website disclosures

WEBSITE OWNERSHIP

This website is owned and operated by Robo Advisor™, 255 Primera Blvd., Suite 160, Lake Mary, FL 32746-2168, which is also referred to in these terms as “Robo Advisor” or “we” or “us” or “Company” or “our”.

Robo Advisor™ is the marketing name for Robo Advisor Technologies™, Robo Advisor, Inc. and Sovereign Wealth Management Group, Inc. For purposes of these Terms and Conditions of Use, the term "The Company" includes without limitation all Robo Advisor™ parents, branches, subsidiaries, affiliates and other entities.

NOTE: PLEASE READ THESE TERMS & CONDITIONS CAREFULLY BEFORE CONTINUING. IF YOU DO NOT AGREE WITH ANY OF THESE TERMS OR CONDITIONS, DO NOT ACCESS OR OTHERWISE USE THIS WEBSITE OR ANY INFORMATION CONTAINED ON THIS WEBSITE.

THESE TERMS & CONDITIONS ARE A BINDING AGREEMENT BETWEEN YOU AND US. BY USING OR ACCESSING THE ROBO ADVISOR™ SITES, YOU ACCEPT AND AGREE TO BE BOUND BY THESE TERMS OF USE. YOUR USE OF THESE WEBSITES AND YOUR TRANSACTIONS CONDUCTED WITH THE COMPANY IN CONNECTION WITH THESE WEBSITES ARE GOVERNED BY THE VERSION OF THE TERMS OF USE IN EFFECT ON THE DATE EACH ROBO ADVISOR™ SITE IS ACCESSED BY YOU. CLICKING ONTO WEB PAGES BEYOND THE WEBSITE’S HOMEPAGE CONSTITUTES YOUR ACCEPTANCE OF AND AGREEMENT WITH THE TERMS OF USE WHETHER OR NOT YOU COMPLETE A TRANSACTION WITH THE COMPANY AND WHETHER OR NOT YOU COMPLETE YOUR TRANSACTION ON THE WEBSITE OR THROUGH OTHER CHANNELS, SUCH AS BY PHONE, BY E-MAIL, FACSIMILE OR OTHERWISE.

THESE TERMS OF USE ARE SUBJECT TO CHANGE, UPDATE AND/OR REVISION (COLLECTIVELY "CHANGE") BY THE ROBO ADVISOR™ COMPANIES, PARENTS, SUBSIDIARIES, AFFILIATES AND ENTITIES IN THEIR SOLE DISCRETION AT ANY TIME, WITHOUT NOTICE. YOUR USE OF THESE SITES AFTER ANY SUCH CHANGE CONSTITUTES YOUR ACKNOWLEDGMENT AND ACCEPTANCE OF SUCH CHANGE. YOU SHOULD THEREFORE PERIODICALLY VISIT THIS PAGE TO REVIEW THE MOST CURRENT TERMS AND CONDITIONS OF USE REGULARLY. THESE TERMS ARE IN ADDITION TO ANY OTHER AGREEMENTS BETWEEN YOU AND ROBO ADVISOR™, INCLUDING ANY CUSTOMER OR ACCOUNT AGREEMENTS, AND ANY OTHER AGREEMENTS THAT GOVERN YOUR USE OF INFORMATION, CONTENT, TOOLS, PRODUCTS AND SERVICES AVAILABLE ON AND THROUGH ROBO ADVISOR™ SITES.

ACCESS TO ROBO ADVISOR™ SITES

Robo Advisor™ is pleased to offer you access to the information, content, resources, tools, products and services on all Robo Advisor™ sites (the term “Robo Advisor™ Sites” or "Site" or "Sites" refers to all web sites, as well as the content on them). Because these Terms of Use cover multiple web sites, some terms may refer to items that are available only on certain Robo Advisor™ Sites. These Terms of Use also include some important disclosures and information related to certain products and services that may or may not be available yet. Your use of Robo Advisor™ Sites is subject to these Terms of Use (“Terms”). There are various Robo Advisor™ companies (“Robo Advisor™ Entities”), and their affiliates, that provide information, content, tools, products and services on and through the Robo Advisor™ Sites.

Because you may be asked to provide certain registration details or other information. It is a condition of your use of these Sites that all the information you provide on these Sites will be correct, current, and complete. If The Company believes the information you provide is not correct, current, or complete, it retains the right to deny access to these Sites or any of its resources, and to terminate or suspend your access at any time.

RESTRICTIONS ON USE

You may use Robo Advisor™ Sites only for purposes expressly permitted by the Site. You may not use Robo Advisor™ Sites for any other purpose, including any commercial purpose, without The Company's prior written consent. For example, you may not (and may not authorize any other party to) (i) co-brand this Site, (ii) frame this Site, or (iii) hyperlink or deep-link to Robo Advisor™ Sites without the express prior written consent of an authorized representative of The Company. For purposes of these Terms and Conditions of Use, "co-branding" means to display a name, logo, trademark, or other means of attribution or identification of any party, in a manner that is reasonably likely to give a user the impression that such other party has the right to display, publish, or distribute Robo Advisor™ Sites or Content (as defined below) accessible within this Site. You agree to cooperate with The Company in causing any unauthorized co-branding, framing, or linking to immediately cease.

