PRIVACY POLICY

Last Updated: 06-04-2025

INTRODUCTION

Opus Investment Management Inc., a leading financial services firm, is unequivocally dedicated to maintaining the confidentiality, integrity, and security of sensitive information pertaining to its esteemed clients, valued investors, trusted affiliates, and website users. This comprehensive Privacy Policy serves as a transparent disclosure of Opus's information handling practices, delineating the manner in which we collect, process, utilize, disclose, and safeguard personal information.
In recognition of the sacred trust placed in us by our stakeholders, Opus is committed to upholding the highest standards of data protection, aligning our policies and procedures with pertinent regulatory requirements and industry best practices. This Privacy Policy provides an exhaustive overview of our information management framework, ensuring that all individuals whose personal information is entrusted to Opus are informed of their rights and our responsibilities in handling their sensitive data.

SCOPE

The scope of this comprehensive Privacy Policy encompasses the following entities and platforms within the Opus Investment Management Inc. ecosystem:

1. Investment Management Services: This Privacy Policy applies to all investment management services offered by Opus, including but not limited to, portfolio management, investment advisory, and financial planning services provided to individual and institutional clients.
2. Affiliate Partnership Program: This Privacy Policy also governs the collection, use, and disclosure of personal information within the context of Opus's Affiliate Partnership Program, which facilitates collaborative relationships with trusted partners and referral sources.
3. Official Website (opusinvestmentmgmt.com): Furthermore, this Privacy Policy extends to the Opus website, including all web pages, subdomains, and microsites, which provide information on Opus's services, news, and industry insights.

Collectively, these entities and platforms are referred to herein as the "Opus Services." By accessing or utilizing any of the Opus Services, individuals acknowledge and consent to the terms and conditions outlined in this Privacy Policy.

DEFINITIONS AND CLASSIFICATIONS OF INFORMATION

For the purposes of this Privacy Policy, Opus Investment Management Inc. adopts the following definitions and classifications of information:

1. Personal Information

"Personal Information" refers to any information, whether recorded electronically or in physical form, that:

• Identifies an individual directly, such as name, address, phone number, or email address;
• Can be used, alone or in combination with other information, to identify an individual indirectly, such as social security number, driver's license number, or passport number;
• Relates to an individual's financial situation, investment activities, or other personal characteristics;
• Can be linked to an individual, such as cookies, device identifiers, or geolocation data.
2. Non-Personal Information

Non-Personal Information refers to any information that:

• Does not identify an individual directly or indirectly;
• Is anonymous or aggregated, making it impossible to link to an individual;
• Relates to the usage, performance, or functionality of Opus's services or website.

By distinguishing between Personal Information and Non-Personal Information, Opus aims to ensure transparency and accountability in its information handling practices.
Please note that these definitions align with applicable data protection regulations and industry standards.

INFORMATION COLLECTION AND CLASSIFICATION

Opus Investment Management Inc. collects and processes various types of information from its clients, investors, affiliates, and website users. For the purposes of this Privacy Policy, collected information is categorized into two primary classes: Personal Information and Non-Personal Information.

PERSONAL INFORMATION

Opus collects and processes the following Personal Information:

1. Contact Information: This includes, but is not limited to, an individual's name, email address, phone number, physical address, and other contact details.
2. Identification Documents: Opus may collect and verify identification documents, such as passports, driver's licenses, social security numbers, or other government-issued IDs, for purposes of client onboarding, identity verification, and regulatory compliance.
3. Financial Information: This encompasses information related to an individual's or institution's financial situation, including investment accounts, transaction history, account balances, and other financial data.
4. Investment Objectives and Risk Tolerance: Opus collects information regarding an individual's or institution's investment goals, risk tolerance, and preferences to provide tailored investment advice and management services.
5. Communication Records: Opus maintains records of communications with clients, investors, affiliates, and website users, including emails, phone calls, meetings, and other interactions.

NON-PERSONAL INFORMATION

1. Website Usage Data: This includes information related to website traffic, such as IP addresses, browser types, pages visited, and other analytics data.
2. Device Information: Opus collects data regarding devices used to access its website or services, including operating systems, screen resolutions, and other device-specific information.
3. Location Data: Opus may collect location data, such as city, state, or country, to provide localized services, tailor marketing efforts, and comply with regulatory requirements.

