What Does STBS Tax and Business Services, LLC (“STBS”) Do With Your Personal Information?

Accounting firms are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. Federal law gives the customer the right to limit some but not all sharing of nonpublic personal information. It also requires us to tell you how we collect, share, and protect your nonpublic personal information.

TYPES OF NONPUBLIC PERSONAL INFORMATION (“NPI”) WE COLLECT

We collect nonpublic personal information about you that we receive from you, your agents or other third parties or sources. The types of your personal nonpublic information STBS collects and shares depend on the services that it provides to you. This information can include, but is not limited to: your social security number, employment and residential information, name, address and date of birth, income, net worth, account numbers, account balances, and tax and accounting related information.

STBS's web servers collect domain names and/ or IP addresses of users to measure what pages and features are accessed by our visitors. This information helps us administer the site, improve content and gather broad demographic information for aggregate use. STBS may use "cookies" or similar files or scripts throughout its website to enhance your convenience in using our websites, to improve search functionality or to hold information that you would otherwise need to re-key. "Cookies" are text files collected by a user's web browser. If you do not wish to accept "cookies" from our website, you may configure your web browser so that it does not accept "cookies"; however, you may lose certain functions available on our website.

PARTIES TO WHOM WE DISCLOSE INFORMATION

Investment advisers may need to share the nonpublic personal information of their clients, internally, with their employees, with their Affiliates and with the employees of their Affiliates, and, externally, with their independent contractor service providers, including but not limited to insurance companies, custodians and certain third-party vendors, in order to run their everyday business. The table below lists the reasons that STBS may share your nonpublic personal information, and whether you can limit this sharing.

STBS’s undertaking not to share as indicated in the table above applies in all events,

• except as permitted or directed by any client according to a written instruction or authorization,
• except to facilitate the investment advisory services to STBS clients provided by Waverly Advisors, LLC and those Non-Affiliates that participate, directly and indirectly, in the provision of investment advisory services by Waverly Advisors, LLC, or
• except as required or permitted by any applicable agreement, rule, regulation or law (STBS may disclose or report personal information in limited circumstances where STBS believes, in good faith, that disclosure is required or permitted under law, for example, to cooperate with regulators or law enforcement authorities).

Sharing Practices:

How does STBS protect my nonpublic personal information?

To protect your nonpublic personal information from unauthorized access and use, STBS maintains physical, electronic, and procedural safeguards that comply with federal standards. These measures include restricting access to your personal and account information to those employees who need to know that information in order to provide services to you, as well as computer safeguards and secured files and physical offices.

How does STBS collect my nonpublic personal information?

STBS collects certain nonpublic personal information from you, for example, when you open an account.

Why can’t I limit all sharing?

Federal law gives you the right to limit sharing only for:

• Affiliates’ everyday business purposes – information about your creditworthiness;
• Affiliates or Non-Affiliates from using your information to market to you. State laws and individual companies may give you additional rights to limit sharing.

What happens when I limit sharing for an account I hold jointly with someone else?

Your choices will apply to everyone on your account.

How Does STBS Treat My Personal Information Once I Am No Longer A Client?

STBS will provide nonpublic personal information about former clients only if required to do so by law or regulation, or in connection with continuing obligations of the former clients or the enforcement thereof (including the obligation of the former clients to pay STBS or any of its Affiliates for any outstanding fees, charges or costs), or to those parties who need such information in order for STBS (directly or indirectly) to carry out any continued obligation with respect to the services covered by the former accountant/client relationship.

Definitions:

“Affiliates” means companies related by common ownership or control. They can be financial and non-financial companies. Our Affiliates include IQ Companies, LLC and StrategIQ Financial Group, LLC.

“Non-Affiliates” means companies not related by common ownership or control. They can be financial or non-financial companies.

STBS does not share with Non-Affiliates so they can market to you.

“Joint Marketing” means a formal agreement between Nonaffiliated companies that together market financial products or services to you. STBS does not engage in Joint Marketing.

“Privacy Policy” means the policies set forth in this privacy policy, as amended from time to time. STBS’ use of your nonpublic personal information is subject to this Privacy Policy, as the same is in effect at the time of use. The provisions of this Privacy Policy supersede all previous notices or statements regarding STBS’s privacy policy.

Changes:

STBS reserves the right to change its Privacy Policy at any time without prior notice. If, at any time, STBS adopts material changes to its Privacy Policy, STBS will provide its clients notice of such material changes or notice of the existence of a revised Privacy Policy (including a copy of the same, a link to the same or instructions for accessing the same).

Scams:

STBS does not send emails to clients, and does not have websites, that request billing, login or password information of clients. If you receive an email purporting to be from STBS, or access a website purporting to be from STBS, that asks you to provide any of your personal nonpublic information, including any account-related or any login or password information, do not provide such information unless you have first verified the legitimacy of such email from or website of STBS. Such email or website may be fraudulent and used in connection with scams, including phishing. Please immediately report to STBS any suspicious email that you receive or website that you access.

Disposal of Information:

STBS has taken steps to reasonably ensure that the privacy of your nonpublic personal information is maintained at all times, including in connection with the disposal of information that is no longer required to be maintained. Such steps shall include whenever possible, shredding paper documents and records prior to disposal, requiring off-site storage vendors to shred documents maintained in such locations prior to disposal, and erasing and/or obliterating any data contained on electronic media in such a manner that the information can no longer be read or reconstructed.

Contact and Modifying Personal Information:

Should you have any questions about the privacy and protection of your records, please contact us. You may request copies of, or have STBS make changes or corrections to, nonpublic personal information in STBS's possession, or opt out of receiving further communications from STBS, by requesting the same via email or phone.

Governing Law and Jurisdiction:

This Policy, and STBS's collection and use of client information, shall be governed and interpreted in accordance with the laws of the United States and the State of Delaware. Any disputes arising out of this Policy shall be adjudicated in a court of competent jurisdiction in the Eastern District of the State of Indiana.

Your privacy, our professional ethics, and the ability to provide you with quality accounting services are very important to us.