PROPRIETARY INFORMATION

Except for third party performance of mutual funds or sub-accounts, the information, reports, material and content accessible on or generated by this Site, and any other site owned, operated, licensed, or controlled by The Company (the "Content") is proprietary information of The Company or its licensor and The Company or its licensor retains all right, title, and interest in and to the Content. Content may not be copied, reproduced, performed, displayed, distributed, republished, uploaded, posted, or transmitted in any way without the prior written consent of The Company, which may be withheld in its sole discretion, except that you may print out a copy of the Content solely for your personal use. In doing so, you may not remove or alter, or cause to be removed or altered, any copyright, trademark, service mark, or any other proprietary notice or legend or regulatory disclosure appearing on any of the Content. Modification or use of the Content except as expressly provided in these Terms and Conditions of Use violates The Company's or its licensor's intellectual property rights. Neither title nor intellectual property rights are transferred to you by your use of or access to this Site.

HYPERLINKS

The Company may provide hyperlinks to other sites ("Third Party Sites"). Third Party Sites are not maintained by, related to, or sponsored or affiliated by, The Company and are provided as a service and convenience to you. The Company has not reviewed Third Party Sites and is not responsible for their content. Third Party Sites are to be accessed at your own risk, and The Company makes no representations or warranties about the content, or the completeness, accuracy or security of Third Party Sites. A hyperlink to a service or site is not an endorsement of the service or site, its content, or its sponsoring organization. Furthermore, The Company is not liable for any direct or indirect computer system damage or other problems you may incur as a result of clicking on a link to any Third Party Site.

WHAT INFORMATION IS COLLECTED BY THIS SITE

In general, you can visit Robo Advisor™ Sites while remaining anonymous by not providing any Personal Information (as defined by applicable law). In some cases, non-personal information may be automatically collected, such as your Internet browser, computer operating system, domain name of your Internet service provider, IP address, and/or the web site from which you linked to this Site. Personal Information about you (e.g., your name, address, telephone number, SSN, and/or Email address) will not be collected unless you provide it to us voluntarily. For example, The Company retains Email addresses of visitors who respond to this Site's Email forms, online forms, registration forms, and surveys and contest entries. The Company may also retain information about the frequency of Site visits, duration of each visit, and aggregate information on which Site pages you access. If you choose not to provide Personal Information, we may not be able to respond to a request, or an error message may be displayed on your browser. For more information please access The Company's web site privacy statement located here.

COOKIES

The Company sends Site visitors cookies, web bugs or pixel tags (collectively, "Cookie"), each of which is a small data file sent by the Site to your browser and which may be stored on your hard drive. The Company's Cookie enables the Site to recognize you if you have a Company policy or contract, or have previously utilized certain Site features. In addition, the Cookie may recall information so that you do not have to resubmit it, and also automatically updates Site information. If available, you may program your browser software to notify you of attempts to send cookies and/or you may decline to accept or delete them. Your declination of any Site Cookie may impair your ability to access or use certain functionality of the Site or require you to enter and re-enter information each time you visit the Site.

SUBMISSIONS

You hereby grant to The Company the royalty-free, perpetual, irrevocable, worldwide, nonexclusive right and license to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, perform, and display all content, remarks, suggestions, ideas, graphics, or other information communicated to The Company through this Site (collectively, the "Submission"), and to incorporate any Submission in other works in any form, media, or technology now known or later developed. The Company will not be required to treat any Submission as confidential, and may use any Submission in their businesses (including without limitation, for products or advertising) without incurring any liability for royalties or any other consideration of any kind, and will not incur any liability as a result of any similarities that may appear in future operations. The Company will treat any Personal Information that you submit through this Site in accordance with its web site privacy statement.

DISCLAIMER

You understand that The Company cannot and does not guarantee or warrant that Content available for downloading from this Site or the Internet will be free of viruses, worms, Trojan Horses, or other malicious code that may manifest contaminating or destructive properties. You are responsible for implementing sufficient procedures and checkpoints to satisfy your particular requirements for accuracy of data input and output, and for maintaining a means external to this Site for the reconstruction of any lost data. The Company does not assume any responsibility or risk for your use of the Internet or this Site, nor does The Company assume any responsibility for any products or services or hypertext links to third parties or for any breach of security associated with your use of this Site or your transmission of sensitive information through this Site or any hyperlinked sites.

If you have agreed to the electronic delivery of documents or conduct business electronically with The Company, The Company may, at its discretion, make certain documents required by regulatory authorities, including but not limited to, the Securities and Exchange Commission (the SEC), Financial Industry Regulatory Authority (FINRA) or state departments of insurance, available for download or access electronically or via Email (such documents may include quarterly or annual statements, prospectuses and confirmations) (collectively, the “Required Documents”). Click here to review The Company's Electronic Information Consent Terms and Conditions.

The Content, excluding the Required Documents, is not necessarily complete and up-to-date and should not be used to replace any written reports, statements, or notices provided by The Company. Account information, other than the Required Documents, available on this Site is not the official record of your account. Investors, borrowers, and other persons should use the Content in the same manner as any other informational medium and should not rely on the Content, excluding the Required Documents, to the exclusion of their own professional judgment. Information obtained by using this Site is not exhaustive and does not cover all issues, topics, or facts that may be relevant to your goals and objectives. Nothing on this Site should be construed as rendering tax, legal, investment, or accounting advice.

