PRIVACY POLICY

Purpose of the Internet Privacy Policy

At Transamerica Investment Advisors, protecting your privacy is very important to us. By posting our Internet Privacy Policy, we want you to understand what information we collect about you when you visit our Web site and how we use that information. This Internet Privacy Policy also describes our practices for handling and securing such information. This Policy applies solely to information collected by this Web site (divinvest.com). The Policy does not apply to third party web sites, if any, linking to or from this site. Transamerica is not responsible for the privacy practices employed by other sites.

Categories of Information We Collect

Nonpublic Personal Information

Transamerica will collect no personal information about you (such as your name, phone number, mailing address or e-mail address) when you visit this Web site unless you choose to provide that information to us. You may choose to provide us with personal information in order to use a password-protected portion of our Web site (such as the Transamerica DirectSM Online account access and RetireTrackSM), to contact us by using e-mail, to complete an online form or application for a product or service that we offer, to participate in an online forum or conference, or to respond to an online survey or inquiry. We use the information to service your account, to provide you with an interactive experience by facilitating your participation in an online forum or Web conference or, in the case of e-mail, to help us get you the information you have requested and to respond to your message. We may also use personal information, such as your e-mail address, to promote products, programs or services that we believe may be of interest to you, to announce changes and new features about our products, programs or services, to provide news and educational information to you, to deliver reports or other account-related material to you, or to invite you to participate in online surveys or forums. To the extent that we collect your personal information for any of the immediately foregoing uses, you will be provided with the opportunity to opt out of such uses. Any decision to opt out may affect all such uses and, if you are a participant in an employer-sponsored retirement plan that Transamerica services, we may be required to continue complying with your employer's or plan administrator's directions regarding use of your personal information for the retirement plan and related matters. Also, to the extent that we collect your personal information, you will be given the opportunity to access and verify such information, update such information or correct factual errors in such information. You may be able to update your personal information by accessing your Profile through Transamerica DirectSM Online and making the necessary changes. To protect your privacy and security, Transamerica will take reasonable steps to help verify your identity before granting access to your personal information or making corrections. Also, Transamerica will not store or use personal information collected from this Web site unless Transamerica believes that the information is genuine or that the identity of the information provider is authentic.

The password-protected portions of our Web site are secure and you should consult the Security Information page on this Web site for additional information about our Internet security procedures. E-mail on the Internet is not secure, however, unless you are using a secure e-mail program. Other site features or mechanisms (such as online application forms, online forums, or online surveys) through which you may choose to provide personal information may or may not be secure depending on the nature of the information requested. Transamerica will provide notification of the level of security, if any, which exists with respect to each such feature or mechanism; and, where necessary or appropriate, Transamerica will take reasonable measures to ensure the secure collection and transmission of personal information using industry-accepted data encryption methodologies. In the event that a site feature or mechanism is made available to you through a third-party service provider or other agent who, because of such relationship with Transamerica, may have access to your personal information, such service provider or agent will be required to protect this information in a manner that is consistent with this Privacy Policy by, for example, not using the information for any purpose other than to carry out the services being performed for Transamerica. In rare cases, in order to access or take advantage of a particular site feature or mechanism through which you may choose to provide your personal information, you may be required to go directly to the Web site of such third party service provider or agent. In such cases, Transamerica suggests that you review the privacy policies posted on such web sites as Transamerica will have no control or responsibility over the online privacy or security practices of such third parties. Your decision to transmit or provide us with personal information in a non-secure method should be made with considerable care as there is an increased risk that such information may be intercepted or otherwise tampered with.

Other Information

If you do nothing during your visit but browse through the web site, read pages, or download information, we will not gather and store any information about your visit.

If you use our retirement or financial planning calculators (other than RetireTrackSM, which is password-protected) the information that you input into the calculator is used only for purposes of generating the illustration requested and is not stored by Transamerica. Such calculators do not require you to input any information that identifies you personally. Transamerica may conduct online surveys regarding its Web site or other products or services. You may choose to complete such surveys by inputting the requested information. The information you provide is used collectively for analytical purposes, and individual responses are not tracked. Generally, unless a survey requires its participants to meet a specific demographic profile and asks for such demographic information (containing personal information) in order to determine a prospective participant's eligibility to participate in the survey, surveys are conducted in a non-secure environment because they do not require you to provide information that identifies you personally. Because you may nonetheless choose to provide personal information (such as your e-mail address) in completing such surveys, you are solely responsible for the content of your responses to such surveys. Individuals who participate in an online forum or Web conference sponsored by Transamerica may be permitted to submit online questions or commentary as part of the interactive experience. Individuals who in fact submit such online questions or commentary should expect that they will be shared with other individuals participating in the online forum or Web conference. Also, while the submission of such online questions or commentary does not require the inclusion of personal information, you may nonetheless choose to include such information (such as your e-mail address). Consequently, if you are a participant in an online forum or Web conference, you are solely responsible for the content of any online questions or commentary you submit.

Cookies

"Cookies" are small text files that some web sites transfer to your computer for added functionality, or for tracking web site usage. A web site may place personal information into the cookie file to help you navigate through the web site. For example, a web site may use the cookie file to store a password so that you do not have to continually input it every time you move to a different section of a password-protected portion of the web site. Also, a web site may place other information into the cookie file in order to measure the effectiveness of the site. For example, a web site may use the cookie file to store the Internet domain or IP address from which you access the web site, the type of browser and operating system used to access the site, the date and time you access the site, the pages you visit and the address of web sites from which you access the site. Such information are compiled on an aggregate, anonymous basis. Most cookies are designed to expire after a certain period of time but you can delete your cookie file or set the browser to notify you when a web site is sending a cookie to your computer so that you may accept or reject it.

Generally, Transamerica does not track or record information about individuals' visits to the public Web site. However, Transamerica recognizes the benefits that such information can provide to help make our site more useful to visitors and to help us determine the effectiveness of the site. Accordingly, Transamerica may develop a keen interest in making broader use of cookie technology in the future.

With respect to its public web site, Transamerica uses cookies only to store your homepage preference or default setting for purposes of accessing the site. This is strictly for your convenience and allows you to set your browser so that every time you visit the site, you will automatically be directed to the Plan Participants homepage.

With respect to the password-protected portion of the Web site, the Transamerica DirectSM Online web application uses a cookie to hold the session ID of the user for the limited purp