Protecting Your Privacy

Website Privacy and Security

We understand that privacy is an important issue for visitors to the Beacon Wealthcare’s Web site. Specifically, Web users are concerned about what information is being collected, how it’s being collected and how it is being used. The following information is designed to help you understand our Web site Privacy Policy.

Public Area Whenever you visit the public area of our site, we recognize you only by your domain name. We do not collect any personal information about you. IF you should choose to use one of the ‘Interactive Calculators’ in our Planning section, please note these calculators are for your information and use only; we do not store or acknowledge any data you should input.

Private Area As a registered user of our website, when you select the option to access your personal reports via your private portal, we will recognize you by your personal User ID and password. When your account is established, you will be given a temporary password via email and from there immediately prompted to change that password. Beacon does not have access to either your password, or the initial temporary password sent to you. You may change your password as often as you feel necessary.

To prevent password guessing, accounts are locked after 5 unsuccessful sign in attempts.

We will never disclose your personal information, or share it with any third party unless specifically instructed to do so by you.

If you would rather not have access to your reports on our Web site, please contact us and we will deactivate the information.

How Do We Protect Your Information?

When you access your financial data, we use a secure server to keep all of your personal information as secure as possible. The Transfer Layer Security (TLS ) protocol provides secure communications on the Internet by doing three things:

1. TLS encryption verifies that the server that you are communication with is the one it purports to be.

2. TLS creates a secure communication channel by encrypting all communication and viewing between the user and the server.

3. TLS conducts checks to verify data integrity between the server and the client (or user). TLS verifies that the entire message.

4.The software utilizes .NET session management for authenticating individual users and allowing permissions through the applications

In addition, we have an internal firewall in place, and monitor that we have the latest in virus protection. This approach helps ensure that your personal data remain safe and private. We will continue to implement security features in the future that will maintain the highest levels of secure data transmissions.

Use of Cookies The beaconwc.com site, like many web sites, uses “cookies” (information stored on your computer by your browser at our request). Cookies enable the site to ‘remember’ whom you are so that you can get navigate around it easier and more efficiently. We do not save any personal or sensitive information in our 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 same Transfer Layer Security ( TLS) technology we use to transmit account reporting.

Logging Off When you finish accessing your account, don’t forget to log off. This prevents someone else from accessing your account if you leave your computer and your session hasn’t “timed out”, or automatically shut down.   We further recommend closing your browser for added security.

 

Summary of Proxy Voting Policies and Procedures 

Beacon Wealthcare (“BEACON, or, the Firm”) has adopted proxy voting policies and procedures which are described below.  As a matter of policy and as fiduciary to our clients, BEACON has responsibility for voting proxies for portfolio securities consistent with the best economic interest of this client.

BEACON votes consistently for all clients, and does not engage in voting the specific voting requirements of any client.

BEACON’s authority to vote the proxies of its clients is established by the Management Agreement and the Schwab new account form. However, at the time of opening the account the client has the option to vote or to allow us to vote proxies. If a change is required afterwards, it will be made upon written request.

Since the recommended portfolios of BEACON represent broad indices of securities (ETFs) as the primary client holding, generally speaking BEACON only votes on matters regarding the fee structure of those securities as it is the one issue BEACON is focused on actively monitoring. Otherwise, all non-material issues are viewed as very unlikely to impact the pricing or returns from holding such ETFs.

Due to the nature of BEACON’s recommended portfolios of ETFs, which generally do not have proxies, we believe it would be very unusual for conflicts of interest to arise in proxy voting as it would be focused only on keeping fund fees low for our clients.

The custodian, Charles Schwab, will be relied upon to forward all relevant proxy material to BEACON, either electronically or in physical form to the address of record.  Receipt of proxies will be recorded and will be voted upon in a timely manner.  Records of each proxy vote are retained by BEACON.

Clients may obtain a copy of the Policies by phoning Patricia Hall at 919.821.5225 or via email at phall@beaconwc.com .  Information on how Beacon voted on a particular proxy for any security held can be obtained by either calling the above number or emailing as well.

Code of Business Conduct and Ethics

Beacon Wealthcare Inc., (Beacon), as a fiduciary, is committed to conducting business with honesty, competence, and integrity.  Compliance with the law is fundamental to the ethical and business principles of Beacon Wealthcare.

The following policies have been adopted by Beacon pursuant to paragraphs (a) (1), (2), (4) and (5) of Rule 204A-1 under the Investments Advisors Act of 1940 with the objective of deterring wrongdoing and to provide standards of ethical and honest conduct.  The following policies are set forth to provide guidance to officers and employees and in addition, ensure they act in accordance with not only these but also the spirit of the laws and regulations that apply to the Company’s business.

