Protecting Your Privacy

Website Privacy and Security

Beacon Wealthcare, LLC. respects your privacy and guards your data carefully.
We understand that privacy is very important to you. Details of our privacy pledge and how your personal information is collected and used are outlined in this brochure, the Beacon Wealthcare Privacy Policy. It also describes the instances where we share information with other parties and affiliates, and when and how you can “opt out” of sharing certain information about you with others. We recognize the important position of trust we hold with you, and take your privacy seriously.

Beacon Wealthcare’s Pledge to Our Customers:
When we talk of “personal information”, we refer to information that personally identifies you or your accounts, your nonpublic personal information. Our privacy policy applies to consumers who are current or former Beacon Wealthcare clients, or those that have requested information about our services.

Information we collect:
We collect nonpublic personal information about you on account applications and other forms. We limit the collection and use of personal information to that which is necessary to effectively manage your accounts and to meet regulatory requirements. We collect and maintain nonpublic personal information about you from the following sources:

• Information that you provide, such as on applications or other forms, or any other documentation you may supply to us.
• Information about your transactions with us and/or our custodian or an outside fiduciary. This information collected includes balances, positions, and history and may include your name or other data in an internal client list that reflects your activities, as well as social security number and birth date.

Information we share:
We do not disclose personal information to third parties, unless one of the following exceptions applies.

• We disclose personal information to our custodian, Schwab Institutional through the forms highlighted above for the processing and servicing of your account’s transactions. The custodian delivers statements, confirmations, and 1099s. With your approval on the new account form, confirmations, statements and 1099 information are shared with us.
• We may share some of your personal information with third parties that perform services for us, in order to service your accounts.
• We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted under law; to cooperate with regulators or law enforcement authorities, or to resolve consumer disputes.
• We may share personal information with companies of those securities held in your account in order for you to receive financial reports directly, however, you can “opt out” on the account application, or at any time by writing your desire to withhold (“opt out” ) or to receive ( “opt in” ) information from companies.
• Outside of these exceptions, we will not share your personal information with third parties such as attorneys or CPAs, unless you specifically authorize us to do so, that is, opted in.
• Our privacy policies, described in this statement, continue even if your relationship with us is terminated.
• We do not sell your personal information to anyone.
• We limit the use of your personal information supplied to our custodian to the performance of the specific services you have requested.
• Access to your information is restricted to our employees who need it in order to provide service to you. We maintain physical, electronic and procedural safeguards to ensure information security. We maintain and grant access to customer information only in accordance with our internal security standards.

We are committed to customer privacy on our websites
Beacon Wealthcare is equally committed to protecting the privacy of customer information on the Internet. In the public area of our web site, we do not collect any personal information. In the private area, we will only recognize you by your personal User ID and password.

How do we protect your Information?
Beacon maintains technical, physical, and procedural safeguards. We utilize a secure, encrypted network to keep your personal information is as safe from unauthorized access as possible as well as employee training and adhering to strict confidentiality policies. This approach helps ensure that your personal data remains safe and private. We will continue to implement security features in the future that will maintain the highest levels of security to safeguard both the storage and the transmission of private information.

Third Party Websites
We provide links for your convenience only. Beacon does not control such websites and is not responsible for their content or privacy. Reading these separate privacy policies is up to you.

Use of Cookies
The Beaconwc.com site, like most web sites, uses “cookies” (information stored on your computer by your browser at our request). Cookies enable the site to ‘remember’ who you are and your preferences making future visits faster and more efficient. We do not save or process beyond the web site any personal or sensitive information in these cookies.

Hyperlinks
Our Web site contains hyperlinks to other sites. Web sites we link to may have different privacy practices from the ones described here for www.beaconwc.com. Visitors and clients should read the privacy statements of other Web sites they visit. This privacy statement applies solely to information collected by this Web site.

Electronic Message and E-Mail Security
E-mail sent to Beacon Wealthcare from within our Web site is secured with the encrypting technology we use to transmit account reporting.

Consumers have been experiencing an increase in email-related fraud, often referred to as phishing. Because of this, it’s important that consumers make sure their personal computer’s own defenses are strong with up-to-date anti-virus and anti-spyware software.