YOUR USE OF THIS SITE IS AT YOUR OWN RISK. THE CONTENT IS PROVIDED "AS IS" AND WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESSED OR IMPLIED. THE COMPANY DISCLAIMS ALL WARRANTIES, INCLUDING ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, SECURITY OR NONINFRINGEMENT. THE COMPANY DOES NOT WARRANT THAT THE FUNCTIONS OR CONTENT CONTAINED IN THIS SITE WILL BE UNINTERRUPTED OR ERROR-FREE, THAT DEFECTS, IF ANY, WILL BE CORRECTED, OR THAT THIS SITE OR THE SERVER THAT MAKES IT AVAILABLE ARE FREE OF VIRUSES, DISABLING DEVICES OR OTHER HARMFUL COMPONENTS. THE COMPANY DOES NOT WARRANT OR MAKE ANY REPRESENTATION REGARDING THE USE, OR THE RESULT OF USE, OF THE CONTENT IN TERMS OF CORRECTNESS, ACCURACY, RELIABILITY, OR OTHERWISE. THE CONTENT MAY INCLUDE TECHNICAL INACCURACIES OR TYPOGRAPHICAL ERRORS, AND THE COMPANY MAY MAKE CHANGES OR IMPROVEMENTS AT ANY TIME. YOU, AND NOT THE COMPANY, ASSUME THE ENTIRE COST OF ALL NECESSARY SERVICING, REPAIR OR CORRECTION IN THE EVENT OF ANY LOSS OR DAMAGE ARISING FROM THE USE OF THIS SITE OR ITS CONTENT. THE COMPANY ASSUMES NO LIABILITY OR RESPONSIBILITY FOR ERRORS OR OMISSIONS IN SUCH CONTENT.

All of the information on this Site, whether historical in nature or forward-looking, speaks only as of the date the information is posted on this Site, and The Company does not undertake any obligation to update such information after it is posted or to remove such information from this Site if it is not, or is no longer, accurate or complete. All Content, together with information filed and furnished with the Securities and Exchange Commission and any oral information provided by The Company's executives that relates to The Company's future performance or financial results are considered forward-looking statements. These forward-looking statements involve uncertainties that could cause actual performance or results to materially differ, and users are cautioned not to place undue reliance on them. All forward-looking statements should be read in conjunction with the additional information about risks and uncertainties set forth in our Securities and Exchange Commission reports, including any annual report.

LIMITATION OF LIABILITY

THE COMPANY, ITS SUBSIDIARIES, AFFILIATES, LICENSORS, SERVICE PROVIDERS, CONTENT PROVIDERS, EMPLOYEES, AGENTS, OFFICERS, AND DIRECTORS WILL NOT BE LIABLE FOR ANY ACTUAL, DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY, PUNITIVE OR OTHER DAMAGES, INCLUDING LOSS OF REVENUE OR INCOME, LOSS OF PRINCIPAL, PAIN AND SUFFERING, EMOTIONAL DISTRESS, OR SIMILAR DAMAGES THAT RESULT FROM THE USE OF, OR THE INABILITY TO USE, THE CONTENT ON THIS SITE, EVEN IF THE COMPANY OR A REPRESENTATIVE AUTHORIZED BY THE COMPANY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. APPLICABLE LAW MAY NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY OR INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION OR EXCLUSION MAY NOT APPLY TO YOU. IN NO EVENT WILL THE COLLECTIVE LIABILITY OF THE COMPANY AND THEIR SUBSIDIARIES, AFFILIATES, LICENSORS, SERVICE PROVIDERS, CONTENT PROVIDERS, EMPLOYEES, AGENTS, OFFICERS, AND DIRECTORS TO ANY PARTY (REGARDLESS OF THE FORM OF ACTION, WHETHER IN CONTRACT, TORT, OR OTHERWISE) EXCEED THE LESSER OF $100 OR THE AMOUNT YOU HAVE PAID FOR THE APPLICABLE CONTENT OR SERVICE OUT OF WHICH LIABILITY AROSE.

INDEMNITY

You will indemnify and hold The Company, its parents, subsidiaries, affiliates, licensors, content providers, service providers, employees, agents, officers, directors, and contractors (the "Indemnified Parties") harmless from any breach of these Terms and Conditions of Use by you, including any use of Content other than as expressly authorized in these Terms and Conditions of Use. You agree that the Indemnified Parties will have no liability in connection with any such breach or unauthorized use, and you agree to indemnify the Indemnified Parties against any and all resulting losses, damages, judgments, awards, costs, expenses, and attorneys' fees in connection therewith. You will also indemnify and hold the Indemnified Parties harmless from and against any claims brought by third parties arising out of or related to your use of the Content accessed from this Site.

TRADEMARKS, SERVICE MARKS AND COPYRIGHTS

Unless otherwise specifically noted images, trademarks, service marks, logos, and icons displayed on this Site are the property of The Company or its licensors and may not be used without The Company's prior written consent. The Company and its licensors retain all rights with respect to any of their respective trademarks, service marks, and logos appearing on this Site. Any unauthorized use of the images may violate copyright, trademark, privacy and publicity laws and regulations.

INFORMATION YOU PROVIDE

You may not post, send, submit, publish, or transmit on, through, by or in connection with this Site any material that:

• You do not have the right to post, including proprietary material of any third party;
• Advocates illegal activity or discusses an intent to commit an illegal act;
• Does not pertain directly to this Site;
• Threatens or abuses others, libels, defames, invades privacy, stalks, is racist, abusive, harassing, threatening, offensive, vulgar, obscene, pornographic or indecent;
• Seeks to exploit or harm children by exposing them to inappropriate content, asking for personally identifiable details, or otherwise;
• Infringes any intellectual property or other right of any entity or person, including violating anyone's copyrights or trademarks or their rights of publicity;
• Violates any law or may be considered to violate any law;
• Impersonates or misrepresents your connection to any other entity or person or otherwise manipulates headers or identifiers to disguise the origin of the content;
• Advertises any commercial endeavor (e.g. offering for sale products or services) or otherwise engages in any commercial activity (e.g. conducting raffles or contests, displaying sponsorship banners, and/or soliciting goods or services) except as may be specifically authorized on this Site;
• Solicits funds, advertisers, or sponsors;
• Includes programs which contain viruses, worms, and/or Trojan Horses or any other computer code, files, or programs designed to interrupt, destroy, or limit the functionality of any computer software or hardware or telecommunications;
• Disrupts the normal flow of dialogue, causes a screen to scroll faster than other users are able to type, or otherwise acts in a way which affects the ability of other people to engage in real time activities via this Site;
• Amounts to a "ponzi" or similar scheme;
• Disobeys any policy or regulations established from time to time regarding use of this Site or any networks connected to this Site; or
• Contains hyperlinks to other sites that contain content that falls within the descriptions set forth above.

