Under the terms of the Management Agreement and certain related agreements, Ascensus Broker Dealer Services and JPMorgan are required to treat all Account Owner and Beneficiary information confidentially. Ascensus Broker Dealer Services and JPMorgan are prohibited from using or disclosing such information, except as may be necessary to perform their obligations under the terms of the Management Agreement and such related agreements. In addition, the Advisor-Guided Plan is subject to the New York State Personal Privacy Protection Law.

New York State Personal Privacy Protection Law Notice

Personal Information is being requested from you by the Office of the Comptroller of the New York State ("Comptroller") and the New York Higher Education Services Corporation ("HESC") (the "Program Administrators" of New York's 529 College Savings Program), by Ascensus Broker Dealer Services, Inc. (the "Program Manager"), and by The Vanguard Group, Inc. or J.P. Morgan Investment Management Inc. (the "Investment Advisors"), or their employees agents, or representatives.

Personal Information you submit will be maintained in the records of New York’s 529 College Savings Program. The officials responsible for the Program records are the Program co-directors employed by the Comptroller and HESC. Their address is P.O. Box 55498, Boston, MA 02205. The telephone number of the Program is 877NYSAVES

Personal information is collected from you under the authority of the New York State College Choice Tuition Savings Program Act (Article 14 A of the New York Education Law) and Section 529. The personal information you submit will be used to maintain records of your contributions to the Program and the earnings on those contributions and to process transactions you request. If you decline to submit the requested information, it may be impossible for you to be enrolled in the Program or for the Program to process transactions you request.

New York State Information Security Breach and Notification Act

Each of the Comptroller, HESC, the Program Manager and the Investment Manager is required to comply with provisions of the New York State Information Security Breach and Notification Act (General Business Law section 899-aa; State Technology Law section 208).