Effective Date: May 30, 2017

We are committed to protecting your privacy. Our website is a great way to find out more about our services, access informative articles, market information and financial calculators. We will not collect any personal, identifiable information without your knowledge. Federal law gives consumers the right to limit some, but not all, sharing of personal information. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

Obtaining Information

IREXA Financial Services | Wealth Strategies collects personal information about you to help us serve your financial needs, process transactions in your account(s), provide customer service, offer new products or services, and fulfill legal and regulatory requirements.

IREXA Financial Services | Wealth Strategies collects nonpublic personal information from you, as well as from other sources. The sources and the information collected may include:

Information you provide to us, to our affiliated entities, or to your advisor on applications and related forms, through discussions with our customer service staff, or on our website, such as address, social security number, birth date, net worth, assets, income, and medical information, if applying for insurance. Information regarding your transaction history with us, such as products or services purchased, account balances, trading history, and payment history, as well as information from information service companies and consumer reporting agencies, such as your transactions or credit relationships with unaffiliated third parties. Information from other unaffiliated third parties, including employers, associations, benefit plan sponsors, and other institutions, if you transfer positions or funds to SANDLAPPER Securities, LLC, such as address, social security number, net worth, assets, and income.

Sharing information

We may disclose any of the nonpublic personal information that we collect about you, as required to conduct our business and as permitted or required by law. We may share information about our customers with our affiliated insurance company and/or with unaffiliated financial or nonfinancial services providers, such as insurance companies, broker/dealers, investment advisors, mutual fund companies, banks, investment firms, third-party administrators, clearing firms, retirement plan sponsors, and other third parties who assist us in obtaining business or providing account maintenance or customer service to your account(s). In addition, we may share some or all of the information we collect with other financial institutions with whom we have joint marketing agreements. Furthermore, we also may share your information with auditors, regulators, and law enforcement organizations or in response to a subpoena or discovery request, as permitted or required by law.

We do not sell, share, or disclose your nonpublic personal information to unaffiliated third-party marketing companies.

Opting in

If you live in an “opt-in” state, where we are required to obtain your affirmative consent to share your nonpublic personal information with unaffiliated third parties who do not currently assist us in servicing your account or conducting our business, we are required to obtain your consent. Please note: You can withdraw your consent at any time by contacting the Compliance department at 864-679-4701. In addition, please see below for “Important Information for California and Vermont Residents.”

Opting out

If you do not want us to take your information with us should we decide to leave SANDLAPPER Securities, LLC in the future, you have the right to opt out of such disclosure. If you have a joint account, we will treat an opt-out direction by a joint customer as applying to all associated joint customers. If you wish to opt out, now or at any time in the future, please contact our Compliance department by phone at 864-679-4701, or by mail at SANDLAPPER Securities, LLC, SANDLAPPER FINANCIAL CENTER, 800 E. North Street, Second Floor, Greenville, SC 29601.

Cookies

Cookies are very small files placed onto the hard drive of your computer the first time you visit our website that enable our server to recognize who you are the next time you come back. Contrary to popular belief, cookies do not extract private or personal information from your computer’s memory; rather, they record only information relating to your visit to our site. The Sherer Group uses cookies to track usage of the website and to address security issues. We may also use cookies to store your preferences relating to use of our website. If you do not want to allow our website to place a cookie on your computer, you can change your browser’s settings to deny cookies; however, this may affect your experience with certain features of our website.

AdRoll

The AdRoll website uses cookies, tracking pixels and related technologies. Cookies are small data files that are served by our platform and stored on your device. Our site uses cookies dropped by us or third parties for a variety of purposes including to operate and personalize the website. Also, cookies may also be used to track how you use the site to target ads to you on other websites.

We may collect the following categories of information for the purposes explained below.

IREXA website activity: This is data about your browsing activity on the IREXA websites. For example, which pages you visited and when, and what items you placed into your online shopping cart.

Device and browser information: This is technical information about the device or browser you use to access the IREXA websites. For example, your device’s IP address, cookie string data and (in the case of mobile devices) your device type and mobile device’s unique identifier such as the Apple IDFA or Android Advertising ID.

Ad data: This is data about the online ads AdRoll has served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, and whether you clicked on or otherwise interacted with the ad.

Data from AdRoll Advertising Partners: This is data that AdRoll receives from other digital advertising companies that they work with (“AdRoll Advertising Partners”) to help us deliver ads to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that some Advertisers or other third party ad platforms choose to share with us, such as your “Customer ID” with an Advertiser or an identifier associated with a hashed (not readable) version of your email address. We may work with these Advertising Partners to synchronize their unique, anonymous identifiers to our own to enhance data points about a particular unique browser or device.

Safeguarding privacy

IREXA Financial Services | Wealth Strategies recognizes the need to prevent unauthorized access to the information we collect, including information held in electronic format. IREXA Financial Services | Wealth Strategies authorizes access to your nonpublic personal information only to parties with whom we have executed confidentiality/nondisclosure agreements and who need that information to serve you or to assist us in conducting our operations. We maintain physical, electronic, procedural, and contractual safeguards regarding your nonpublic personal information to ensure that we comply with our own policy, industry practices, and federal and state regulations. And we train our employees in the proper handling of sensitive information. If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.

Questions

IREXA Financial Services | Wealth Strategies Group privacy protections apply automatically to all of our clients and former clients. If you have any questions we please contact us at 2312 East Lake Ave., E., Seattle, WA 98102, (866) 596-1031.

Important information for California and Vermont residents

California residents: For accounts with a California mailing address, we will not share your personal information with a financial company for joint marketing purposes except as required or permitted by law.

Vermont residents: For accounts with a Vermont mailing address, we will not share your creditworthiness information with our affiliates except as required or permitted by law. For joint marketing with other financial companies, we will disclose only your name, contact information, and information about your transactions, unless otherwise required or permitted by law.

Securities are not FDIC- or NCUA-insured; not guaranteed by any bank, credit union, or government agency; and are subject to risk, including potential loss of principal invested.