If you do not want to provide this information to us via the Internet, please contact us at (407) 474-5600 or your financial advisor to assist you.

PRODUCT FEES

Product fees and other charges are being provided for general information purposes only and are subject to change. To obtain a more detailed and accurate strategy for your personal situation, we recommend you consult your prospectus or consult with a Robo Advisor™ qualified financial professional.

CALCULATOR DATA

If this Site contains an online calculator, the online calculator may contain data regarding retirement investing. Such information is provided for educational purposes only and does not constitute an endorsement or recommendation of any security or investment program or service or the suitability thereof for you. The Company does not offer legal or tax advice, and the information provided in the online calculators should not be used in lieu thereof. Please consult your tax or financial advisor for guidance regarding your particular situation.

WE ARE NOT PROVIDING INVESTMENT ADVICE, SOLICITING OFFERS OR SELLING

The information contained on this Site does not constitute investment advice, and is not an offer to sell or a solicitation to buy any security or any insurance product. All insurance and/or securities transactions require signed agreements between The Company and its customers, and the terms of those agreements are binding on the parties. No other representation, whether made in person, online, electronically, in written, graphical, or verbal communication, may alter the terms of those agreements except that your use of this Site constitutes your agreement to the additional Terms and Conditions of Use applicable to such use. By using this Site, you accept at your own risk that the Internet and online communications medium may not perform as intended. No security or other insurance product is offered or will be sold in any jurisdiction in which such offer or sale would be unlawful under the securities, insurance, or other laws of such jurisdiction. Some products may not be available in all jurisdictions. In addition, any prospectus information available on this Site is posted for informational purposes only and is not a recommendation or opinion for you to buy or sell any product or participate in any transaction.

This Site is controlled by us from our offices within the United States. Except as specifically stated, we make no representation that Content in this Site is appropriate or available for use in other jurisdictions. Access to this Site's Content from jurisdictions where such access is illegal is prohibited. If you choose to access this Site from other jurisdictions, you do so at your own risk. You are always responsible for your compliance with applicable laws. You may not use or export the materials in this Site in violation of U.S. export laws and regulations. The Company and its parents, affiliates and subsidiaries are not authorized to do business in every jurisdiction. By downloading any Content, you are agreeing that you are not in a country where such export is prohibited and that you are not a person or entity to which such export is prohibited. You are responsible for compliance with the laws of your local jurisdiction regarding the import, export, or re-export of any Content. Information published on this Site may contain references or cross-references to products, programs or services that are not available in your state or country. The products referred to on this Site may be offered and sold only to persons in the United States and its territories. Consult your Robo Advisor™ qualified financial professional for information regarding the products, programs and services which may be available to you.

YOU SHOULD NOT RELY ON THE STOCK PRICE INFORMATION ON THIS WEB SITE

We do not generate the information regarding stock prices for this Site. We believe that the information on this Site is accurate, but we cannot guarantee or warrant the accuracy, completeness, or timeliness of the information. You should not rely on the stock price information for investment purposes. We are not liable for any loss or damages, whether direct, indirect, incidental, special, consequential, or exemplary, that may arise from reliance on the stock price information on this Site.

NO REPRESENTATION AS TO SUITABILITY

The Company makes no representation as to the financial or other suitability of any product described on this Site for any user. In order to evaluate whether a particular product is suitable for your financial needs, you should contact a Robo Advisor™ qualified financial professional. The posting of any prospectus or any other information on this Site should not be interpreted as a recommendation or opinion that you should make any purchase or sale or participate in any transaction.

VIOLATIONS OF RULES AND REGULATIONS

The Company reserves the right to seek any remedy available at law or in equity for any violation of these Terms and Conditions of Use, including the right to block access from a particular Internet address to this Site.

PERSONAL INFORMATION

Depending on your level of access to this Site, you may receive or obtain access to Personal Information as defined below. Your access and use of such information is governed by state and federal law and limited to specific business activities for which you are authorized. Should you access Personal Information intentionally or unintentionally of others for who you are not authorized, you will immediately notify us and you will not copy, download, store or transmit such information to any third party.

SECURITY

Access Codes (User names and passwords) used for this Site are for individual use only. You will be responsible for the security of your Access Codes. The Company will be entitled to monitor your Access Codes and, at its discretion, require you to change it. If you use Access Codes that The Company considers insecure, The Company will be entitled to require the password to be changed and/or terminate your account.

You are prohibited from using any services or facilities provided in connection with this Site to compromise security or tamper with system resources and/or accounts. The use or distribution of tools designed for compromising security (e.g., password guessing programs, cracking tools or network probing tools) is strictly prohibited. If you become involved in any violation of system security, The Company reserves the right to release your details to system administrators at other sites in order to assist them in resolving security incidents and to federal or state law enforcement officials. The Company reserves the right to investigate suspected violations of these Terms and Conditions of Use.

You agree that The Company shall not be responsible for damages or losses resulting from any breach of security caused by your failure to maintain the confidentiality of your Access Codes. If you permit access to your Access Codes by third parties, then you agree to defend, indemnify and hold The Company harmless from and against any liability, losses, damages, or costs and expenses (including attorneys' fees) arising out of, related to or resulting from, such access and related use of this Site. The Company reserves the right to block access to this Site for any reason. You also agree to immediately notify The Company if you:

• Become aware of any loss or theft of your Access Codes, or
• Become aware of any unauthorized use of your Access Codes.

