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Privacy Notice

This Privacy Notice (“Notice”) sets out information about the types of personal information we collect as part of our business, how we process that information and who we disclose it to in relation to our services. It also explains any rights you may have in relation to that information.

Last Updated: October 28, 2025

About Us
This Notice covers the following entities: Great Gray Group, LLC, Great Gray Trust Company, LLC (together, “Great Gray®”), Retirement Plan Advisory Group, LLC (“RPAG®”) and any affiliates or subsidiaries that link to this Notice. References to “we” or “us” in this Notice mean the relevant group entity with which you are working. Where parts of this Notice relate solely to Great Gray® or RPAG®, we will specify which of them it applies to.

Types of Information We Collect
Personal information means any information about a person who is either identified or can be identified.

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Both Great Gray® and RPAG® process any personal information you provide to them via forms, surveys, applications, or other fields on our website(s) including name, postal or email addresses, telephone, fax or mobile numbers, and account numbers.
  • If you are a retirement advisor and have an account on the RPAG® platform, RPAG® also processes your user login details (first name, last name, email address, user authentication information) and information about how you use the platform.
  • Both Great Gray® and RPAG® may automatically collect certain personal information relating to your use of our websites, including your phone number, IP address (which may be used to determine approximate physical location), device model, identity of the carrier and the name and version of your operating system.

How We Use Your Information
We may use the information we collect through our websites for several purposes including:

  • to provide you with, renew, or modify products and services
  • to provide you with the information and documents you request and for other customer service purposes
  • to provide you with information about our services or required notices
  • to allow you to participate in digital surveys and other forms of market research
  • to deliver affiliate marketing communications or promotional materials that may be of interest to you, and to assist us in determining relevant advertising
  • to improve the services we provide and the usefulness of our websites
  • to customize your experience when using our websites
  • to comply with applicable laws
  • to perform research, and
  • to prevent and detect fraud, infringement, and other potential misuse

We also may anonymize, combine, or aggregate any of the information we collect through our websites or elsewhere for any of these purposes or for analysing usage statistics and trends.

Information We Disclose To Third Parties
If you provide us with personal information in connection with products or services that we provide to you primarily for personal, family or household use, we will not sell, license, transmit or disclose this information to other parties unless: (1) you expressly authorize us to do so, (2) it is needed to allow our service providers to provide services for us or to you (e.g., cloud / SaaS providers, IT managed services, and professional advisors), (3) it is needed to provide our products or services to you, (4) it is disclosed to entities that perform marketing services on our behalf or to other entities with whom we have joint marketing agreements, (5) it is connection with a merger, consolidation, acquisition, divestiture or other corporate restructuring of all or part of our business, or (6) it is otherwise required or permitted by law.

Retention of Personal Information
We will only retain personal information for as long it we reasonably require it, including for the purposes of satisfying any legal, regulatory, commercial, accounting, or reporting requirements.

To decide on the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Do Not Track
While, as described above, you may have the ability to control the use of cookies through your web browser, unless the browser settings block our data collection, we do not currently respond to “Do Not Track” signals or other mechanisms. The available settings vary greatly by browser; please refer to your Internet browser settings for more information. For more information about Do Not Track, please visit www.allaboutdnt.com.

Children’s Privacy
We recognize that protecting children’s identities and privacy online is important and that the responsibility to do so resides with both the business and the parents. We do not knowingly solicit data from children under the age of 13, and we do not knowingly market through our website to such children. We comply with the requirements of the Children’s Online Privacy Protect Act (COPPA) that are applicable to us.

Working with Other Companies
From time to time, we may establish a relationship with other companies and vendors to collect and analyse data and provide you with additional value and new products we may not offer ourselves. When permitted or required by law, we may share information with third parties for purposes including response to legal processes. In these circumstances, we will treat information you provide us in the same manner described in this Notice.

We offer access to other websites either using hyperlinks or through “co-branded” sites in which both we and the other company share the same URL, domain name or pages within a domain name on the Internet. In some cases, the other site will also collect information from you. This information may include, but is not limited to, name, address, and account numbers. Prior to providing any information to any third party, review their privacy notices to determine the extent to which they may disclose your information.

Making Sure Your Information is Accurate
It is important for us to have your most accurate and up-to-date contact information. If any of your contact information has changed, please contact us using the details below.

Security of Online Communications
We employ various measures to protect information you provide us online. We leverage multiple layers of security, including multi-factor authentication, password protection, encryption of data at rest and in motion, and backup and recovery. As always, we strongly encourage you to assist us in that effort by not sharing your User ID(s) or Passcode(s) with anyone.

Changes to this Notice
This Notice is subject to change from time to time, and we therefore recommend that you review it periodically. When a change has been made, we will post the revised Notice on this page with a new “Last Updated” date at the top of the page. All changes will become effective when posted unless indicated otherwise.

Contact Us
If you have any questions concerning this Privacy Notice, please contact privacy@greatgray.com