Privacy Policy

1. Introduction

Super Chief Pension Services LLC ("Company," "we," "us," or "our") is a third-party administrator (TPA) serving financial advisors, employers, tax professionals, benefits consultants, and other retirement plan service providers. We are committed to protecting the privacy and security of information entrusted to us by our professional partners and their clients. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website at supercpensions.com ("Website") and when you engage with us for retirement plan administration, compliance, and related TPA services.

As a TPA, we understand that the information we handle—participant data, plan records, financial information, and compliance documentation—represents a significant trust. This Privacy Policy outlines our commitment to that trust. Please read this policy carefully. If you do not agree with our policies and practices, please do not use our Website or services. Your continued use of our Website and services following any modifications to this Privacy Policy means you accept those changes.

2. Company Information

3. Our Role as a Third-Party Administrator (TPA)

Super Chief Pension Services operates as a third-party administrator for retirement plans. Our role is to provide comprehensive administrative support to:

• Financial advisors and advisory firms seeking to expand retirement plan services
• CPA firms and tax professionals integrating plan administration into their practice
• Employers sponsoring retirement plans directly
• Benefits consultants and other retirement plan service providers
• Multi-advisor platforms and aggregators offering retirement solutions

We serve as the operational and compliance backbone, managing plan administration while our professional partners deliver advisory services and client relationships. This Privacy Policy addresses both our responsibilities as a TPA and your privacy rights as a business partner or plan participant.

4. Information We Collect

4.1 Information Provided by Plan Sponsors and Professional Partners

We collect information that financial advisors, employers, tax professionals, and other professional partners provide to us for the purpose of plan administration:

• Professional Contact Information: Name, title, firm name, business email, phone number, and business address
• Plan Sponsor Information: Legal entity details, EIN, plan structure, plan type (401(k), SIMPLE, SEP, Solo, etc.)
• Plan Participant Information: Names, Social Security numbers, addresses, dates of birth, salary/wage information, deferral elections, and beneficiary designations
• Financial Data: Contribution amounts, employer match calculations, loan activity, and distribution information
• Tax Information: Tax identification numbers, required minimum distribution calculations, and tax compliance documentation
• Plan Documents and Records: Investment elections, plan amendments, compliance test results, and regulatory filings

4.2 Information Collected Automatically from Our Website

When you visit our Website, we automatically collect certain information about your device and browsing activity:

• Log Data: IP address, browser type, operating system, pages visited, time and date of visits, and duration of visits
• Device Information: Device type, device identifiers, and mobile network information
• Cookies and Tracking Technologies: We use cookies and similar technologies to enhance your Website experience
• Analytics Data: Information about how you interact with our Website, including click patterns and content engagement

4.3 Information from Third Parties

We may receive plan information from payroll processors, investment custodians, recordkeeping vendors, and other service providers acting on behalf of plan sponsors, to the extent permitted by law and necessary for plan administration.

5. How We Use Your Information

We use the information we collect to fulfill our responsibilities as a TPA and to support the professional relationships that enable our partners to serve their clients:

• Plan Administration: To maintain accurate participant records, process contributions and distributions, manage plan accounts, and administer benefits
• Compliance Management: To perform nondiscrimination testing, prepare required regulatory filings (Form 5500, 401(k) plan tests, etc.), and monitor ongoing compliance with ERISA, IRS, and DOL requirements
• Professional Communication: To respond to inquiries from plan sponsors, financial advisors, employers, and other professional partners; provide service updates; and deliver administrative support
• Payroll Integration: To coordinate with payroll providers to ensure accurate and timely contribution processing and employer match calculations
• Tax Planning and Reporting: To prepare tax documents, calculate required minimum distributions, file tax forms, and support tax optimization strategies
• Participant Communication: To prepare participant statements, educational materials, and other communications that support participant understanding of their retirement benefits
• Website and Service Improvement: To analyze Website usage, improve functionality, enhance user experience, and refine our administrative processes
• Security and Fraud Prevention: To detect, prevent, and address security incidents, fraud, and technical issues that could compromise plan data
• Business Operations: To conduct business analysis, manage our practice, prepare internal reporting, and support operational efficiency

6. How We Share Your Information

6.1 With Plan Sponsors, Advisors, and Professional Partners

We share appropriate information with plan sponsors, financial advisors, employers, tax professionals, and other authorized representatives as necessary for plan administration and to support your role as a professional service provider. This may include participant records, compliance test results, regulatory documentation, and administrative reports.

6.2 With Service Providers

We share information with third-party service providers who support our operations, including payroll processors, compliance software vendors, recordkeeping service providers, investment custodians, tax filing services, and cloud infrastructure providers. These service providers are contractually bound to use your information only as necessary to provide services to us and to maintain the confidentiality and security of all data in their custody.