Finally you acknowledge and agree that you will not: (i) collect or store personal data about other users of this Site, or (ii) upload, Email, or otherwise transmit any material that contains viruses or any other computer code, files, or programs that might interrupt, limit, or interfere with the functionality of any computer software, hardware, database or file, or communications equipment that is owned, leased, or used by The Company.

For your protection, The Company may require the use of encryption technologies for certain types of communications conducted through this Site. This Site has adopted industry standard security measures to protect the loss, misuse, and alteration of the information under our control. While we provide those technologies and use other reasonable precautions to protect confidential information and provide suitable security, we do not guarantee or warrant that information transmitted through the Internet is secure, or that such transmissions will be free from delay, interruption, interception, or error. While there is no such thing as "perfect security" on the Internet, we will take reasonable steps to insure the safety of your personal information. There is always the possibility of unknowingly acquiring computer viruses on the Internet and thus we want to warn you about infections or viral contamination on your system. It is your responsibility to scan any and all downloaded materials received from the Internet. The Company is not responsible or liable for any damage caused by viruses or related hazards, whether or not that virus or hazard resulted from a visit to this Site. You, and not The Company assume the entire cost of all necessary servicing, repair, or correction related to computer viruses.

The Company reserves the right to fully cooperate with any law enforcement authorities, regulatory authorities, or court order requesting or directing them to disclose the identity of anyone posting any Email messages, or publishing or otherwise making available any materials that are believed to violate these Terms and Conditions of Use. BY ACCEPTING THESE TERMS YOU WAIVE AND HOLD HARMLESS THE COMPANY FROM ANY CLAIMS RESULTING FROM ANY ACTION TAKEN BY THE COMPANY DURING OR AS A RESULT OF ITS INVESTIGATIONS AND/OR FROM ANY ACTIONS TAKEN AS A CONSEQUENCE OF INVESTIGATIONS BY EITHER THE COMPANY OR LAW ENFORCEMENT AUTHORITIES.

E-MAIL

The Company recognizes that Email can be the preferred mode of communication for some of its customers. Either at the time of a policy purchase, during your registration on this Site or your election to participate in electronic document delivery or to transact business electronically with The Company, you provided your Email address to The Company. The Company may use, and you hereby permit The Company to use, this Email address for the following:

• Service notifications related to your account(s) or policy(ies);
• Regularly scheduled Email newsletters;
• Products or services you have purchased;
• Optional Email communications which you have signed up for (e.g., newsletters on a selected topic);
• Occasional updates about products and services as well as marketing offers.

Also, once you have requested information from The Company via Email, The Company may communicate with you via Email regarding your request to provide additional information related to your initial information request. However, The Company will never ask you to send personal information such as account or Social Security numbers by non-secure Email. The Company may require certain Email communications to be conducted through secure or encrypted Email. If The Company sends you an advertisement via Email, it will include instructions on how to opt-out of receiving such Email advertisements in the future. If you elect to opt-out of receiving Email advertisements, The Company will continue to send you non-advertisement Email's as stated above. It is your responsibility to maintain accurate records with The Company and to update your Email address if it changes.

Additionally, certain portions of this Site may offer you the ability to Email a message to The Company even if you have not elected to participate in electronic document delivery or to transact business electronically with The Company. Email functionality, if any, is provided to you to facilitate communications between you and The Company. You agree, however, that you will not use Email to request, authorize, or affect the purchase or sale of any securities or other product or service, to change your address or other account information, to change your User Codes, to transmit personal credit information (including credit card numbers), to send fund transfer instructions, or for any other financial transactions that require formal authorization in accordance with applicable law or The Company's policies and procedures. Any such requests, orders, or instructions that you send to The Company by Email will not be accepted or processed by The Company. The Company shall have no liability for any loss or damage that arises from unaccepted Email requests, orders, or instructions. Moreover, The Company shall have no liability for any loss or damage that result from interception and/or unauthorized use by third parties of any information you send by Email.

ELECTRONIC TRANSACTIONS

In the event this Site permits you to view, change information and make investment or sub-account exchanges on your account and receive other information or services related to an investment, contract or policy purchased through The Company through electronic transmission via a compatible personal computer and a secure web browser, access to such services requires an electronic identification that consists of a user name, password, or other security measures that we may require. By obtaining Access Codes, you agree that the use of this electronic identification is the legal equivalent to your written signed instructions to The Company and that your identity as an authorized user of our on-line services is determined solely by your Access Codes. You acknowledge that you are responsible for the safekeeping of your Access Codes and The Company is unable, and under no obligation, to confirm the identity or authority of any user of our on-line services.

CHILDREN

This Site does not intend to market any products or services to children under thirteen (13) years of age. The Company does not knowingly gather or solicit data from children under thirteen (13) years of age through this Site for marketing purposes. By using this Site you represent that you are not under thirteen (13) years of age.

RECOMMENDED BROWSER

For optimal performance, please use the latest version of either Internet Explorer, Edge, Mozilla Firefox, Apple Safari or Google Chrome when connecting to this Site.

