concerned about security and confidentiality, we recommend that you use good general privacy protection and Web policies, such as the following:

  • Do not share your personal information with others.
  • Use one of the leading anti-virus software applications. Anti-virus software can protect your computer from "Trojan Horse" programs, which can send private information from your computer to an unauthorized person anywhere in the world.
  • Use your own computer when you access cnlsecurities.com. Using another person's computer means that you trust that person's computer to be safe, which in fact it may not be. If they do not follow adequate security procedures, their computer may harbor "Trojan Horse" programs, or other applications which can capture your personal data.
  • Keep your operating system up-to-date with the latest patches and security enhancements. New vulnerabilities in the Windows OS family are found virtually weekly, and Microsoft makes patches and upgrades freely available at http://windowsupdate.microsoft.com.
  • Use one of the leading personal firewalls to protect your computer from unauthorized entry. Personal firewalls can protect your computer from probes and attacks based on network protocols, and even allow you to prevent unethical users from finding your computer on the Web.

CONCLUSION

CSC restricts its requests for personal information to very limited circumstances. We do not maintain retail accounts. To the extent CSC does access your personal and account information, such access is limited to those of its employees and affiliates who need to know that information to provide services to you. CSC maintains physical, electronic, and procedural safeguards to guard your nonpublic personal information.

If you have any questions concerning CSC privacy policies and procedures, please feel free to contact us. Thank you.

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