Disclosures

PRIVACY POLICY

Wellspring Associates ("WA") is a professional service firm that advises on personal financial matters and, as such, we are required by federal law to inform our clients of our policies regarding the privacy of client information. We are committed to maintaining the confidentiality and security of our client's personal and private information. Please take a moment to review our privacy notice informing you of the steps we take to safeguard your nonpublic personal information.

While providing service to you, we collect personal information from the following sources:

  • Account and product applications and other standard forms related to your financial services. Examples of information collected include your name, address, social security number, assets, types and amounts of investments, transactions, and income.
  • Information obtained from third parties when verifying applications, other forms or legal documents. This may be obtained from your other professional advisers, employer, or financial service providers.

Keeping your information secure is one of our most important responsibilities. We restrict access to your personal information to those employees and agents who assist us in providing services to you. We maintain physical, electronic and procedural safeguards that comply with applicable law to protect your personal information. We train our personnel in the proper handling of personal information. When we use other companies to help provide our services to you, we require them to protect the confidentiality of personal information they receive.

Disclosing Personal Information to Non-Affiliated Third Parties

We do not sell, share, or disclose your personal information to non-affiliated third parties, except personal information we share in coordination with the services we provide to you through third parties such as your attorney, accountant, or financial product provider.

We may disclose personal information we collect in order to comply with supervisory requirements of registered representatives of LPL Financial The Leaders Group and Wellspring Planning Group who are also members of Wellspring Associates. This may include investment accounts, transactions, financial investment objectives and related information.

We may also disclose your personal information as permitted or required by law. These disclosures may include, for example, information to process transactions on your behalf, to conduct operations, to follow your instructions as you authorize, or to protect the security of your financial records.

Disclosing Personal Information to Affiliated Parties

We may share within our affiliates information about our services or experience with you, such as your name, social security number, or similar information. For example, if you currently do business with one of our affiliates or ask to receive information about an affiliatesˇ¦ service, we may share your personal information with the affiliate. Our affiliates may also continue to use personal information they receive from us to perform services on our behalf, to respond to communications from you, as you authorize or request, or, if you are their client, to offer you their services. To the extent that you are entitled to other protections under applicable laws and these laws apply, we will comply with them when we share personal information about you.

View and Change Your Personal Information

You can review the personal information we maintain on you and make any needed corrections to it by contacting us in writing at the Atlanta Georgia office at the address found on this website.

Right to Access and Correct Information

You may contact us with any questions you may have about your personal information. To protect your personal information, we may ask you to verify your identity and to provide other details to respond to your access and information change requests.

If Your Relationship with Us Ends

If our relationship with you ends, we will continue to treat and protect your personal information in accordance with this Privacy Notice. This means that we may continue to share your personal information with our affiliates as previously described or permitted by law. However, if you notify us of your election not to have us share your personal information with others before or after your relationship with us ends, we will honor that request.

Changes to Our Privacy Policy Notices

We reserve the right to amend (that is, to add to, delete from, or change) the terms of this Privacy Notice from time to time. Updates will be posted to this website promptly after they are made.

TERMS AND CONDITIONS

Wellspring Associates and its affiliates requires that all site visitors adhere to the following regulations. By accessing this Site you indicate the acknowledgement and acceptance of these terms and conditions.

This Site is designed for residents of the United States only, and should not be considered a solicitation to buy or an offer to sell any financial service or product in any other jurisdiction.

Laws and regulations

User access to and use of this Site is subject to all applicable federal, state, and local laws and regulations.

Copyright

All information, content, forms, photographs, graphics, and software available on or through this Site (collectively "Content") is owned, controlled, or licensed to Wellspring Associates, its affiliates, and other parties. The Content is protected by U.S. copyright law. Users are prohibited from modifying, copying, distributing, transmitting, displaying, publishing, selling, licensing, or using any Content available on or through this Site for commercial or public purposes without the prior written permission of Wellspring Associates.

Trademarks

The trademarks, service, marks, slogans, logos, and other identifiers ("Marks") displayed on this Site are the property of Wellspring Associates, its affiliates, and other parties.

Hyperlinking

This site may provide a link to other sites by allowing the user to leave this site to access third-party material or by bringing into this site via linking technology (a "linked site"). Wellspring Associates has no discretion to alter, update, or control the content on a linked site. The fact that Wellspring Associates provides a link to a site is not an endorsement, authorization, or sponsorship. There are inherent risks in relying upon or retrieving information from the internet and you are encouraged to consider the risks before relying upon, using, or retrieving any such information on a linked site.

