Protecting Your Privacy
Website Privacy and Security
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.
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 Advisory 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 [email protected] . 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 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.
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 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 registered investment adviser with the SEC 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:
- Favoring the interests of one client over another or favoring larger accounts over smaller accounts.
- Use or disclosure of confidential information for personal profit by any employee or officer.
- 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 Wealthcare’s Compliance Manual.
Each Employee and officer are prohibited from:
- Using corporate property, information or position for personal gain
- Competing with Beacon
- 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.
- Offering, soliciting, or accepting any gifts, benefits, compensation, or consideration that reasonably could be expected to compromise Beacon and/or its clients.
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.
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.
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.
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.
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.
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.
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.
“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 [email protected] .
As a matter of policy, Beacon Wealthcare Inc. seeks to prevent the theft or misappropriation and misuse of the identities and identifying information of its clients. In order to prepare this program, the firm has evaluated the risks of identity theft in connection with its investment advisory practice including the firm’s:
- methods of opening client accounts;
- methods for accessing client accounts; and
- previous experience with identity
The principal risks of identity theft acknowledged by Beacon Wealthcare Inc. lie in the methods for accessing accounts and the acceptance of instructions for transfers out of an account for the payment of third party payees or otherwise.
Identification of Red Flags
From time to time, Beacon Wealthcare Inc. or its staff may receive indications that the identities of clients or investors may have been compromised, stolen or are otherwise at risk. It is critical that these “red flags” are recognized so that the firm can take appropriate measures to safeguard clients and investors and prevent the misappropriation and misuse of client or investor identities and assets.
Categories of red flags to consider include the following:
- alerts, notifications or other warnings received from consumer reporting agencies or service providers, such as fraud detection agencies;
- presentation of suspicious personal identifying information, such as suspicious address change;
- unusual use of, or other suspicious activity related to a covered account, including, but not limited to:
- unexplained or urgent requests for large transfers or payments to be made from the account to third parties;
- telephone requests for urgent transfers from the client’s account on a unclear or poor connection, particularly where the client is unwilling to remain on the line or claims to be in a hurry;
- requests to transfer funds from the client’s account to a new or recently opened bank account, and;
- notice from clients or investors regarding unusual transfers or account activity, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with covered accounts held by Beacon Wealthcare Inc. client
Any Beacon Wealthcare Inc. personnel becoming aware of red flags, suspicious activity or unusual transfer requests must promptly notify the CCO and/or other designated person(s) before taking any further action to facilitate a transfer from the client’s account (if applicable).
Detection of Red Flags
Beacon Wealthcare Inc. and its staff should be conscious of suspicious activity or transfer requests and actively seek to detect red flags in connection with the opening and maintenance of accounts.
With respect to the opening of client accounts, Beacon Wealthcare Inc. seeks to obtain appropriate identifying information about, and verification of the identity of, the client. In order to confirm client identities, when opening accounts, if a client is not known to us personally, a driver’s license must be shown to us. In addition, our custodian verifies the account information, including address, social security, and other vital information with outside official sources.
Transfer/Payment Requests and Address Changes
Beacon Wealthcare Inc. is also committed to monitoring transfers and transactions within client accounts and seeking to authenticate clients and client requests for transfers, whether such requests direct the transfer of funds from the client’s account to third party payees or to another account in the client’s name, particularly (though not exclusively) when the receiving client account was only recently opened and/or the request was received via email or other electronic communication.
Clients can login to view their transactions and accounts via a sign in they create using their personally information. All sites are secured. Only a request for a check being mailed to the name and address of record or a request to move funds via pre-authorized money movement to a bank account can be taken over the phone. All other requests (such as wire transfers, checks to an alternate address, etc), must be done in writing, with the signature being matched to what is on file, prior to processing. For third party wire transfers an additional phone call is done to confirm the request.
We are never authorized to process a wire transfer unless we have spoken to the client and they have confirmed the instructions in writing and signed. We do not handle standing instructions for any wire transfers.
