Waddell & Reed, Inc., the Waddell & Reed Advisors Funds, the Ivy Funds Variable
Insurance Portfolios and the InvestEd Portfolios ("Waddell &
Reed") are committed to ensuring their clients have access to a broad range of products
and services to help them achieve their personal financial goals. Accurate information
lies at the heart of our pledge to provide these products and services, and we strive
to protect your personal nonpublic information. In the course of doing business
with Waddell & Reed, clients are requested to share financial information and
they may be asked to provide other personal details. Clients can be assured that
Waddell & Reed is diligent in its efforts to keep such information confidential.
Recognition of a customer's expectation of privacy. At Waddell & Reed,
we believe the confidentiality and protection of customer information is one of
our fundamental responsibilities. And while information is critical to providing
quality service, we recognize that one of our most important assets is our customers'
trust. Thus, the safekeeping of customer information is a priority for Waddell &
Information collected. In order to tailor available financial products to
your specific needs, Waddell & Reed may request that you complete a variety
of forms that require nonpublic personal information about your financial history
and other personal details, including but not limited to, your name, address, social
security number, assets, income and investments. Waddell & Reed may also gather
information about your transactions with us, our affiliates and others.
Categories of information that may be disclosed. While Waddell & Reed may disclose
information it collects from applications and other forms, as described above, we
at Waddell & Reed also want to assure all of our customers that whenever information
is used, it is done with discretion. The safeguarding of customer information is
an issue we take seriously.
Categories of parties to whom we disclose nonpublic personal information.
Waddell & Reed may disclose nonpublic personal information about you to selectively
chosen financial service providers, whom we believe have valuable products or services
that could benefit you. Whenever we do this, we carefully review the company and
the product or service to make sure that it provides value to our customers. We
share the minimum amount of information necessary for that company to offer its
product or service. We may also share information with unaffiliated companies that
assist us in providing our products and services to our customers; in the normal
course of our business (for example, with consumer reporting agencies and government
agencies); when legally required or permitted in connection with fraud investigations
and litigation; and at the request or with the permission of a customer. In addition,
Waddell & Reed, Inc. has entered into a Protocol with a number of other brokerage
firms intended to further our clients' freedom of choice in connection with the
movement of their financial advisors to new firms. In the event your account is
maintained through Waddell & Reed, Inc. and your financial advisor leaves Waddell
& Reed to join a firm that has likewise entered the Protocol, Waddell &
Reed may disclose your name, address and telephone number to the departed advisor's
Opt out right. If you prefer that we not disclose nonpublic personal information
about you to nonaffiliated third parties, you may opt out of those disclosures;
that is, you may direct us not to make those disclosures (other than disclosures
permitted by law). If you wish to opt out of disclosures to nonaffiliated third
parties, you may make this request by completing the opt out form and mailing
it to Waddell & Reed .
Confidentiality and security. We restrict access to nonpublic personal information
about you to those employees who need to know that information to provide products
and services to you. We maintain physical, electronic, and procedural safeguards
that comply with federal standards to guard your nonpublic personal information.
If you decide to close your account(s) or become an inactive customer, we will adhere
to the privacy policies and practices as described in this notice.