Your Privacy Is Important To Us
We know how important personal privacy is to you. We recognize that whether you are an existing client or are considering a relationship with us, you have an interest in how we collect, retain, and use information about you and your financial relationship with us. Our systems and policies have been engineered to provide maximum protection against unauthorized access to sensitive customer information. The following information details what we have done to answer your financial privacy concerns:

Staff Member Access to Information
We permit only authorized staff members to have access to your information. This access enables our staff to assist you in completing transactions and resolving any issues that might arise. We have policies and procedures in place and have educated our staff members on the importance of confidentiality and client privacy. Any staff member who willfully or knowingly violates these policies is subject to disciplinary action, including the possibility of termination.

How and Why Information Is Collected and Shared
We will collect, retain, and use only the information that we are permitted by law to obtain and that we believe is useful in helping you succeed. We use your information in ways that are compatible with the purposes for which we originally obtained or requested it, such as to process your requests and transactions, to provide you with additional information about products and services, or to evaluate your financial needs.

We are highly selective in choosing vendors and service companies that assist us in providing quality products and services to our clients. We may share certain client information with these parties to facilitate the offering, administration, collection, and delivery of these products and services, but any such sharing is done under controlled circumstances designed to protect our clients' privacy. In addition, we require these parties to comply with strict standards regarding security and confidentiality of such information.

Sharing Customer Information
We do not sell any customer information to third party marketing companies. At times, we may be legally required to disclose information about you, such as in response to a subpoena, to prevent fraud, or to comply with a legally permitted inquiry by a governmental agency or regulator. We may also exchange your information, to the extent permitted by law, to perform necessary credit checks or collect or report debts owed to us, to protect our rights or property, for verification and risk management, and for other legally permissible purposes.

Maintaining the Accuracy of Your Information
Keeping your account information up-to-date is very important to us. We have established procedures to ensure that your financial information is as accurate and up-to-date as reasonably possible. If you believe that our records contain inaccurate or incomplete information, please call or write to us at the telephone number or address listed on your account statement. We will investigate the matter and take prompt steps to make appropriate corrections.

Security Standards
We have established, and continually maintain, security standards and procedures to help us protect you from unauthorized access to confidential information we may have about you, including through the Internet.

Protecting Website Information
When you visit our website, you may ask yourself, "Is it really safe to conduct trust business on the Internet?" The answer to that question is YES. While no system is impenetrable, our systems are designed for maximum protection of your information.

For your protection, we use 128-bit encryption for our on-line services. Data is transferred via a "secure session" established with Secure Sockets Layer (SSL) 128-bit encryption technology. This technology protects information as it crosses the Internet by encrypting - or scrambling - your account information so it is virtually impossible for anyone other than you and us to read it. If your Internet browser does not support 128-bit encryption, you can download the most current version of Microsoft® Internet Explorer, Mozilla Foxfire® or Apple® Safari® free of charge. (If you access the Internet from a corporate network, we recommend that you contact your network administrator before downloading a new browser.) If your browser is provided as part of a national Internet Service Provider ("ISP"), such as America Online or Prodigy™, you will need to check to see if your version is capable of supporting SSL 128-bit encryption technology. If your browser does support the 128-bit encryption, it will activate SSL automatically whenever you sign onto our on-line services.

Note to International Customers
Under current U.S. export laws, web browsers that encrypt data in 128-bit sessions may be exported only to a limited number of countries outside of the U.S. Therefore, if you are located outside of the U.S., you may not have access to such a browser. In this case, you would not be able to use our on-line services, and your ability to enjoy other features of our site would also be limited.

Password Protection
Your unique User ID ("UID"), password, security image, and security caption also protect access to accounts you may have with us and to transactional information through our on-line services. You can also help maintain the security of your financial information by not sharing your UID, or password, security image, security caption, or any information about the security questions you have selected with anyone, by changing your password regularly, and by remembering to sign off of our website when you have finished your session.

When Website Information is Collected and Not Collected
If you register with our website, we will request information from you in connection with your registration. In addition, if you choose to apply for various on-line services that we offer, such as On-Line Portfolio and On-Line Statements, we will request personal information that we need to process your application. Subsequent to signing up for these on-line services, we may also request information from you, such as your email address or your account number, to enable you to perform certain tasks (for example, review your accounts or correspond with us). In this case, we will collect your information, if necessary, to interact with you. If you do not register with us or sign up for our on-line services, we do not collect any personal information from you.

About "Cookies"
A "cookie" is a small text file placed on your computer hard drive by our web server. Cookies are commonly used on websites and do not harm your system or read or collect information from your computer's hard drive. To better serve you and to provide a more effective website, we use "cookies" as part of our interaction with your web browser.

We use cookies to determine if you have previously visited our website, to log the pages you use on our site, and for a number of administrative purposes - for example, to store your preferences for certain kinds of information. These cookies do not collect personally identifiable information, but we may combine information collected through cookies with other personal information you have provided to us in connection with your use of our website to determine who you are or your email address. All of this information helps us in our efforts to continually improve our website and to be responsive to your specific needs.

Cookies will not contain information that will enable us to contact you via telephone, e-mail, or U.S. mail. You can set up your web browser to inform you when cookies are present or to prevent cookies from being set up.

However, by rejecting a cookie, some of the features available on our website may not function properly or be accessible to you. If while inside our website you receive a pop-up box asking if you would like to "accept the cookie," you must answer "yes" in order to advance beyond the area that prompted the message.

We may preserve the content of your email, your email address, and our response so that we can more efficiently handle any questions you may have and also to meet legal and regulatory requirements.

We request that you not send sensitive, confidential information such as social security or account numbers to us via an unsecured email, because it is possible that the information could be intercepted during transmission. Any communications of sensitive or confidential information should be sent to us via encrypted email, by U.S. mail, or you may call 1-800-258-6334 or visit one of our offices.

Consolidation Sites or Account Aggregators
We recommend that you exercise caution when using account aggregator or consolidation sites. These sites are Internet sites that offer the ability to collect some or all of your personal information on one site. For example, you might be encouraged to provide an account aggregator with your personal financial information, such as your ID and password for online services. You should never provide personal information to a site that you do not recognize and fully trust.

Use of your personal information is governed by the policies and practices of the companies providing such services and not by our policies. You should also note that all transactions initiated by an account aggregator, using access information provided by you, are considered to be authorized by you whether or not you were aware of the specific transaction. You may revoke this authority only by notifying us, and we may need to block your account until we issue a new UID and/or password to you.

Information you voluntarily provide on surveys and promotions on our website will be used for internal marketing purposes, such as developing website information and services that you may find helpful. In addition, we may inform you of new or upgraded products and services based on the information you provide to us.

Protecting Our Children
We recognize that protecting children’s identities and privacy online is important and that the responsibility to do so rests with both the online industry and with parents. We do not knowingly solicit data from children under the age of 13, and we do not knowingly market through our website to such children.

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If you have any specific questions related to our Security and Privacy Statement, please contact us or call us at 1-800-258-6334.