| We are committed to protecting our customers' business information. In the course of providing products and services, we need to collect and maintain certain nonpublic personal information. This Privacy Statement answers some questions about what nonpublic personal information we collect, what we do with it, and how we protect it. We do not disclose any nonpublic personal information about our customers or former customers to any nonaffiliated third parties, except as described below. What types of nonpublic personal information do we disclose? We may disclose nonpublic business or personal information we collect, primarily to make available to you the products and services that we and our business partners provide. We do not disclose nonpublic personal information about former customers to anyone, except as permitted by law or to cooperate with regulators or law enforcement authorities. To what types of entities (other than those companies used to process or service transactions) do we disclose nonpublic personal information? We may disclose nonpublic personal information among our affiliated companies and to other financial services providers with which we have joint marketing agreements or that offer financial products and services with us or on our behalf. By sharing this information, we can provide you with a broader range of products and services, improve your experience with us, and better serve your needs. We may also disclose information that we collect from you such as your name, contact information, and customer relationships with us to nonaffiliated third parties that perform services, such as marketing or market research, on our behalf. For example, we may provide your name, address, phone number, and/or e-mail address to vendors who send our e-mail or regular mail. We require that all entities with which we share your nonpublic personal information, including companies that process or service transactions for us, agree to keep your information confidential. We also prohibit them from using or disclosing your information except for the limited purpose and to the persons for whom disclosure was intended, or as otherwise permitted by law. We will not sell your personal information to third-party marketers or any other entity for any purpose without your consent. In some limited circumstances, we may disclose nonpublic personal information about you to a non-financial services company, such as a retailer with which we have a marketing program, but only with your prior consent. If you consent to such disclosure, the information shared will be limited to that stated in our request for your consent. Account balance, credit, Social Security number, and trading activity information are not disclosed. To what other types of entities might we disclose nonpublic personal information? We also may disclose information about you to companies that service, maintain, or process for us your transactions and accounts. For example, we provide information to companies that prepare and mail account statements and transaction confirmations. In addition, we disclose nonpublic personal information to nonaffiliated third parties, as permitted or required by law or to cooperate with regulators or law enforcement authorities. These parties include government/regulatory organizations, such as the Internal Revenue Service (IRS) and the Securities and Exchange Commission (SEC), as well as any of the securities exchanges, self-regulatory organizations and states we are registered with and to parties under court order or subpoena that request this information. Disclosures for which you have provided your consent or you have directed us to make are also permitted. What opt outs of disclosure are available and how can they be exercised? The law allows you to opt-out of our sharing nonpublic personal information about you in certain circumstances with affiliated and nonaffiliated companies; that is, you may direct us to not make such disclosures. We do not currently share information about you with any affiliate or third party that triggers this opt-out right. Therefore, there is no need for you to opt-out. If in the future we desire to disclose your information in a way that is inconsistent with this policy, we will notify you in advance and provide you with the opportunity to opt-out of such disclosure. How do we protect the confidentiality and security of nonpublic personal information?We maintain physical, electronic, and procedural safeguards that meet or exceed industry standards to guard your nonpublic personal information. We protect your account information by placing it on the secure portion of our Web site, using firewalls and other security technology to protect our network and systems from external attacks, and requiring you to enter a unique user name and password to access your account information online. Also, our servers have been enabled with Secure Sockets Layer (SSL) technology to prevent unauthorized parties from viewing the nonpublic personal information that you provide or access during a secure session (look for the padlock icon on your browser). In addition, if you access information online, we use digital certificate services to authenticate that you are transacting with our Web site. Our employees (for example, customer service and compliance personnel) and third party service providers have access to your nonpublic personal information only on a "need to know" basis. We conduct regular internal audits of our business practices and procedures, examining confidentiality standards and information access in order to protect your personal information. |