By collecting and processing both Personal and Non-Personal Information, Opus aims to provide exceptional investment management services, enhance user experience, and maintain regulatory compliance.

INFORMATION UTILIZATION AND PURPOSES

Opus Investment Management Inc. utilizes the collected information for the following legitimate business purposes:

1. Investment Management Services
Opus employs collected information to provide tailored investment management services, including:
• Portfolio management and advisory
• Financial planning and analysis
• Investment research and recommendations
• Client account administration and maintenance
2. Affiliate Partnership Management
Collected information facilitates the management of affiliate partnerships, enabling Opus to:
• Track referrals and commissions
• Monitor partnership performance
• Communicate with affiliates
• Optimize partnership strategies
3. Marketing and Promotional Initiatives
Opus uses collected information for marketing and promotional purposes, including:
• Personalized communication and outreach
• Targeted advertising and promotional campaigns
• Event invitations and notifications
• Newsletters and industry insights
4. Digital Platform Enhancement
Collected information informs the development and improvement of Opus's website and mobile applications, enabling:
• Enhanced user experience and interface design
• Optimized functionality and performance
• Integration of new features and technologies
• Data-driven decision making
5. Regulatory Compliance
Opus utilizes collected information to ensure compliance with applicable regulatory requirements, including:
• Anti-money laundering (AML) and know-your-customer (KYC) protocols
• Securities and Exchange Commission (SEC) regulations
• Financial Industry Regulatory Authority (FINRA) guidelines
• Other relevant laws and regulations
6. Risk Management and Fraud Prevention
Collected information supports Opus's risk management and fraud prevention efforts, enabling:
• Identification and mitigation of potential risks
• Detection and prevention of fraudulent activities
• Maintenance of information security and integrity
• Protection of client assets and interests
By utilizing collected information for these purposes, Opus aims to provide exceptional investment management services, foster strong affiliate partnerships, and maintain the highest standards of regulatory compliance and risk management.

INFORMATION DISCLOSURE AND SHARING

Opus Investment Management Inc. may disclose personal information to the following entities, as necessary, for legitimate business purposes:

1. Affiliates and Subsidiaries
Opus may share personal information with its affiliates and subsidiaries to facilitate business operations, provide integrated services, and ensure consistency in client experience.
2. Service Providers
Opus discloses personal information to select service providers, including: >
• Custodians: for safekeeping and reporting of client assets
• Brokers: for execution of investment transactions
• Administrators: for record-keeping and account maintenance
These service providers are contractually obligated to maintain confidentiality and adhere to applicable data protection standards.
3. Regulatory Bodies
Opus complies with regulatory requirements by disclosing personal information to:
• Financial Industry Regulatory Authority (FINRA)
• Securities and Exchange Commission (SEC)
• State insurance departments
• Other relevant regulatory agencies
as required by law or regulatory guidance.
By disclosing personal information to these entities, Opus aims to provide integrated services, maintain regulatory compliance, and protect client interests.

INFORMATION SECURITY AND PROTECTION POLICY

Opus Investment Management Inc. recognizes the critical importance of safeguarding personal information and has implemented a comprehensive information security program to protect sensitive data from unauthorized access, disclosure, alteration, or destruction.

SECURITY MEASURES

To ensure the confidentiality, integrity, and availability of personal information, Opus employs a multi-layered security framework incorporating reasonable physical, technical, and administrative measures, including:

1. Physical Security Measures
• Secure facilities and data centers
• Restricted access controls (biometric authentication, keycard systems)
• Surveillance systems (CCTV, motion detectors)
• Secure storage and disposal procedures
2. Technical Security Measures
• Firewalls and intrusion detection/prevention systems
• Encryption technologies (SSL/TLS, AES)
• Secure data transmission protocols (HTTPS, SFTP)
• Regular software updates and patch management
• Anti-virus and anti-malware protection
3. Administrative Security Measures
1. Information security policies and procedures
2. Employee training and awareness programs
3. Access control and authorization protocols
4. Incident response and breach notification plans
5. Regular security audits and risk assessments

PROTECTED INFORMATION

These security measures protect personal information from:

1. Unauthorized Access: Preventing unauthorized individuals or systems from accessing or viewing sensitive data.
2. Disclosure: Preventing unauthorized sharing or transmission of personal information.
3. Alteration: Preventing unauthorized modification or manipulation of personal information.
4. Destruction: Preventing intentional or unintentional deletion or destruction of personal information.

