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 user's reliance on information obtained through this site or a linked site, or user'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

Wellspring Associates is 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.

Business Continuity Strategy

Offices and Staff

Wellspring Associates has offices and staff located in two primary locations: Atlanta and Dallas. 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 Associates 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 Associates client service, policy service, account service, and computing platforms are operated in various geographical regions of the United States by unaffiliated third-party vendors (such as insurance carriers 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 Associates 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 Associates business contingency plans are designed to ensure sustained service. In the event that your Wellspring Associates advisor ceases operations due to a significant business interruption, you may call your insurance carrier or account custodian 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 website (www.wellspringassociates.com) and can be obtained by submitting a written request to Wellspring Associates, 2200 Century Parkway, Suite 750, Atlanta, Georgia 30345.