Midwest Institutional Trust Services (MITS) understands that as a financial services institution it must be committed to maintaining the confidentiality of all private client information.

In today’s world, information and data is often stored and transmitted using technology that did not exist even 20 years ago. Although the technology has changed significantly, our commitment to maintaining the confidentiality of client information has not.

Our client relationships are critical to us, and we work to protect those relationships by safeguarding the personal information our clients share with us. We want to ensure an understanding relative to the nature of information that we collect, and the manner in which we use and protect that information.

Information MITS may collect

In the course of providing services, we may collect non-public personal information. That may include:

• Name, address, phone numbers, dates of birth, and even social
  security numbers.
• Family information, such as beneficiaries.
• Important financial information, including account numbers, risk
  tolerance, and assets and liabilities.

Information Collection

Non-public information might be collected from multiple sources:

• Through client meetings, phone calls, and documents and forms
  completed.
• From family members.
• Through third parties and service providers like attorneys, accountants,
  or other professionals who work with our clients.
• From companies that are affiliated with MITS.

MITS will not share any non-public information with third parties, including family members or any professional service providers, without prior explicit direction (other than those required or permitted by law).

Your consent to provide MITS with personal information

How Consent Is Provided: You may provide us with your consent to the collection, use and disclosure of personal information in various ways. Consent can be express (for example, by submitting an online employment application that contains a consent provision) or implied (for example, when you provide information necessary for a service you have requested). You may provide your consent in some circumstances where notice has been given to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option.

Consent For Disclosed Purposes: Generally, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this privacy policy, if applicable, or otherwise at the time of collection.

Third Party Consents: Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). If you provide us with personal information about a third party such as a reference we will assume that you have the consent of that third party to provide their personal information to us.

Withdrawal of Consent: You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. If you withdraw your consent to certain uses of your personal information, we may no longer be able to continue our relationship with you.

How MITS shares personal information

Personal information is used to help us service our clients. We use it to complete transactions and identify services that might be useful. Client information may also be used in other ways. It may be necessary to share client information under certain circumstances, which could include but are not limited to the following:

• With parties that we have been directed to share information with.
• With regulators as required by law.
• With non-affiliated organizations hired by MITS to provide services to
  clients, and to prepare for regulatory examinations.
• With affiliated organizations that we have contracted to provide
  additional services to clients.

MITS does not sell any personal information. Organizations that MITS employs to provide any services to clients are required to maintain the same strict confidentiality policies that MITS adheres to.

MITS is committed to maintaining confidentiality

MITS will take commercially reasonable steps to protect your personal information against loss, theft, or misuse as well as unauthorized access, disclosure, copying, use, modification, alteration, or destruction, which steps may include technical, contractual, administrative, and physical measures that are appropriate to the sensitivity of the information. All MITS employees are required to follow appropriate privacy standards. Personal information is only utilized in providing services to clients, and privacy standards are reinforced annually in mandatory training. MITS maintains data security, cyber security protocols, and physical security measures to ensure that personal information is properly protected.

The practices outlined above represent our current policies with respect to the handling of personal information. MITS reserves the right to modify its privacy policies from time to time. In the event that this privacy policy is modified, clients will be notified of any changes in writing. Your continued provision of personal information or use of MITS services or sites constitutes your acceptance of any such changes. You should review this privacy policy often to ensure familiarity with its then-current terms and conditions.

When should you contact us?

We will continue to evaluate our efforts to protect your personal information and ensure that it is kept accurate and current. If you find any error in your personal information, need to make a change to that information, or have any questions about our policies, please contact us.