Should a client request that Beacon Wealthcare Inc. facilitate a transfer of monies from the client’s account to a new or different account held in the client’s name, the firm shall:
- request written instructions with the client’s original signature requesting that Beacon Wealthcare Inc. update the wire instructions on file with the firm;
- verify that written instructions submitted are from the client or other authorized signatory on the account;
- seek to ensure that the signature on the written instructions match the signature on file with the firm; and
- ensure the request is addressed to Beacon Wealthcare
Any request received (ostensibly) from a client to facilitate a transfer of monies from the client’s account to a third party payee, must undergo the same process set forth above and Beacon Wealthcare Inc. should seek to verify the request as set forth below. Similarly, any request for a change of address on a client’s account must be verified by Beacon Wealthcare Inc. before being processed.
Verifications are to be accomplished through direct contact with the client at the telephone number held on record with Beacon Wealthcare Inc. Telephone contact with the client must be documented and is required regardless of whether the request for transfer or address change was received by email or telephone as a fraudster impersonating the client could have easily contacted the firm to make the request from a different phone number. When seeking verification at the client’s telephone number of record, should a client deny having requested the transfer, the Beacon Wealthcare Inc. employee having spoken to the client must immediately notify the CCO or other designated person(s).
Responding to Red Flags
To best protect our clients and investors and ensure that the firm responds in an appropriate manner to red flags and suspicious activity, all red flags and suspicious activity recognized or uncovered by personnel should be promptly reported to the CCO and/or other designated person(s).
When determining the appropriate response to red flags, Beacon Wealthcare Inc. will consider the degree of risk posed and aggravating factors that may heighten the risk of identity theft, such as a data security incident that results in unauthorized access to a client’s or investor’s account records held by the Beacon Wealthcare Inc. or other third party, or notice that a client has provided information to someone fraudulently claiming to represent Beacon Wealthcare Inc. or to a fraudulent website.
Appropriate responses may include the following, based on a consideration of the relevant facts and circumstances:
- monitoring a covered account for evidence of identity theft;
- contacting the client or investor;
- contacting the account custodian;
- temporarily requesting a freeze on any asset transfers from the account;
- changing any passwords, security codes, or other security devices that permit access to the account;
- reopening an account with a new account number;
- not opening a new account;
- closing an existing account;
- notifying law enforcement and regulatory authorities; or
- determining that no response is warranted under the particular
Oversight of Third-Party Service Providers
Our firm uses various service providers, including custodians and brokers in connection with our covered accounts. We have a process to confirm that relevant service providers that perform activities in connection with our covered accounts comply with reasonable policies and procedures designed to detect, prevent and mitigate identity theft by contractually requiring them to have policies and procedures to detect Red Flags. Typically, we will request an effective identity theft prevention program implementation certification from each critical service provider (e.g., brokers, custodians, etc.) on an initial and annual basis.
Furthermore, when appropriate and to ensure that our firm’s identity theft prevention program is consistently implemented, we may require certain service providers who directly or indirectly participate in the identity theft prevention effort to agree not to take, without Beacon Wealthcare Inc.’s specific approval, actions such as the following:
- not to change wire instruction;
- not to direct any redemption proceeds to an account not listed in the original subscription document;
- not to partition, retitle, or otherwise change any indicia of ownership of an investment or account (including changes purportedly for estate planning and domestic relations reasons); or
- not to consent to liens or control agreements being placed on an investment or
Updates and Approval
Beacon Wealthcare Inc.’s identity theft program shall be reviewed and approved in writing by senior management of the firm. Periodically, and at least yearly, the CCO and/or other designated person(s) shall review the program and present senior management with a report regarding the effectiveness of the program and any suggestions for improving the program based on changing or newly perceived risks, such as:
- the experiences of Beacon Wealthcare Inc. with identity theft;
- changes in the types of accounts that Beacon Wealthcare Inc. offers or maintains;
- changes in methods used by fraudsters to perpetrate identity theft;
- changes in methods to detect, prevent, and mitigate identity theft; and
- changes in the business arrangements of Beacon Wealthcare Inc., including mergers, acquisitions, alliances, joint ventures, and service provider
It is imperative that all personnel be familiar with the firm’s identity theft program and have a thorough understanding of his/her role and responsibilities in protecting our clients and investors. To this end, Beacon Wealthcare Inc. will conduct initial and annual training regarding its identity theft program to assist personnel to recognize and appropriately respond to and report red flags and other suspicious activity. Employees are encouraged to ask the CCO or other designated person(s) for clarification or additional information regarding the program in general or any suspicious activity in particular.
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.