SECURITY POLICY

Client and/or User Information Protection Policy

We will use commercially reasonable methods to keep information securely in our files and systems. To help protect your financial data and credit information Heritage Capital Associates, Inc. uses SSL (Secure Sockets Layer) encryption. We cannot guarantee the security of your data as it travels over the internet.

Other technologies such as firewalls, virus detection and eradication software, and backup files are used to protect our clients data.

We limit employee access to CLIENT and/or USER information to those who have a business reason to know this information. Employees are required to honor our code of conduct, which includes standards to protect CLIENT and/or USER confidentiality. They are subject to disciplinary action if they fail to do so.

We maintain policies and procedures covering the proper physical security of workplaces and records.

Effective Date
Rev. November 2005

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