6.3 For Regulatory Compliance

We may disclose plan information when required by law, regulation, or legal process, including but not limited to: IRS requests and tax reporting, Department of Labor inquiries and regulatory compliance, state pension and regulatory agencies, law enforcement requests, and court orders. We disclose information only to the extent necessary to comply with legal obligations, regulatory requirements, and professional standards.

6.4 Business Transfers

If we are involved in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction, plan information and related data may be transferred as part of that transaction. We will provide advance notice to all affected plan sponsors and professional partners before information becomes subject to a different privacy policy.

6.5 With Your Explicit Consent

We may share information for purposes other than those outlined above only with your explicit written consent. You will be notified and given the opportunity to opt-out of any such sharing.

7. Data Security

We implement comprehensive technical, administrative, and physical safeguards to protect plan information, participant data, and business records against unauthorized access, alteration, disclosure, and destruction. Our security program includes:

• Encryption in Transit and at Rest: Data transmitted to and from our Website and systems is encrypted using SSL/TLS technology; data stored in our systems is encrypted
• Access Controls and Authentication: Strict access limitations, multi-factor authentication, and role-based permissions for sensitive information
• Secure Cloud Infrastructure: Industry-standard, SOC 2 compliant platforms with robust security features and redundant systems
• Employee Security Training: Regular security training and compliance education for all staff members
• Continuous Monitoring: Real-time monitoring, regular security audits, and periodic testing for vulnerabilities
• Incident Response Plan: Established procedures for detecting, responding to, and resolving security incidents

8. Data Retention

We retain plan information and records for as long as necessary to provide TPA services, comply with legal and regulatory requirements, and fulfill the purposes outlined in this Privacy Policy. Retention periods are determined by applicable law and professional standards:

• Plan documents and administrative records: Typically 6-7 years following plan termination (or longer per IRS/DOL requirements)
• Participant records: In accordance with Department of Labor and IRS regulations (typically indefinitely for active plans)
• Compliance testing and regulatory filings: Maintained per record retention requirements
• Website usage and analytics data: Typically 12-24 months

You may request deletion of non-essential information subject to legal, contractual, and regulatory retention obligations. For active plans, records are retained to support ongoing compliance and participant service. Upon plan termination, records are retained according to regulatory timelines.

9. Your Rights and Choices

9.1 Access to Plan Information

As a plan sponsor, financial advisor, or professional partner, you have the right to access and request copies of your plan information, participant records, compliance documentation, and administrative reports. To request access or receive copies, contact us at the email or telephone number provided below. Participant rights to access their individual account information are governed by plan documents and ERISA.

9.2 Correction of Information

You have the right to request correction of inaccurate plan information or records in our system. To request a correction, please contact us with specific details about the information that needs to be updated.

9.3 Marketing Communications

If you no longer wish to receive marketing communications, newsletters, or service announcements from us, you may opt-out by clicking the unsubscribe link in the email or by contacting us directly.

9.4 Website Cookies

You can control cookie settings through your browser. Most browsers allow you to refuse cookies or alert you when cookies are being sent. However, blocking cookies may affect your ability to access certain features of our Website or online services.

9.5 State-Specific Privacy Rights

Depending on your location, you may have additional rights under state privacy laws. These may include the right to know what personal information we collect, request deletion of personal information (subject to business necessity and legal obligations), and opt-out of data sales. Contact us to understand and exercise any state-specific rights that may apply to you.

10. Children's Privacy

Our Website and TPA services are not intended for children under the age of 18. We do not knowingly collect personal information directly from children. If we become aware that information from a child has been collected, we will take steps to delete such information and terminate access.

11. Third-Party Links and Integrations

Our Website may contain links to third-party websites and integrations with third-party platforms operated by financial institutions, payroll processors, investment custodians, and other service providers. This Privacy Policy applies only to information collected by Super Chief Pension Services. We are not responsible for the privacy practices of third-party websites or platforms. We strongly encourage you to review the privacy policies of any third-party sites or services before providing information or authorizing integrations.

12. Updates to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, regulatory guidance, or other factors. The "Last Updated" date at the top of this policy indicates when it was last revised. Material changes will be announced on our Website or communicated directly to plan sponsors and professional partners to the extent required by law. Your continued use of our Website or services following any modifications to this Privacy Policy means you accept those changes.

13. Contact Us

If you have questions about this Privacy Policy, concerns about your privacy or plan data security, wish to exercise your rights regarding your information, or need to report a data security incident, please contact us: