Privacy Policy – Rev. June 2015

FACTS

WHAT DOES ORION ADVISOR SERVICES, LLC (“ORION”) DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

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

  • Social Security number

  • Account transactions

  • Employment information

  • Income

  • Account balances

  • Investment experience

When you are no longer our customer, we continue to share your information as described in this notice.

How?

All financial companies need to share a customer’s personal information to run their everyday business – to process transactions, maintain customer accounts, and report to credit bureaus. In the section below, we list the reasons financial companies can share their customer’s personal information; the reasons Orion chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Orion share?

Can you limit this sharing?

For our everyday business purposes such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes to offer our products and services to you

Yes

No

For joint marketing with other financial companies

Yes

No

For our affiliates’ everyday business purposes information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes information about your creditworthiness

No

We don’t share

For nonaffiliates to market to you

No

We don’t share

Questions?

Call (402) 496-3513 or go to www.orionadvisor.com

Who we are

Who is providing this notice?

Orion Advisor Services, LLC

What we do

How does Orion protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Orion collect my personal information?

We collect your personal information, for example, when you

  • open an account

  • provide account information
  • give us your income information

  • give us your contact information

  • provide employment information

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only

  • sharing for affiliates’ everyday business purposes — information about your creditworthiness

  • affiliates from using your information to market to you

  • sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Affiliates of Orion include:

  • NorthStar Financial Services Group, LLC
  • CLS Investments, LLC
  • Blu Giant, LLC
  • Gemini Alternative Funds, LLC
  • Gemini Hedge Fund Services, LLC
  • Gemini Fund Services, LLC
  • Northern Lights Compliance Services, LLC
  • Northern Lights Distributors, LLC
  • Constellation Trust Company
  • NorthStar Topco, LLC
  • NorthStar CTC Holdings, Inc.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • Orion does not share with nonaffiliates so they can market to you.

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products and services to you.

  • Our joint marketing partners include other financial service companies.

0318-OAS-6/1/2015