Quantuvis Consulting, Inc., Quantuvis Online and Advisor Ascent Privacy and Security Policy

Effective October, 2009

The Privacy and Security of Your Proprietary Information is Important to Us

Quantuvis Consulting, Inc. (“Quantuvis”) provides practice management consulting services to business clients, including without limitation investment advisers, broker-dealers and their representatives. In its business operations, Quantuvis does not generally collect personal information from individuals related to personal, family or household purposes.

At Quantuvis, we believe it is important to protect the confidential and proprietary information of our clients, as well as the privacy of visitors to our web sites. This Privacy and Security Policy (the “Privacy Policy”) explains and summarizes how we collect, use and protect your information as you interact with us directly, by phone, online and through our client support services. This Privacy Policy applies to Quantuvis’ operations in the United States and to its web sites, located at www.Quantuvis.com, and to users of Quantuvis Online and/or the Advisor Ascent program, including its surveys. Quantuvis is a subsidiary of Genworth Financial Services, Inc. (“Genworth”) and an affiliate of Genworth Financial Wealth Management, Inc. (“GFWM”), a registered investment adviser. This Privacy Policy does not apply to other web sites which may be operated by Genworth, GFWM or other Genworth affiliates, or business partners of Quantuvis, even if they are linked to the Quantuvis.com site.

By using our services and/or our web site(s), you consent to the collection and use of your information by Quantuvis consistent with this Privacy Policy and applicable privacy and data protection laws.

Our Privacy Policy May Change Over Time

Our Privacy Policy may change over time. We will post the revised Privacy Policy on our web site(s). We encourage you to refer to the Privacy Policy from time to time to stay abreast of our most current practices. If you are an existing client of Quantuvis, we will attempt to notify you of material changes to our Privacy Policy. Your continued access and use of www.Quantuvis.com and Quantuvis’ services, including Quantuvis Online and/or Advisor Ascent, constitute your acceptance of any changes to our Privacy Policy.

The Types of Information Quantuvis Collects About You

Quantuvis collects information that you provide to us, or that we learn about you, from the use of our web site and/or in contracting for services from us, or given to us in any other way. For example, you may provide information to us when you complete the Advisor Ascent or Quantuvis Online survey(s) or use our site(s) or services. We might also receive information about you from other sources. You may also provide us with information about your clients. If you are applying for a job with us, you may provide us with personal information and your employment background.

How We Use Information About You

We use information we have collected about you to provide you with our consulting and other services, to respond to your inquiries and complaints, to maintain and collect payment on your account(s) with us, to enforce your agreements with us and to provide you with marketing and promotional information about products and services we believe may be of interest to you.

We do not disclose your information to unaffiliated third parties or to our affiliates who may want to offer you their own products and services unless you have requested or authorized us to do so.

We may also share your information with third parties or affiliates where it is necessary for us to provide you with the services you have requested, to collect payment or to do something that you have asked us to do, including where we have contracted with third parties or affiliates to perform services on our behalf (“service providers”). Companies that act on our behalf are obligated to keep the client information we provide to them confidential and to use the information only to provide the services we ask them to perform. Quantuvis will not share your business information with GFWM or any other Genworth affiliate unless it is in connection with their activities as a service provider or in connection with a joint venture with Quantuvis to offer services to you.

We may share the information you provided to us, in response to one of our surveys or otherwise, on an anonymous and/or, aggregated basis, as part of our survey analyses or other services, to you and other participating clients. We may aggregate statistics that we gather about our customers, sales, traffic patterns, and services, and provide these statistics to third parties. When we provide these statistics to third parties, however, they will not include any personal information that identifies you, unless you have agreed to receive tailored information.

We may also disclose information about our clients as permitted or required by law, to protect against fraud or security hazards, and in connection with a merger, acquisition or bankruptcy. Quantuvis may be required to disclose your information if it: (i) believes it is reasonably necessary to comply with legal process, such as a court order, subpoena, or search warrant, or other legal requirements of any governmental authority; (ii) would potentially mitigate our liability in an actual or potential lawsuit; (iii) is otherwise necessary to protect our rights or property; or (iv) is necessary to protect your interests or those of other users of our web site or services. If Quantuvis should ever file for bankruptcy or merge with another company (including its parent or affiliates), or if Quantuvis should decide to buy, sell or reorganize part or all of its business, Quantuvis may be required to disclose your information to prospective or actual purchasers. It is Quantuvis’ practice to seek appropriate protection for client information disclosed or received in these types of transactions. Quantuvis cannot, however, guarantee that Quantuvis’ Privacy Policy will remain unchanged if Quantuvis is sold or merges with another company.

How We Collect Information

Quantuvis collects and uses information from you in several other ways:

Web Site Usage. Quantuvis, and Quantuvis authorized service providers, may observe your activities, preferences, and transactional data (such as your IP address, browser type and operating system) relating to your use of our web site(s). We may use this collected or logged information in order to provide better service, facilitate our clients’ use of the web site, track usage of the web site, and to address security hazards. We may use aggregated, statistical information to describe our client audience, products and services, and to develop partnerships with third parties to offer products and services in which we believe our clients will be interested.