Annual Review

Each Officer, and employee shall provide written acknowledgment annually that they have read and understand this Code and its contents and they have not violated the Code, and are not aware that any other Officer, or employees has violated this Code.  

 

Compliance with Laws, Rules and Regulations

This Conduct and Code of Ethics applies to each and every employee, and officer.  All employees and officers are expected to read these policies, comply with them and acknowledge such in writing.  The compliance officer, Patricia Hall will administer and interpret this Code as well as implement rules and procedures to promote its effectiveness. The activities of Beacon must at all times be in full compliance with all rules, regulations and laws of the jurisdictions in which the Company conducts business.  All employees and officers are expected to fully comply with this Code. Any questions regarding compliance with any laws, rules or regulations should be directed to the Compliance Officer.

Beacon is a North Carolina state registered investment adviser and subject to the compliance with federal, state, and local laws. 

Conflicts of Interest

No employee or officer will have a “conflict of interest” with Beacon Wealthcare.  A “conflict of interest” exists when a person’s private interest interferes, or even appears to interfere, with the interest of Beacon Wealthcare.   Some types of transactions and/or relationships that might cause a conflict of interest and that should be considered are:

  1. Favoring the interests of one client over another or favoring larger accounts over smaller accounts.
  2. Use or disclosure of confidential information for personal profit by any employee or officer.
  3. Competing with client trades, and using that knowledge to profit personally, directly or indirectly, as a result of such transactions, including by purchasing or selling such securities.

The above list is only a guide in identifying potential conflicts of interest. A review will be done on any circumstances that could possible be deemed as a conflict of interest. All employees and officers are required to promptly make full and fair disclosure of any matter that could be expected to impair their objectivity or interfere with duties to Beacon, its clients, or prospective clients to the compliance office including any transaction or relationship that could be deemed as a conflict. Every employee and officer is expected to avoid any outside activity, financial interest or relationship that may present a possible conflict of interest.  No employee or officer may engage in any activity that involves any conflict except with specific prior approval in accordance with procedures set out in this Code and the Beacon Wealthcares Compliance Manual.

Corporate Opportunities

Each Employee and officer is prohibited from

  1. Using corporate property, information or position for personal gain
  2. Competing with Beacon
  3. Taking for themselves personally opportunities that are found through the use of Beacon’s property or information, or through their position with Beacon, unless prior approval is given by Beacon’s President.
  4. Offering, soliciting, or accepting any gifts, benefits, compensation, or consideration that reasonably could be expected to compromise Beacon and/or its clients.

Confidentiality

Employees and officers should maintain confidentiality at all times. Confidential information includes proprietary information of Beacon and its clients, employee data and all other non-public information that might be of use to competitors, or harmful to Beacon and its clients, if disclosed is confidential.  This confidential information should be protected at all times, however may be subject to legal or regulatory requirements to disclose that information.  In such cases, the President of Beacon will assist in determining what disclosure is required.  Confidentiality of information continues after association with Beacon ends.

Fair Dealing

All employees and officers should deal fairly with customers, suppliers, employees, and competitors. No person will take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice.  The interest of clients is placed first at all times.

Protection and Proper Use of Company Assets

Employees and officers are expected to protect and help ensure the efficient use of Beacon’s assets, including trade secrets, proprietary information, equipment and other property created, obtained or compiled by employment with Beacon. All company assets should be used for a legitimate business purpose as deemed so by the President of Beacon. The misuse or removal from Beacon’s facilities of Beacon assets is prohibited, unless specifically authorized by an appropriate representative of Beacon. All electronic devices used outside the office must have up to date antivirus in place.

Any suspected fraud or theft should be immediately reported to the Compliance Officer or the President.

Personal and Insider Trading

Beacon currently has an insider trading policy which governs its employees and officers.  This policy states that employees and officers may not trade in stocks of companies which they may learn material, non-public information through the course of their employment or service. They are also prohibited from passing on such information to others.

Personal trading reports for all access and related persons of Beacon are reviewed daily by the Compliance Officer and are kept monthly.  Statements of all holdings for access persons are recorded quarterly and filed at least annually.  In addition, it is firm policy that complete reports of securities holdings must be made available and filed at the time there is a new access person, and at least filed annually thereafter.

Any IPO or private placement that may be done by an access person must be pre-approved by Sam Bass, Jr.

Anti-Corruption

Firm policy prohibits any employee from providing anything of value to a foreign government official without first obtaining approval from a designated officer of the firm, as well as prohibits facilitation payments.  Designated officers of the firm will conduct risk-based due diligence prior to any engagement of third parties such as consultants, representatives and other intermediaries and any other individual/entities representing Beacon.

