Connecticut Social Security Number Privacy Protection Policy

Hooker & Holcombe, Inc. and its subsidiaries, Hooker & Holcombe Retirement Services, Inc. and Hooker & Holcombe Investment Advisors, Inc., are committed to maintaining the confidentiality of the Social Security numbers we collect during the regular course of business. Accordingly, we have established this policy to safeguard and restrict access, disclosure and use of the Social Security numbers we have collected. The purpose of this policy is to comply with applicable law protecting the confidentiality of Social Security numbers, including but not limited to Connecticut General Statutes § 42-471(b).

Collection of Social Security Numbers

We collect the Social Security numbers of employees, plan participants and certain other individuals only for legitimate business purposes.

Access to Social Security Numbers

We restrict access to the Social Security numbers we collect to only our employees and certain third parties who are authorized to access this information. Authorized employees are those who we have determined have a legitimate business need to access this information. Authorized third parties are those who have a legitimate need to access this information and owe a duty to maintain its confidentiality.

Use and Disclosure of Social Security Numbers

We prohibit the disclosure and use of Social Security numbers unless such disclosure and use complies with this policy and with applicable law. Social Security numbers shall not be displayed on identification cards or badges, bulletin boards, or any similar materials that are publicly displayed. Documents, materials or computer screens that display Social Security numbers shall be shown only to authorized employees and third parties and shall be kept out of public view at all times.

Safeguarding Social Security Numbers

We safeguard the confidentiality of the Social Security numbers we collect in accordance with our internal procedures governing the protection of confidential and personal information. Such procedures address the physical, technical and administrative safeguards we have adopted and implemented to protect Social Security numbers and other confidential and personal information.