Privacy Policy

Reason Financial goes to great lengths to protect the privacy of our clients’ personal financial and tax related information, as do our affiliates and the entire securities industry.

When customers engage our services we tell them about our own privacy protections and the different federal laws that also provide safeguards. The latest and most significant legislation is the Gramm-Leach-Bliley Financial Services Modernization Act, which established four new requirements regarding the use of a consumer’s nonpublic personal information. Enacted by Congress on November 13, 2000 and effective as of July 1, 2001, the Act proclaimed a federal privacy policy that each financial institution “has an affirmative and continuing obligation to respect the privacy of its customers and to protect the security and confidentiality” of customers’ nonpublic personal information. The Act requires all financial institutions must annually disclose their privacy policy regarding the disclosure of the customer’s nonpublic personal information to nonaffiliated third parties; and otherwise prohibits financial institutions from disclosing the customer’s personal information to them.

The Act also provides you with an opportunity to “opt out” of a disclosure of such information by financial institutions to nonaffiliated third parties if you do not want it disclosed.

Reason Financial’s Privacy Policy

Reason Financial is an independent financial planning firm, and is committed to safeguarding the confidential information of its clients. We hold all personal information provided to our firm in the strictest confidence. These records include all personal information that we collect from you or obtain in connection with any of the services provided by Reason Finacial

How and Why We Obtain Information

Reason Financial may receive nonpublic personal information about you from any of the following sources:

• From your applications or forms (examples include name, address, Social Security number, birth date, assets and income)

• From transactional activity in your account (examples include trading history and account balances)

• From other sources with your consent (for example, from other institutions if you transfer positions into an account at 1st Global Capital Corp.)

The categories of nonpublic personal information that we collect from a client depend upon the scope of the client engagement. It will include information about your personal finances, information about your health to the extent that it is needed for the planning process, information about transactions between you and third parties, and information from consumer reporting agencies.

For unaffiliated third parties that require access to your personal information, including financial service companies, consultants, and auditors, we also require strict confidentiality in our agreements with them and expect them to keep this information private.

How We Protect Your Information

Reason Financial has always considered the protection of sensitive information to be a sound business practice and a foundation of customer trust. We employ extensive information protection controls in keeping with industry standards and practices, and we regularly adapt these physical, electronic and procedural controls to respond to changing requirements and advances in technology.

Within Reason Financial and our affiliates, and among our service providers, we restrict access to your information to those who require that access in order to provide products and services to you. We may share the personal information that we collect about our customers, prospects or former customers with:

• Affiliates, including 1st Global Capital Corp., 1st Global Advisors, Inc., 1st Global Insurance Services, Inc., 1st Global Retirement Services, Inc. and various 1st Global insurance agencies established under state requirements

• Unaffiliated service providers (for examples, fulfillment companies or securities clearinghouses) Government agencies and law enforcement officials (as required by law)

• Other organizations, as permitted by the laws that protect your privacy (such as for fraud prevention)

• Other organizations, with your consent

At Reason Financial we do not disclose any nonpublic personal information about you, except as permitted by law. You may hear reference to an “opt out” provision at other firms. Since Reason Financial and its affiliates do not disclose any nonpublic personal information except as permitted by law, there is no ability to “opt out.”

Federal and state regulators also may review firm records as permitted under law.

We do not provide your personally identifiable information to mailing list vendors or solicitors for any purpose.

Personally identifiable information about you will be maintained during the time you are a client, and for the required time thereafter that such records are required to be maintained by federal and state securities laws. After this required period of record retention, all such information will be destroyed.


Privacy Online

Reason Financial considers privacy, security and service to be just as critical in the online environment as in the rest of our operation. We therefore employ all of the safeguards described above, along with the following Internet-specific practices.

Reason Financial uses a variety of proven protections to maintain the security of your online session. For example, we make extensive use of firewall barriers, encryption techniques and authentication procedures.

• If you are a former customer, your information is treated in the same manner as that information of current customers.