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Effective Date: June 2002
Who we are
Hooker & Holcombe, Inc. is a firm of retirement plan professionals, providing employers with actuarial, administrative and consulting services. Hooker & Holcombe Retirement Services, Inc. is a wholly-owned subsidiary of Hooker & Holcombe, Inc., and specializes in investment management services for retirement plans. Throughout this Privacy Policy we refer to Hooker & Holcombe, Inc. and Hooker & Holcombe Retirement Services, Inc. collectively as "The Hooker & Holcombe Companies", or "we". This Privacy Policy applies to both entities. In conducting our business, we, by necessity, collect and process information about retirement plan participants. We recognize the importance of maintaining the private nature of the nonpublic personal information we are provided, whether provided by individuals themselves or by the plan sponsor to enable us to properly service the plan. In order to effectively conduct our business, however, we must sometimes share the nonpublic personal information we collect. This disclosure sets forth our privacy policy and practices concerning the collection and disclosure of nonpublic personal information. Please read this notice to learn more about our policies and practices.
To Whom This Policy Applies
The policies and procedures described in this notice apply to individuals who inquire about and/or obtain products or services from The Hooker & Holcombe Companies for personal, family or household purposes. This includes individuals who use the features of our Defined Benefit or Defined Contribution webpages to view information about their retirement plans. The term "you" will be used throughout to refer to such individuals. This policy does not apply to institutional or commercial entities.
Information we collect, and how we use it
We collect nonpublic personal information about you (collectively referred to herein as "Collected Information") from the following sources:
· information we receive from you or your authorized representative, whether in writing, in person, by phone, electronically, via the Internet or other means, including, for example, information you provide through our website, on applications or other forms;
· information we receive about you from your plan sponsor; and
· information about your transactions with us, our affiliates or others.
We also gather information about pages you visit on our website and the duration of your visit. We use this information solely within our organization for the purpose of improving and managing our website. In order, for example, to determine the level of interest in information available on our website and to help us design or improve our products and services, we may use standard software to collect information about visitors to our website and use such information to create summary statistics. This information is maintained only in aggregated form and cannot be used to identify you.
We use cookies in some instances, but only for the purpose of managing your current session on our website. "Cookies" are pieces of data stored on your computer tied to information about you. We use only temporary cookies and, accordingly, all cookies are removed from your hard disk when you log off your session.
Sharing of Nonpublic Personal Information
1. We do not sell your nonpublic personal information to anyone.
2. We do not disclose nonpublic personal information about you to any nonaffiliated parties, except as authorized by you or permitted by law. Our communication with affiliated parties may include, without limitation, (a) providing information to third parties that perform support services on our behalf or assist us in providing you with products and services that you request; (b) exchanging information with your plan sponsor to enable us to provide you with products or services that you request or otherwise service the plan in which you participate; and (c) sharing information within the Hooker & Holcombe Companies.
Protecting the Confidentiality and Security of Information
We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards to guard your nonpublic personal information.
For example, on our website we employ the following security-related techniques:
· User authentication procedures;
· Secure Socket Layer (SSL) 128-bit encrypted software, which requires the use of browsers with 128-bit encryption. Links are provided to the Netscape and Microsoft web sites, from which you can obtain free browser upgrades. We note, however, that our email services are NOT encrypted and, accordingly, ask that you refrain from sending personal nonpublic information to us via email unless you do so through a secure channel.
· Online access to an account will be disabled after three unsuccessful login attempts. A plan participant must contact his or her Human Resources department to get his or her account reactivated.
· Accounts will be automatically logged off if there is no keyboard activity for 20 minutes. To reestablish connection, a user must log on again.
In order to help maintain your nonpublic personal information in confidence, we ask that you (a) keep your username and password private and not share them with any third party; and (b) do not include personal information in email that you send to us unless you do so through a secure channel, since our email services are not encrypted.
Our website contains links to websites maintained and controlled by third parties. Please be aware that The Hooker & Holcombe Companies are not responsible for the privacy or security practices of third parties. We encourage you to be aware when you leave our website and to read the privacy and security statements of each and every website that you visit. This Privacy Statement applies solely to the practices of The Hooker & Holcombe Companies.
Correction procedures
Please contact your plan sponsor's Human Resources department to report any inaccurate or missing data on your account. We can accept only those corrections and additions that are submitted to us from the plan sponsor.
Also, if you are concerned about on-line access to your information, you may have online access to your account terminated at any time. Please contact your plan sponsor's Human Resources department to have such access terminated.
If you have any questions or concerns about our Privacy Policy, please call 860-521-8400 or send email to info@hhconsultants.com.
Keeping up with our Privacy Policy
If we materially change this Privacy Policy, we will notify you of such changes, as required by law. The Privacy Policy contained in this notice supersedes all previous notices or statements with respect to the subject matter described herein.