Privacy Notice

RJA is committed to protecting the confidentiality and security of the nonpublic personal information of our clients and prospective clients. We maintain written policies and procedures reasonably designed to safeguard customer information in accordance with applicable federal regulations. The following is designed to help you understand what information we collect from you and how we use that information to serve your account.

Categories of Information We May Collect

We collect nonpublic personal information about you in connection with providing advisory services, including:

• Information you provide to us (e.g., name, address, email, phone number, Social Security number, date of birth, financial information);
• Information about your transactions with us or others (e.g., account balances, investment history);
• Information received from third parties (e.g., custodians, service providers).

How We Use Your Information That We Collect

We use your information to provide advisory services, maintain and service your account, and comply with legal and regulatory obligations.

We do not disclose your nonpublic personal information to nonaffiliated third parties except as permitted by law. Such disclosures may include:

• Service providers that assist us in servicing your account (e.g., custodians, administrators, auditors, attorneys, technology providers);
• Regulatory authorities or law enforcement, as required by law;
• Other parties as necessary to process, service, or carry out transactions you request.

We do not disclose your information to nonaffiliated third parties in a manner that would require us to provide you an opportunity to opt out under federal law.

Safeguards and Incident Response

We maintain administrative, technical, and physical safeguards designed to protect customer information. These safeguards include measures to detect, respond to, and recover from unauthorized access or use of such information.

In the event of unauthorized access to or use of your sensitive customer information, we will provide notice to affected individuals as required by applicable law.

Confidentiality and Security

We restrict access to nonpublic personal information about our clients to those employees and agents who need that information to provide products and services.

We maintain and periodically review physical, electronic, and procedural safeguards—including access controls, monitoring, and secure disposal practices—to protect customer information.

If you have any questions about this Privacy Notice, please contact us at (763) 560-2127 or RJAInfo@rossjohnsonweb.com.