If you have any questions regarding this privacy policy, please contact us at 919-821-5225.

Identity Theft
As a matter of policy, Beacon Wealthcare LLC. seeks to prevent the theft or misappropriation and misuse of the identities and identifying information of its clients. In order to prepare this program, the firm has evaluated the risks of identity theft in connection with its investment advisory practice including the firm’s:

• methods of opening client accounts;
• methods for accessing client accounts; and
• previous experience with identity theft.

The principal risks of identity theft acknowledged by Beacon Wealthcare LLC lie in the methods for accessing accounts and the acceptance of instructions for transfers out of an account for the payment of third party payees or otherwise.

Identification of Red Flags
From time to time, Beacon Wealthcare LLC or its staff may receive indications that the identities of clients or investors may have been compromised, stolen or are otherwise at risk. It is critical that these “red flags” are recognized so that the firm can take appropriate measures to safeguard clients and investors and prevent the misappropriation and misuse of client or investor identities and assets.

Categories of red flags to consider include, but not limited to, the following:

• alerts, notifications or other warnings received from consumer reporting agencies or service providers, such as fraud detection agencies;
• presentation of suspicious personal identifying information, such as suspicious address change;
• unusual use of, or other suspicious activity related to covered account, including, but not limited to:
• unexplained or urgent requests for large transfers or payments to be made from the account to third parties;
• telephone requests for urgent transfers from the client’s account on a unclear or poor connection, particularly where the client is unwilling to remain on the line or claims to be in a hurry;
• Non-characteristic large withdrawals on a customer’s account via check to new payee:
• Customer complains of a check or checks stolen from the mail and deposited into an unknown account,
• Existing customer with no history of check deposits has new sudden check deposits and withdrawal or transfer of funds,
• requests to transfer funds from the client’s account to a new or recently opened bank account;
• notice from clients or investors regarding unusual transfers or account activity, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with covered accounts held by Beacon Wealthcare LLC. client custodians;
• consideration of new types of accounts and how clients access those accounts;

Any Beacon Wealthcare LLC personnel becoming aware of red flags, suspicious activity or unusual transfer requests must promptly notify the CCO and/or other designated person(s) before taking any further action to facilitate a transfer from the client’s account (if applicable).

Detection of Red Flags
Beacon Wealthcare LLC and its staff should be conscious of suspicious activity or transfer requests and actively seek to detect red flags in connection with the opening and maintenance of accounts.

Opening Accounts
With respect to the opening of client accounts, Beacon Wealthcare LLC seeks to obtain appropriate identifying information about, and verification of the identity of, the client. In order to confirm client identities, when opening accounts, if a client is not known to us personally, a driver’s license must be shown to us. In addition, our custodian

verifies the account information, including address, social security, and other vital information with outside official sources.

Transfer/Payment Requests and Address Changes
Beacon Wealthcare LLC is also committed to monitoring transfers and transactions within client accounts and seeking to authenticate clients and client requests for transfers, whether such requests direct the transfer of funds from the client’s account to third party payees or to another account in the client’s name, particularly (though not exclusively) when the receiving client account was only recently opened and/or the request was received via email or other electronic communication.

Clients can login to view their transactions and accounts via a sign in they create using their personal information. All sites are secure. Only a request for a check being mailed to the name and address of record or a request to move funds via pre-authorized money movement to a bank account can be taken over the phone. All other requests (such as wire transfers, checks to an alternate address, etc), must be done in writing, with the signature being matched to what is on file, prior to processing. For those requests that can be processed through e-signature ( electronically), the client can login to their account with the custodian for quick approval and processing ( this includes wire transfers). Third party wire transfers an additional phone call is made to a known number to confirm the request.

We do not handle standing instructions for any wire transfers.

Should a client request that Beacon Wealthcare LLC facilitate a transfer of monies from the client’s account to a new or different account held in the client’s name, the firm shall:

• request instructions with the client’s signature ( many can now be processed electronically , again with the client logging into their account with the custodian)
• verify that instructions submitted are from the client or other authorized signatory on the account;
• seek to ensure that the signature on the written instructions match the signature on file with the firm ( if these are wet signed, if electronic the client their own secure login); and
• ensure the request is addressed to Beacon Wealthcare LLC

Any request received (ostensibly) from a client to facilitate a transfer of monies from the client’s account to a third party payee, must undergo the same process set forth above and Beacon Wealthcare LLC should seek to verify the request as set forth below. Similarly, any request for a change of address on a client’s account must be verified by Beacon Wealthcare LLC before being processed.