MISCELLANEOUS

These Terms and Conditions of Use will be governed and interpreted pursuant to the laws of the state of Florida, United States of America, notwithstanding any principles of conflicts of law. You specifically consent to personal jurisdiction in Florida in connection with any dispute between you and The Company arising out of these Terms and Conditions of Use pertaining to this Site. The parties to these Terms and Conditions of Use each agree that the exclusive venue for any dispute between the parties arising out of these Terms and Conditions of Use or pertaining to the subject matter of these Terms and Conditions of Use will be in the state or federal courts having jurisdiction within Orlando, Florida. If any part of these Terms and Conditions of Use is unlawful, void or unenforceable, that part will be deemed severable and will not affect the validity and enforceability of any remaining provisions. These Terms and Conditions of Use constitute the entire agreement among the parties relating to this subject matter. Notwithstanding the foregoing, any additional terms and conditions on this Site will govern the items to which they pertain. The Company may revise these Terms and Conditions of Use at any time by updating this posting. These Terms and Conditions of Use constitutes the entire agreement between The Company and you with respect to your use of this Site. Any cause of action you may have with respect to your use of this Site must commence within one (1) year after the claim or cause of action arises.

NOTE: I consent to initiate the process of receiving documents and notices applicable to the Eligible Policy/Policies accessed through the Company website. These include, but are not limited to, prospectuses, prospectus supplements, annual and semiannual reports, quarterly statements and immediate confirmations, privacy notice and other notices and documentation in electronic format when available instead of receiving paper copies of these documents by U.S. mail. I consent to receive in electronic format any documents added in the future.

IMPORTANT INFORMATION CONCERNING ELECTRONIC DOCUMENT DELIVERY:

• There is no charge for electronic delivery, although your internet provider may charge for Internet access.
• You are confirming that you have access to a computer with internet capabilities and an active email account to receive information electronically.
• This Electronic Document Delivery applies only to Eligible Policies accessed through the following websites: roboadvisor.com , my.roboadvisor.com and advisor.roboadvisor.com as well as all location based domains marketed under the Robo Advisor Network™ subscription program.
• After subscribing to Electronic Document Delivery, we will send an email to confirm the provided email address is correct. If we are not able to confirm an email address or have reasonable suspicion that an email address is incorrect, we will not be able to activate the subscription for electronic delivery, in which case paper copy documents will be sent.
• Email filters must be updated which may prevent you from receiving email notifications from us.
• Not all contract documentation and notifications may currently be available in electronic format.
• Paper copies of the information may be requested at any time for no charge.
• For jointly owned policies both owners are consenting to have information sent to the specified email address.
• If the email address changes after the subscription process, notification must be sent to us.
• This consent will remain in effect until revoked.

Please call (407) 474-5600 or visit the Company website if you would like to revoke your consent, wish to receive a paper copy of the information above, or need to update your email address.

IMPORTANT: INSURANCE AND ANNUITY PRODUCTS ARE:

• NOT A DEPOSIT
• MAY LOSE VALUE
• NOT FDIC/NCUA/NCUSIF INSURED
• NOT BANK/CREDIT UNION GUARANTEED
• NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY

1. DISTRIBUTION

Insurance and Annuity products are made available in an environment where consumers and entities can shop and compare in a best efforts attempt to create value through choices. All Insurance and Annuity products are distributed through a licensed insurance agent, insurance agency, Robo Advisor Network™ member or any affiliates of those entities. For more detailed information, please visit our insurance & annuities licensing section.

2. DISCLAIMER

An annuity is a long-term contract designed for savings and retirement purposes, wealth distribution and wealth transference and not suitable for meeting short-term financial objectives. Annuity Benefits, features and optional riders which are available for an additional fee, may vary, are subject to state regulation and subject to change without notice. Please consult one of our financial professionals for complete details and/or refer to the contract for a complete and detailed explanation of benefits, limitations and restrictions.

Income Annuities (including immediate, longevity & qlac):

• Taxable income examples assume the account type is non-qualified: The non-taxable portion (Tax Exclusion Ratio) of an income payment amount is based upon the cost basis provided (or, if none is provided, the purchase payment will be treated as the after-tax cost basis), and is limited to that basis. The non-taxable portion of income payment amount is the amount of each income payment that is excludable from income taxation. Once the cost basis has been recovered, the non-taxable portion of income payment amount is zero and any additional amount paid out will be fully taxable as ordinary income. Because the non-taxable portion of income payment amount is calculated using the cost basis indicated above, the non-taxable portion of income payment amount may be more or less than illustrated if the cost basis indicated above is incorrect. Additionally, if you make additional purchase payments, the cost basis will differ from what is indicated above. *This taxable income explanation of the non-taxable portion (Tax Exclusion Ratio) of an annuity income payment amount is not intended to be tax advice. It is calculated using the Internal Revenue Code tables pursuant to IRC Sec. 72(b)(1). It is presented for your convenience and should not be considered specific tax advice. You should consult your own independent tax advisor regarding your specific legal or tax situation.
• Income payment amounts quoted are guaranteed until the quote expiration date shown provided that the application, illustration and funds are received in good order by the quote expiration date. Subject to each company’s specific rules, if this is a 1035 Exchange or transfer request, then the application, illustration, transfer request paperwork and any other required state forms generally must be received in good order by the Illustration expiration date and funds must be received within 60 calendar days of the Illustration prepared date.
• Annuity quotes do not constitute a contract and are subject to change. All quotes are based on the rates set by each individual insurance company on the date the quote was provided, age and gender of annuitant(s), purchase payment amount, the annuity payout option you choose, payment frequency, issue date of the contract, payment start date you select, state of residence and various other factors. Any variations in the information listed in the quote provided may change the premium amount or income payments higher or lower than what is illustrated.
• Annual payout rates are a percentage of the purchase price paid out each full year and includes both interest and return of principal. It is not an interest rate.
• Guaranteed payment figures represent the minimum amount of income you or your beneficiaries will receive from an annuity based upont the payment type, guarantee type and continuation options selected.
• Payments to 100 amounts assume at least one annuitant of the contract is living through age 100.
• Distributions under a QLAC must begin no later than the first day of the month following the owner reaching age 85.
• The QLAC limit effective January 1, 2022 is the lesser of $145,000.00 or 25% of the total retirement account balances for each owner.

