NUSOURCE FINANCIAL, LLC’S POSITION ON PRIVACY AND DATA PROTECTION

As a leading provider of customer transaction solutions, NuSource Financial is committed to protecting personal information it gathers about its employees and customers. NuSource Financial considers data protection a customer satisfaction issue. We meet all customer expectations in our solutions, products and services, as well as in our business practices.

NuSource Financial believes that individuals have the right to be informed about the information being collected about them and about its intended use. They have the right to review information being retained by NuSource Financial and must be informed of the appropriate measures to update information or correct inaccuracies. Individuals have the right to decline having their personal data used for any purposes.

NUSOURCE FINANCIAL WEB SECURITY

When you visit us at www.nusourcefinancial.com you can feel secure that NuSource Financial is respecting your privacy. The only private information available on our website is that provided by you at our request. We do not give or sell information provided to third parties. Some of our web pages may use “cookies”. A cookie is a small data element sent from a web page to a browser and stored in the user’s system.

NuSource Financial uses the data collected from cookies to help determine how many people visit its site and what pages they view. We use this information to better serve all visitors as we improve our site content and design. You can set your Web browser to warn you before you accept a cookie. We do collect information on the domains from which people visit us. We gather data simply to track trends in our site traffic as the basis for making improvements.

Information collected for this purpose is never shared with third parties. NuSource Financial is committed to protecting personal data on its website just as we are committed to helping our customers protect the privacy of their customers.

NUSOURCE FINANCIAL PERSONAL DATA PROTECTION PRINCIPLES

NuSource Financial recognizes that appropriate protection and management of personal data is a critical element in enabling consumers to realize the potential of global electronic commerce. NuSource Financial also recognizes that its long tradition of protecting employee personal data is encountering new challenges as its personnel databases and systems become increasingly electronic and global.

NuSource Financial has therefore adopted the following privacy principles for the protection of consumer and employee personal data. (Personal data is defined as any information relating to an identified or identifiable individual.) NuSource Financial will follow these principles, consistent with applicable local laws, in all its operations globally.

  1. Providing Information on Data Protection Policies: NuSource Financial will provide consumers and employees with easily understood information about NuSource Financial’s policies regarding the collection, use, and disclosure of personal data.

  2. Limiting Data Collection and Use: NuSource Financial will limit the collection and use of personal data to that which is needed for valid business purposes or to comply with local law, and any such data will be obtained only by lawful and fair means.

  3. Ensuring Data Accuracy: NuSource Financial will strive to maintain the accuracy of the personal data held, including establishing, as appropriate, mechanisms allowing consumers and employees to have the opportunity to review and correct their personal data.

  4. Enabling Informed Choice: NuSource Financial will furnish consumers and employees with information on the intended use of personal data, and with mechanisms permitting the exercise of choice on its disclosure. More specifically: Consumers — NuSource Financial will not release personal data to unaffiliated third parties, unless (1) the consumer requests it; (2) the data is provided to help complete a consumer-initiated transaction; (3) the disclosure is required by law; or (4) the consumer has been informed about the possibility of such disclosure and has decided not to opt out. Employees – NuSource Financial will not release personal data to unaffiliated third parties, except and only as specifically provided for, under internal corporate management policies. If employee or consumer personal data is provided to an affiliated third party (e.g., contractors and partners), NuSource Financial will require the third party to adhere to similar data protection principles that provide for keeping such data confidential.

  5. Safeguarding Security: NuSource Financial will take appropriate steps to ensure that personal data is protected from unauthorized access and disclosure, including limiting access to such data only to those employees with a business need to know.

  6. Adapting Privacy Practices to Electronic and Online Technologies: NuSource Financial will apply these principles via practices that have the equivalent effect regardless of the specific technologies employed for data collection and use. Consumers and employees should have a reasonably consistent expectation of privacy in both electronic and paper-based environments.