By implementing and maintaining these robust security measures, Opus demonstrates its commitment to protecting personal information and ensuring the trust and confidence of its clients, investors, affiliates, and website users.

DATA RETENTION AND DESTRUCTION POLICY

Opus Investment Management Inc. recognizes the importance of responsible data retention and destruction practices. To ensure compliance with regulatory requirements and maintain accurate records, Opus has established the following data retention policy:

RETENTION PERIODS

Opus retains personal information for the following durations:

1. Service-Related Retention: Opus retains personal information for as long as necessary to provide investment management services, support, and maintain client relationships.
2. Regulatory Compliance Retention: Opus complies with applicable regulatory requirements, retaining personal information for the minimum periods specified, including but not limited to:
• Seven (7) years for financial transaction records and related documents
• Five (5) years for tax-related documents
• Three (3) years for employee records
Other retention periods may apply based on specific regulatory or legal requirements.
3. Dispute Resolution and Claims Retention: Opus retains personal information as necessary to resolve disputes, defend against claims, or initiate legal proceedings.

DATA DESTRUCTION

Upon expiration of the applicable retention period, Opus will securely destroy or anonymize personal information

DESTRUCTION METHODS

Opus employs secure destruction methods, including:

• Electronic data: Secure deletion or encryption
• Physical documents: Shredding or secure disposal

By implementing this data retention and destruction policy, Opus demonstrates its commitment to responsible data management, regulatory compliance, and protection of personal information.

CLIENT RIGHTS AND PRIVACY PROTECTIONS

Opus Investment Management Inc. is committed to protecting clients' rights and ensuring transparency in its information handling practices. Clients have the following rights:

1. Right to Access and Review: Clients have the right to access and review their personal information maintained by Opus.
2. Right to Correction and Update: Clients have the right to correct or update their personal information to ensure accuracy and relevance.
3. Right to Deletion: Clients have the right to request deletion of their personal information, subject to applicable legal and regulatory requirements.
4. Right to Opt-Out of Marketing Communications: Clients have the right to opt-out of marketing communications, including emails, newsletters, and promotional materials.

COOKIE POLICY

Opus utilizes cookies to enhance user experience and website functionality:

1. Website Usage Analysis: Cookies enable Opus to analyze website traffic, usage patterns, and user behavior.
2. Personalized User Experience: Cookies facilitate personalized content, recommendations, and advertisements.
3. User Preference Tracking: Cookies track user preferences, enabling Opus to tailor services and communications.

THIRD-PARTY LINKS

Opus's website may contain links to third-party websites. Please note that:

• Opus is not responsible for the privacy practices, content, or security of these websites.
• Clients should review the privacy policies and terms of use for each third-party website.
• Opus encourages clients to exercise caution when sharing personal information with third-party websites.

By acknowledging these client rights and policies, Opus demonstrates its commitment to transparency, accountability, and client trust.

PRIVACY POLICY UPDATES AND AMENDMENTS

Opus Investment Management Inc. reserves the right to review, revise, and update this Privacy Policy periodically to ensure alignment with changing regulatory requirements, industry standards, and business practices.

NOTICE OF CHANGES

In the event of any modifications to this Privacy Policy, Opus will provide notice by:

• Posting the updated Privacy Policy on its website
• Specifying the effective date of the changes
• Notifying clients and users through email or other communication channels, as necessary

EFFECTIVE DATE OF CHANGES

PROTECTED INFORMATION

All changes to this Privacy Policy will become effective immediately upon posting, unless otherwise specified.

ACKNOWLEDGMENT AND ACCEPTANCE

By:

• Accessing or using Opus's website
• Engaging with Opus's services
• Providing personal information

Individuals acknowledge that they have read, understand, and agree to be bound by the terms and conditions of this Privacy Policy, as amended from time to time.

CONSENT TO PRIVACY PRACTICES

Continued use of Opus's services or website constitutes consent to the information handling practices outlined in this Privacy Policy.

REVIEW AND COMPLIANCE

Opus encourages individuals to regularly review this Privacy Policy to ensure familiarity with its information handling practices and any updates.
By acknowledging these terms, individuals demonstrate their understanding of Opus's commitment to protecting personal information and its ongoing efforts to maintain transparency and accountability.