No warranties

All content, products, and services on this site, or obtained from a website to which the site is linked (a "linked site") are provided to you "as is" without warranty of any kind either express or implied. Wellspring Associates does not endorse and is not responsible for (a) the accuracy or reliability of any opinion, advice or statement made through the site by any party other than Wellspring Associates, (b) any content provided on a linked site, or (c) the capabilities or reliability of any product or service obtained by a linked site.

Other than as required under applicable consumer protection law, under no circumstances will Wellspring Associates or its data or content providers be liable for any loss or damage caused by a userˇ¦s reliance on information obtained through this site or a linked site, or userˇ¦s reliance on any product or service obtained from a linked site. It is the responsibility of the user to evaluate the accuracy, completeness, or usefulness of any opinion, advice or other content available through this site, or obtained from a linked site. Please seek the advice of professionals, as appropriate, regarding the evaluation of any specific opinion, advice, product, service, or other content.

DISCLOSURES

Business Continuity Planning

The Wellspring Group and our affiliates - Wellspring Planning Group, Wellspring Wealth Management and Wellspring Associates - are committed to providing timely service to our clients. We recognize the importance of preparing for various disaster scenarios that could hamper our ability to provide service. We have taken aggressive steps to provide for business contingency and continuity planning under a variety of potential scenarios. We continue to evaluate our continuity plans and take the necessary actions to ensure the proper resources are available to provide for the recovery and timely resumption of critical business operations to internal business units, third-party business partners, and clients.

Wellspring Business Continuity Strategy

Offices and Staff

Wellspring has offices and staff located in two primary four principal locations: Atlanta, and Dallas, Salt Lake City, and Savannah. The Atlanta office serves as the primary site for accounting, compliance, HR, and research. These functions, while vital to the business on a continuing basis, are not considered mission-critical for the daily operation of our business. In the event of a disaster that would make the Atlanta office unserviceable, the Dallas office is its alternative facility.

Mission-Critical Departments

Both the Atlanta and Dallas offices serve as primary locations for our mission-critical departments, including: Operations, Transaction Execution and Processing, and Support. Each office serves as the backup for the other. There are documented and tested plans in place to provide for a failover between the two sites.

The Wellspring main data center is located in the Atlanta office. The alternate data center is located within the firm's Dallas location.

  • The main data center infrastructure is fully redundant in terms of power, network, and equipment.
  • The office in Dallas also provides redundant network systems.
  • There is redundant connectivity between Atlanta and Dallas.

Wellspring's client service, policy service, account service, and brokerage service computing platforms are operated in various geographical regions of the United States by unaffiliated third-party vendors (such as insurance carriers, investment custodians, and broker-dealers). The third-party vendors have complete business continuity plans that include alternative sites and recovery times within a few hours.

Business Scenario Preparedness

Office Disruption

If Wellspring loses the ability to perform business at either the Atlanta or Dallas location, mission-critical Atlanta functions would be failed over to our Dallas office and vice versa. Staff associated with non-mission-critical functions will be relocated to an alternative site in an unaffected area. We have plans in place for this relocation and they are tested periodically. Recovery time objectives vary based on the criticality of each function.

Access to Your Policy, Accounts and/or Funds

A site outage should not impact our clients' ability to access their policies, accounts, or available funds, as Wellspring's business contingency plans are designed to ensure sustained service. However, the ability to trade securities may be impacted by market events outside the control of Wellspring, such as when the market was closed following the September 11 tragedy. Our tested business continuity plans result in necessary personnel being available to approve transactions that result in the disbursement of available funds. In the event that your Wellspring advisor ceases operations due to a significant business interruption, you may call your insurance carrier, account custodian, or investment provider for emergency assistance.

Conclusion

Please be aware that, while we have detailed plans in place, we cannot guarantee that we will be successful in achieving recovery in the times noted above. For example, we may not be able to implement a plan during a disaster as quickly as we expect, or there may be disasters that we have been unable to anticipate and for which we have no plan. Additionally, if parts of our plan are dependent upon third parties, we will have no control over the success or failure of the third party to respond appropriately to the challenges posed at the time of the disaster.

Our continuity plans are periodically updated and modified. Updated plan summaries will be made available on our websites (www.wellspringgroupllc.com and www.wellspringassociates.com) and can be obtained by submitting a written request to The Wellspring Group, 2200 Century Parkway, Suite 750, Atlanta, Georgia 30345.