Public Filings and Communications

Beacon Wealthcare upholds fair, full, accurate, timely and understandable disclosure for use in any reports and documents that Beacon files with, or submits to, the Securities and Exchange Commission and in other public communications made by Beacon.  All employees and officers are expected to communicate whether by email correspondence, reports, or documents; in a fair, accurate, timely and understandable method and must not knowingly make any misleading or misrepresentations regarding investment returns, recommendations, or any other professional activity.  The compliance officer or the President of the Company should be consulted prior to any public disclosure of information concerning Beacon. Any questions regarding this should be directed to the compliance officer.

Recordkeeping and Record Retention

Beacon requires honest and accurate recording and reporting of information. Beacon complies with all laws and regulations regarding the preservation of its books, records, account and financial statements, and are all kept for a minimum of five years. Assets of Beacon are carefully and properly accounted for. Any employee or officer making false or misleading records or documentation is strictly prohibited.   Beacon does not maintain unrecorded funds or assets.  All emails are archived by an outside vendor.

 

Reporting Violations

All suspected violations of this Code, applicable laws and regulations, or Beacon’s other internal policies or procedures must be reported immediately to either the compliance officer or the President.  Each employee and officer are encouraged to talk to the compliance officer or the president when in doubt about the best course of action in a particular situation.    Employees may make a report anonymously to the compliance officer if they suspect any unlawful or fraudulent activity. Beacon does not permit retaliation of any kind for good faith reports of violations or possible violations.  All employees and officers are expected to fully cooperate with any internal investigations or either apparent or actual violations of this Code.  All reported violations are immediately investigated, and a record is retained for all investigations, reports, and actions taken.  Beacon reserves the right to take legal action where necessary against employees who engage in prohibited or unlawful conduct.

Social Media

Employees are required to protect the privacy of Beacon Wealthcare Inc., its clients and employees, and are prohibited from disclosing personal employee and non-employee information and any other proprietary and non-public information to which employees have access.  Such information includes but is not limited to customer information, trade secrets, financial information and strategic business plans. Employees cannot use blogs or social media sites to harass, threaten, discriminate or disparage against employees or anyone associated with or doing business with Beacon. Employees cannot post company-privileged information, including copyrighted or trademarked information or company-issued documents.  Employees cannot post on personal blogs or social networking sites photographs of other employees, clients, vendors or suppliers, nor can employees post photographs of persons engaged in company business.  All employees must adhere to the Social Media guidelines in place at Beacon. 

Violations

Any employee or officer who violates this Code will be subject to disciplinary action, up to and including dismissal.  Violations of some provisions of this Code are illegal and may subject the employee or officer to civil and criminal liability.  If there are any questions regarding any information in this Code, they should be directed to the compliance officer.

 

Waiver

Any waiver of the provisions of this Code for executive officers of Beacon may be made only by the President and must be promptly disclosed, along with the reasons for the waiver.

Glossary

“Employee” means any and all employees of Beacon

“Officer” means any officer or director of Beacon

Any questions regarding this should be directly to Patricia Hall at 919.821.5225 or phall@beaconwc.com .

 

 

Disclaimer This web-site is for informational purposes only and does not constitute a complete description of our investment services or performance. This web-site is in no way a solicitation or offer to sell securities or investment advisory services except, where applicable, in states or countries where we are registered or where an exemption or exclusion from such registration exists. The information contained on this web site should not be construed as financial or investment advice on any subject matter. Beacon Wealthcare expressly disclaims all liability in respect to actions taken based on any or all of the information on this web site. Information throughout this site, whether stock quotes, charts, links, articles, or any other statement or statements regarding market or other financial information, is obtained from sources which we, and our suppliers believe reliable, but we do not warrant or guarantee the timeliness or accuracy of this information. No information on this web-site should be interpreted to state or imply that past results are an indication of future performance. Neither we nor our information providers shall be liable for any errors or inaccuracies, regardless of cause, or the lack of timeliness of, or for any delay or interruption in the transmission thereof to the user. There are no warranties, expressed or implied, as to accuracy, completeness, or results obtained from any information posted on this or any linked web-site. The information provided on this site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject Beacon Wealthcare to any registration requirement within such jurisdiction or country. You are solely responsible for your use of this web site. You shall indemnify and hold Beacon Wealthcare harmless from and against any and all claims, damages, liability and/or costs relating to your use of this web site. Due to the increase of computer viruses affecting the Internet, we want to warn you about infections or virus contamination of your system. You solely have the responsibility to scan any and all downloaded materials received from the Internet. Beacon Wealthcare is not responsible or liable for any damage or data loss due to these circumstances.

Copyright or Other Notices If you download any information or software from this site, you agree that you will not copy it or remove or obscure any copyright or other notices or legends contained in any such information. You are prohibited and will be responsible for any and all of our unlawful use of this web site. Beacon Wealthcare reserves the right to terminate, without prior notice to you, your access to this Web site.