Online and Off-line Transactions. You may be asked to share information in order to complete a transaction and when you use our web site. This information is used, for example, to effect your transactions, create and share aggregate reports about these transactions, and perform financial fraud screening services for transactions between you and Quantuvis and/or our authorized service providers. For online transactions, we may assist you in creating a user id and password to protect your account information with us.

Recruitment and Job Applications. You may provide us with information in connection with a job application or inquiry. We may use this information throughout Quantuvis’ offices in the United States for the purpose of employment consideration or your inquiry. We may keep your information on file for future consideration.
Children. Children under 13 should not send any information about themselves to Quantuvis. If a child under 13 submits information through any part of Quantuvis’ web site(s) or otherwise provides such information to Quantuvis, and we learn that the person submitting the information is a child, we will attempt to delete this information as soon as possible. Because we do not knowingly collect any information from children under 13, we do not use or disclose such information to third parties.

This Privacy Policy Applies to U.S. Clients

This Privacy Policy applies to client relationships established in the United States. Our web site is hosted in the United States and is intended for United States visitors. Parts of this Privacy Policy may not apply to visitors to our web site outside the United States because, for example, certain services may not be offered to non-U.S. clients. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from and may be more stringent than U.S. privacy and data protections laws (to the extent those laws are applicable to Quantuvis’ business model), by visiting our web site(s) and providing us with information, you acknowledge and consent to the transfer to and processing of your information in the United States.

Our Security Practices

Our internal data security policies restrict access to clients’ information to authorized employees, agents and subcontractors. These persons are required to use our clients’ information for Quantuvis business purposes only. Employees who violate their confidentiality obligations are subject to disciplinary action, up to and including termination.

We maintain physical, electronic, and procedural safeguards that are designed to guard our clients’ information. For example, for the security of your online visit to Quantuvis.com, we may make use of secure server software (SSL) and firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. Information is maintained within a secure Windows NT Server environment. We may also use encryption techniques and/or authentication procedures. Unfortunately, no data transmission over the Internet or internal security system can be guaranteed to be absolutely secure. As a result, while we strive to protect your information, Quantuvis cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.

In the event of a breach of the confidentiality or security of your information, we may attempt to notify you as necessary by email or other means so you can take appropriate protective steps. By using our web site(s) or providing information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of our site(s) or your account(s) with us. Unless you indicate otherwise, we may notify you using the most current email address you provided to us.

What are Cookies and How Does Quantuvis Use Them?

A “cookie” is a small piece of information that a web site stores on a personal computer and which it can later retrieve. We may use cookies to collect or log certain information or for some administrative purposes, for example, to store our clients’ preferences for certain kinds of services or to store a password so that you do not have to input it every time you visit secured portions of our web site. The cookies will not contain information that will enable anyone to contact our clients via telephone, email, or any other means. If our clients are uncomfortable with the use of cookie technology, they can set their browsers to refuse cookies. Certain services, however, could be dependent on cookies and our clients may disable those services by refusing cookies.

Links to Third Party Sites and Web Sites Containing Quantuvis Branding

Our web site(s) may contain links to third party sites. Please be aware, however, that Quantuvis is not responsible for and cannot control the privacy policies of these other sites or their practices. We encourage you to read the privacy policies for these other sites (including our affiliates’ sites), as they may differ from ours.

Our web site(s) may also contain links to sites that display Quantuvis, Quantuvis Online and/or Advisor Ascent branding and/or logo but which are maintained by third parties. Such web sites may be identified in that they do not display a “Quantuvis.com” or “Quantuvis Online” or “Advisor Ascent” URL. Please read the privacy policy on these sites for applicable privacy practices relating to information collected via those sites because they may differ from Quantuvis’ privacy practices. This Privacy Policy applies solely to information collected by Quantuvis.

Contact Preferences and Accessing Your Information

You have certain choices when it comes to how Quantuvis uses your information. You may choose not to receive information about new services and special promotional offers from us by direct mail and/or email. If you elect not to receive such marketing information by direct mail or email, Quantuvis may continue to contact you as necessary to service your account. You can change your contact preferences by emailing us at privacy@Quantuvis.com or by writing to us at the physical address set forth further below.
Keeping your account information accurate and up to date is very important so we can provide you with excellent service. If your account information is incomplete, inaccurate or not current, please contact Quantuvis client service. You can obtain client service information by emailing us at begreat@quantuvis.com.

What Else Should I Know About My Privacy?

You should be careful to maintain the secrecy of your user id and password and/or account information and be responsible about protecting your account information, both online and off-line.

Contacting Quantuvis

If you have any questions, comments, or concerns about this Privacy Policy, please email us at privacy@Quantuvis.com, or write to us at:

Quantuvis Consulting, Inc.
1660 Plum Lane
Redlands, California 92374
Attention: Privacy Officer

¹ These privacy laws generally do not apply to information pertaining to business entities or provided by individuals for business purposes