Fixed Annuities:

• Fixed Annuity interest rates are provided as effective annual yields (EAY); this is the yield that results after interest has compounded for a full year.
• Fixed Annuity multi-year guarantee periods may not be available at all times and in all states.

Indexed Annuities:

• Individuals who purchase indexed annuities are not directly investing in a stock market index.
• Indexed annuities are not stock market investments and do not directly participate in any stock or equity investments.
• Market indices may not include dividends paid on the underlying stocks, and therefore may not reflect the total return of the underlying stocks.
• Insurance Companies that issue Indexed Annuities protect you from losing any money in your annuity due to market losses - even during economic downturns. During this time, you may have no interest credited to your contract.
• In exchange for the protection described above, indexed crediting strategies limit the interest rate you can receive from the underlying index performance. The limit can take the form of a Cap Rate, an Annual Spread or a Participation Rate.
• Withdrawals from Indexed Annuities are typically not credited with index interest in the year they are taken.

Variable Annuities (including indexed linked annuities):

• Variable annuities are long-term contracts designed for retirement purposes, and are subject to investment risk, including the possible loss of principal.
• Variable annuities are sold only by prospectus. Please read the prospectus carefully before investing.
• Past performance of any investment is not indicative of future results.

3. GUARANTEES DISCLOSURE

All representations and contract guarantees, including the death benefit, rider guarantees, including optional benefits and any fixed crediting rates or annuity payout rates, are backed by the financial strength and claims-paying ability of the issuing insurance company. They are not backed by the broker/dealer from which an annuity is purchased, by the insurance agency from which an annuity is purchased or any affiliates of those entities and none makes any representation or guarantees regarding the claims-paying ability of the issuing insurer.

4. SURRENDER CHARGE DISCLOSURE

If you keep an annuity only a few years, contract values may be less than the total contributions due to surrender charges. Charges may apply to amounts taken in excess of the free withdrawal amount available during the surrender charge period. All withdrawals may reduce the benefits, features and optional riders (including death benefits) and will reduce the contract value on a dollar-for-dollar basis. Before surrendering or exchanging an annuity, check with your current provider to see if it will assess a surrender charge. Also, consider the existing benefits and features you may lose in an exchange/surrender, which may be of particular importance if poor market conditions exist.

5. PERFORMANCE DISCLOSURE

Any illustrations of future values used in this website or within a sales presentation are provided only for illustrative purposes. Any such illustration must not be regarded as guaranteed or as estimated future performance unless it is based solely on the minimum guaranteed interest rates and assume no withdrawals taken. Past performance is not a guarantee of future results.

6. MARKET VALUE ADJUSTMENT (MVA)

The MVA is a key design feature that helps optimize the growth potential of the contract over the long term. The presence of an MVA helps protect the insurance company and thus allows for optimized crediting rates. If you withdraw funds in excess of your free surrender amount before the end of your guaranteed period, the amount you requested will be adjusted based on interest rate conditions at that time. This is referred to as a market value adjustment (MVA). If interest rates are lower than when you bought your annuity, the MVA could increase the amount you requested. However, if interest rates are higher, the MVA could decrease the amount you requested. The MVA applies if you take more than the free annual withdrawal amount each year or if you surrender the contract before the end of the guaranteed period. The Treasury Constant Maturity Series reported by the Federal Reserve is typically used by most companies to measure rates.

7. ANNUITY TAXATION DISCLOSURE

Annuity withdrawals and other distributions of taxable amounts, including death benefit payouts, will be subject to ordinary income tax. For non-qualified contracts, an additional 3.8% federal tax may apply on net investment income. If withdrawals and other distributions are taken prior to age 59½, an additional 10% federal tax may apply. There are no additional tax benefits when an annuity is purchased as an IRA or other tax-qualified plan, since those plans already provide tax-deferred status. Annuities should be purchased as a qualified plan for the value of unique features, benefits and riders other than tax deferral.

8. RATINGS DISCLOSURE

Financial strength and claims paying ability is a consideration in choosing a life insurance company. After all, you want the life insurance company you select to be there when it is time to pay benefits. Financial strength and claims paying ability are rated by independent rating agencies such as A.M. Best, Standard & Poor’s, Moody's and Fitch.

9. PROSPECTUS OFFERING AND DISCLOSURE

Contact your financial advisor or call (407) 474-5600 for more information, including product and fund prospectuses that contain complete details on investment objectives, risks, fees, charges, and expenses as well as other information about the investment company, which should be carefully considered. Please read the prospectuses carefully prior to purchasing. The prospectuses contain this and other information on the product and the underlying portfolios.

1. LICENSING & DISTRIBUTION

Insurance and annuities available at Robo Advisor™ are issued by third-party insurance companies, which are not affiliated with any Robo Advisor™ company. Our agents and/or representatives may only conduct business (e.g., sell securities, provide investment advice, sell insurance and annuities) with residents of the states and/or jurisdictions for which they are properly registered and/or licensed. To find out if a representative is able to conduct business in your state, please contact their local office directly.

2. LEGAL JURISDICTIONS ONLY

The insurance and Annuity services and products described on this Web Site are only for persons in those states and jurisdictions where such products and services may legally be sold. Nothing on this Web Site shall be considered a solicitation to buy or an offer to sell any products or services to any person in any jurisdiction where such offer, solicitation, purchase or sale would be unlawful.

