Privacy Promise

 
Effective Date: Last modified on February 1, 2010 



This ABA Retirement Funds Program (the “Program”) is committed to protecting the privacy and confidentiality of your personal information.  The Program is sponsored by the ABA Retirement Funds (“ABA RF”), and administrative services, including this website, are provided by ING Institutional Plan Services, LLC (“ING”).  This Privacy Promise represents the commitments of the Program and ING, and governs your use of this website.


As a provider of products and services that involve obtaining and using personal and financial information, protecting the confidentiality of that information has been, and will continue to be, a top priority of the Program and ING.

Whether you are a current customer, former customer, or potential customer, the Program and ING  believe that you should know about the information collected, the measures taken to safeguard it, and the limited circumstances in which your information may be shared.


1. We collect only the customer information necessary to consistently deliver responsive products and services.

The Program collects information that helps serve your financial needs; provide high levels of customer service; develop and offer new products or services for our customers and potential customers; and fulfill legal and regulatory requirements.

The information collected may include:

• Information provided on applications and related forms—for example, name, age, address, Social Security number, birthday, account information and beneficiaries.
• Responses from your employer, benefit plan administrator, or association regarding any group products we may provide—for example, name, age, address, Social Security number, and annual income.
• Information about your relationship with us, such as products or services purchased, and account balances, including financial objectives.

Our website is not directed toward children. We do not knowingly collect information from children under the age of 13. You can learn more about children's privacy and the Children's Online Privacy Protection Act (COPPA) at the Federal Trade Commission's website.

2. We maintain safeguards to protect privacy and information security.


We have implemented security standards and processes—including physical, electronic and procedural safeguards. While no organization can guarantee data security, it is always our practice and goal to protect the confidentiality of customer information, and we do not disclose Social Security numbers unless required or permitted by law. We also limit access to customer information to employees, registered representatives or agents who may need it to do their job. These individuals are trained to respect the confidentiality of your personal information and understand their duty to safeguard it.


3. We restrict the sharing of customer information with anyone – even our affiliates – for use in marketing.


First and foremost, we do not sell or share customer information with outside parties who want to market their products to you.


As a provider of a wide variety of financial products and services, we may identify opportunities to enhance customer service or to offer you additional products and services.


However, we will not share personal information with third-party financial services entities, such as banks, credit unions, credit union service corporations, insurance companies, or securities broker dealers, for purposes of joint marketing, unless you direct us to, or unless we notify you first and give you a chance to say no.


4. We share customer information as necessary for business, regulatory, and servicing purposes.

We will share customer information to facilitate or service a transaction, product or service you have requested, but only in accordance with applicable law.

We may share or exchange information with companies engaged to work with us, such as third-party administrators and vendors hired to effect, administer or enforce a transaction, product or service that you request or authorize; to develop or maintain software; to perform marketing research; or to provide us with demographic information to develop marketing plans. We require these companies to maintain the confidentiality of customer information and use it only for the purpose for which it was provided.


We may also share customer information in accordance with, or as required by, law or regulation (for example, in response to a subpoena or other legal process, to prevent fraud, and to comply with rules of, or inquiries from, industry regulators).


In addition, the agent or registered representative with whom you work to obtain the Program’s financial products and services may use the personal information about you in his or her own files to advise you of other products or to help you with your overall financial strategy.


We will reaffirm this policy annually in writing, as long as you maintain an ongoing relationship with the Program. We reserve the right to revise this policy from time to time.  We strongly encourage you to review our current policy online frequently at abaretirement.com.


In this notice, the words "you" and "customer" are used to mean any individual who obtains or has obtained a financial product or service from the Program that is to be used primarily for personal, family, or household purposes.

You should also be aware that other companies that provide services to the Program, including ING (http://www.ing-usa.com/us/ingsprivacypromise/index.htm), and The Northern Trust Company (http://www.northerntrust.com/pws/jsp/display2.jsp?XML=pages/nt/0602/1141167162990_56.xml), and have their own privacy policies and practices which you should review by clicking on the above links or visiting their respective sites.