Privacy Notice

Raymond James, Heritage Distributors and the Heritage Family of Funds, administered by its wholly-owned subsidiary Heritage Asset Management, are committed to protecting confidentiality of the information furnished to us by our clients.

We are providing you this information as required by Regulation S-P adopted by the Securities and Exchange Commission.

Information About You That We Collect

We collect nonpublic personal information about you, including but not limited to, name, address, Social Security number and financial information from the following sources: information we receive from you on applications or other forms or through our website; information we receive about your transactions with us, our affiliates or others; and information we may receive from a consumer reporting agency.

Our Use of Information About You

As permitted by law, we may share information about you with other companies that are owned by Raymond James Financial. That information may include information shared by the Heritage Family of Funds with Raymond James broker/dealers and investment advisors, and information shared among other Raymond James service providers, such as financial advisors and insurance and annuity consultants. In addition, we may share information about you with certain nonaffiliated third parties, including service providers (e.g., mutual fund companies), non-financial companies (e.g., software developers), and others (e.g., consulting firms) in order to help us run our business, manage your accounts, provide professional services, or help us market our products and services to you. We may also share information about you with other financial institutions with which we have joint marketing agreements. These financial institutions have agreed to treat any such information as confidential and not share such information with any other parties except as permitted by law or regulation. Otherwise, we do not disclose any nonpublic personal information about you to anyone except as permitted by law or regulation. You also may have other protections under applicable state laws. To the extent these state laws apply, we will comply with them when we share information about you. We follow the same policy with respect to nonpublic personal information received from all clients and former clients.

When Financial Advisors Leave Raymond James

Financial advisors may change brokerage and/or investment advisory firms and nonpublic personal information collected by your financial advisor may be received or taken by your financial advisor to the new firm so that he or she can continue to service your account(s) at the new firm. If you do not want your financial advisor to utilize and/or transfer this information to another firm, please contact 800-647-SERV (7378) to opt-out of this information sharing. If your primary address is in an “opt-in” state (such as California and Vermont), which requires your affirmative consent to share your nonpublic information with the financial advisor’s new firm, then you must give your written consent before Raymond James will allow your financial advisor to take your nonpublic information with him or her. You can withdraw your consent at any time by contacting 800-647-SERV (7378).

Additional Information for Clients of the Financial Institution Division of Raymond James Financial Services

The Financial Institution Division of Raymond James Financial Services, Inc. is a party to joint marketing arrangements with certain banks and credit unions where you obtain Raymond James’ services. Information about clients who participate in these programs may be shared with the participating bank or credit unions. These financial institutions have agreed to treat any such information as confidential and not to share such information with any other parties except as permitted by law or regulation. In addition, you may have other protections under applicable state laws. To the extent these state laws apply, we will comply with them when we share information about you.

How We Protect Your Confidential Information

Raymond James has policies that restrict access to nonpublic personal information about you to those employees, associates and others who have need for that information to help us run our business, manage your accounts, market or provide investment alternatives or services to you, or to employees, associates, and others who assist those who help us run our business, manage your accounts, or market or provide investment alternatives or services to you. Additionally, we maintain physical, electronic, contractual, and procedural safeguards to protect your nonpublic personal information.