3. USE LIMITATION

This Web Site is for the use of consumers and small businesses that are researching and shopping for Insurance and Annuity products. You are not permitted to use this Web Site or its contents for any commercial or non-personal purpose (direct or indirect). The Company reserves the right to prevent any party who engages in such non-permitted use(s) from accessing this Web Site.

4. EXISTING INSURANCE COVERAGE

DO NOT CANCEL ANY EXISTING INSURANCE OR ANNUITY UNTIL YOU RECEIVE WRITTEN CONFIRMATION FROM THE INSURANCE COMPANY TO WHICH YOU ARE APPLYING THAT YOUR NEW POLICY IS IN EFFECT.

5. AGENCY & INDIVIDUAL LICENSING

This Web Site is brought to you by the following licensed brokers in each respective state which require insurance transactions to be conducted through a licensed agent/broker. Each agent/broker is associated with Sovereign Wealth Management Group, Inc. where applicable, a Florida corporation and licensed insurance agency.

NOTE: This website notice will be updated from time to time to reflect any material revisions, so please check back often to review the statement.

Protecting your privacy is very important to us. We want you to understand what information we collect and how we use it. We collect and use personally identifiable information in order to provide our customers with a broad range of financial products and services as effectively and conveniently as possible.

This privacy statement applies to this website only and does not apply to any linked site or information received or collected by any other means. To learn about the privacy policy of a linked site, please refer to that site's privacy statement.

THE ROBO ADVISOR™ AFFILIATE COMPANIES TO WHICH THIS PRIVACY STATEMENT APPLIES:

• Robo Advisor Technologies™
• Robo Advisor, Inc.
• Sovereign Wealth Management Group, Inc.

SHARING INFORMATION WITHIN OUR CORPORATE FAMILY

Our clients benefit from information shared within our Robo Advisor™ corporate family. "Our affiliates" are companies with which we share common ownership or control and which offer insurance, pension, savings or investment or consumer products. It is important that we have the ability to share this information to provide the quality products and services associated with entrusting your financial business with us.

WHAT INFORMATION WE COLLECT AND FROM WHOM WE COLLECT IT

We collect only the information that is required to provide you with the highest quality professional services or that is required by law and regulation. We maintain strict security procedures to protect the information that we collect. We may collect personally identifiable information about you from the following sources:

• Information you make available to us via social networking logins, such as Facebook or Twitter;
• Information from when you participate in chats, web meetings, web forums or other interactive sessions;
• Information you make available when you purchase or request a quote for an insurance, annuity or investment product or other service;
• Information from when you subscribe to newsletters or provide feedback;
• Information such as your name, social security number, address, telephone number, email address, date of birth, policy, contract or account numbers and, where reasonably required to complete the request or transaction other information which are received from you via applications or other forms submitted to us;
• Information about your financial or service transactions with us, our affiliates, or others;
• Information we receive from non-affiliated third parties, including consumer reporting agencies;
• Information we derive from your access to and use of this web site through software information collecting tools like a cookie, pixel tags, web bug or web beacon or otherwise, such as your Internet browser, domain name and referring link; ( Note: It is possible to browse our site without providing us any personal information. You can also set your browser security settings to reject cookies, however in doing so you may not be able to take full advantage of the site's functionality.) For more about cookies,
• Information you provide voluntarily when registering for account access through our web site, such as confirming your policy number, social security number and providing your e-mail address and telephone number; and
• Information provided by you to initiate an online policy transaction or contained in an e-mail message sent to us.

If you do not want to provide this information to us via the Internet, please contact us at (407) 474-5600 or ask your financial advisor to assist you.

WHAT INFORMATION WE DISCLOSE AND TO WHOM WE DISCLOSE IT

We do not disclose any personally identifiable information about you to either our "affiliates" or non-affiliate vendors without your express consent, except as permitted by law. We may disclose the nonpublic personal information (as noted above) we collect to persons or companies that perform services on our behalf, that provide services to you, to financial institutions with which we have joint marketing agreements, and as required by law (for example regulators, law enforcement agencies).

Any information that we provide non-affiliated vendors is restricted as to content and recipient. Any organization that receives such information must provide us with a copy of its privacy policy, and each policy will be reviewed to ensure that it is sufficient to meet Robo Advisor’s client information privacy standards. Under no circumstances whatsoever will Robo Advisor™ sell information about you or your business to any vendor, public or private.

OUR SECURITY PROCEDURES AND CONFIDENTIALITY

We restrict access to your nonpublic personal information to those who have a legitimate need to know and only allow disclosures to persons and companies as permitted by law to assist in providing products and/or professional services to you. We maintain physical, electronic, and procedural safeguards in accordance with federal law and regulatory standards to protect your nonpublic personal information.

Any employee who has access to individual information receives training about and is required to follow company procedures designed specifically to keep that information confidential. These procedures are also designed to ensure that your financial information is accurate, current and complete. Please notify us if at any time our records contain incomplete or inaccurate information about you. Upon notification from you regarding our records, we will promptly address your concerns and make any necessary correction.

GOING FORWARD

Protecting your privacy is an on-going process. As technology continues to advance, Robo Advisor™ will continue to evaluate its security standards and procedures associated with protecting your privacy. Nothing is more important to us than our clients’ trust and confidence, and we will take whatever steps necessary to maintain the security of our professional relationships. Our policies and procedures for the disclosure of information, stated above apply to both current and former customers of Robo Advisor™.

PRIVACY NOTICE AVAILABLE TO CUSTOMERS

Customers receive copies of our Privacy Notice as required by law or upon any material revision in our privacy practices. For a copy of our Privacy Notice you may click here.

SITE SECURITY

For more information about security for this site or to contact us with any questions, comments or concerns by sending an email to compliance.