Verifications are to be accomplished through direct contact with the client at the telephone number held on record with Beacon Wealthcare LLC . Telephone contact with the client must be documented and is required regardless of whether the request for transfer or address change was received by email or telephone as a fraudster impersonating the client could have easily contacted the firm to make the request from a different phone number. When seeking verification at the client’s telephone number of record, should a client deny having requested the transfer, the Beacon Wealthcare LLC employee having spoken to the client must immediately notify the CCO or other designated person(s).

Responding to Red Flags
To best protect our clients and investors and ensure that the firm responds in an appropriate manner to red flags and suspicious activity, all red flags and suspicious activity recognized or uncovered by personnel should be promptly reported to the CCO and/or other designated person(s).

When determining the appropriate response to red flags, Beacon Wealthcare LLC will consider the degree of risk posed and aggravating factors that may heighten the risk of identity theft, such as a data security incident that results in unauthorized access to a client’s or investor’s account records held by the Beacon Wealthcare LLC or other third party, or notice that a client has provided information to someone fraudulently claiming to represent Beacon Wealthcare LLC or to a fraudulent website.

Appropriate responses may include the following, based on a consideration of the relevant facts and circumstances:

• monitoring a covered account for evidence of identity theft;
• contacting the client or investor;
• contacting the account custodian;
• temporarily requesting a freeze on any asset transfers from the account;
• changing any passwords, security codes, or other security devices that permit access to the account;
• reopening an account with a new account number;
• not opening a new account;
• closing an existing account;
• notifying law enforcement and regulatory authorities; or
• determining that no response is warranted under the particular circumstances.

Oversight of Third-Party Service Providers
Our firm uses various service providers, including custodians and brokers in connection with our covered accounts. We have a process to confirm that relevant service providers that perform activities in connection with our covered accounts comply with reasonable policies and procedures designed to detect, prevent and mitigate identity theft by contractually requiring them to have policies and procedures to detect Red Flags. Typically, we will request an effective identity theft prevention program implementation certification from each critical service provider (e.g., brokers, custodians, cloud providers, etc.) on an initial and annual basis.

Furthermore, when appropriate and to ensure that our firm’s identity theft prevention program is consistently implemented, we may require certain service providers who directly or indirectly participate in the identity theft prevention effort to agree not to take, without Beacon Wealthcare LLC’s specific approval, actions such as the following:

• not to change wire instruction;
• not to direct any redemption proceeds to an account not listed in the original subscription document;
• not to partition, retitle, or otherwise change any indicia of ownership of an investment or account (including changes purportedly for estate planning and domestic relations reasons); or
• not to consent to liens or control agreements being placed on an investment or account.

Updates and Approval
Beacon Wealthcare LLC’s identity theft program shall be reviewed and approved in writing by managing partners of the firm. Periodically, and at least yearly, the CCO and/or other designated person(s) shall review the program and present senior management with a report regarding the effectiveness of the program and any suggestions for improving the program based on changing or newly perceived risks, such as:

• the experiences of Beacon Wealthcare LLC with identity theft;
• changes in the types of accounts that Beacon Wealthcare LLC offers or maintains;
• changes in methods used by fraudsters to perpetrate identity theft;
• changes in methods to detect, prevent, and mitigate identity theft; and
• changes in the business arrangements of Beacon Wealthcare LLC, including mergers, acquisitions, alliances, joint ventures, and service provider arrangements.

Training
It is imperative that all personnel be familiar with the firm’s identity theft program and have a thorough understanding of his/her role and responsibilities in protecting our clients and investors. To this end, Beacon Wealthcare LLC will conduct initial and annual training regarding its identity theft program to assist personnel to recognize and appropriately respond to and report red flags and other suspicious activity. Employees are encouraged to ask the CCO or other designated person(s) for clarification or additional information regarding the program in general or any suspicious activity in particular.