HEADINVEST PRIVACY NOTICE

At HeadInvest, client confidentiality is sacrosanct. Federal law gives consumers the right to limit some but not all sharing of personal information. This policy statement outlines what information we collect, the disclosure of such information to both affiliates of HeadInvest and non affiliated third parties, and the safeguards we have in place to protect it.

About the information we obtain

Information we receive from you can include your name, address, telephone number, social security number, risk tolerance and household assets. We also receive information about your transactions including receipts, disbursements, bank account information and other account information.

How we collect your personal information

HeadInvest may collect nonpublic personal information about our clients from information provided on forms, contracts, statements, transactions and through the normal course of establishing and managing your accounts. We also may collect your personal information from others, such as credit bureaus, affiliates, or other companies.

How we protect your personal information

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. All employees of HeadInvest are trained to handle a Client’s information properly in order to maintain its security.

Reasons we may share your information

All financial companies need to share customers’ personal information to run their everyday business. Examples of third parties we share with include your custodian(s), proxy voting services, and other service providers, but only to the extent necessary or appropriate for such parties to perform services for your benefit. Federal law allows us unlimited rights to share under these circumstances:

  • For everyday business purposes – such as to process your transactions, maintain your account(s), or as required or permitted by applicable law
  • For marketing purposes – to improve our services to you

If any financial organization wants to share your information for the following reasons, Federal law gives you the right to limit such sharing. HeadInvest does not share for the reasons listed below: For joint marketing with other financial companies For our affiliates’ everyday business purposes information about your transactions and experiences For our affiliates’ everyday business purposes – information about your creditworthiness For our affiliates to market to you For nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law. HeadInvest will honor these privacy policies and practices for both current and former clients.

Hyperlinks to Outside Sites

The privacy practices of linked Web sites are not covered by our Privacy Policy, and we are not responsible for the privacy practices, data collection, security or content of other Web sites. You should be careful to review any privacy policies posted on linked sites before using them.

Security Reminder

We will never request from you or send to you confidential information via unsecure email. Please report any such requests to us immediately. In addition, we discourage our clients from sending us personal nonpublic information such as social security numbers, driver’s license numbers and account numbers via unsecure email.

Questions

HeadInvest has always governed ourselves by these precepts and we want you to know that we are strongly committed to our relationship with you and the protection of your privacy. If you have any questions or concerns, please call Carl Gercke at (207) 773-5333 or (800) 315-5360.

Definitions

  • Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies. Our only affiliate is Androscoggin Savings Bank.
  • Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies. Non affiliates we share with can include your custodian(s), proxy voting services, and other service providers, but only to the extent necessary or appropriate for such parties to perform services for the benefit of the client.
  • Joint Marketing: A formal agreement between nonaffiliated companies that together market financial products or services to you.

Other Important Information

While the information sharing practices described above comply with applicable Federal law, certain states, including California and Vermont, have implemented additional limitations regarding the disclosure of personal information. We intend to comply with all applicable state law regarding the disclosure of personal information.

For California and Vermont Residents Only.

With respect to California residents, we will not disclose personal information about you to our affiliates or to nonaffiliated financial institutions with which we may jointly offer financial products or services without first providing you an opportunity to opt out of such disclosure. With respect to Vermont Residents, any personal information disclosed pursuant to a joint marketing agreement with a nonaffiliated third party will be limited to contact information and your transactions and experiences with HeadInvest.

For Nevada Residents Only.

We are providing this notice to you pursuant to Nevada law. If you do not want to receive marketing calls from us, you may be placed on our Internal Do Not Call list by calling 1-800-315-5360 or writing us at 7 Custom House Street, Fourth Floor, Portland, Maine 04101.

For more information, contact us at the address above or by email at [email protected], with A Nevada Annual Notice@ in the subject line. You may also contact the Nevada Attorney General’s Office, Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington Street, Suite 3900, Las Vegas, NV 89101 Phone: (702)-486-3132 Email: [email protected]