Privacy Policy

For the purpose of this document, the term "our customers" refers to you.

Working onbehalf of your financial organization, Pershing LLC recognizes the importance of protecting the confidentiality of nonpublic personal information that it collects about its customers. The information is used to ensure accuracy in reporting and record keeping, to maintain its customers' accounts, and to carry out requested transactions. A top priority for Pershing is to keep this information secure.

1. Pershing collects nonpublic personal information from the following sources:

• Applications or other forms (such as name, address, Social Security Number, assets, and income)
• Customers' transactions with Pershing, their financial organizations, or others
• Consumer reporting agencies (such as credit worthiness and credit history)
• A multitude of reports are delivered electronically, can be printed locally, or are available in hard copy.

2. Internal data security policies restrict access to nonpublic personal information to authorized employees. Pershing maintains physical, electronic, and procedural safeguards that are designed to comply with federal standards to guard nonpublic personal information. Employees who violate these policies are subject to disciplinary action, up to and including termination.

3. Pershing may disclose nonpublic personal information about its customers to affiliates, such as banks, mortgage lenders, and securities broker-dealers, in order for affiliates to provide services, such as data processing and loan servicing.

4. Pershing may disclose nonpublic personal information about its customers to nonaffiliated third parties with whom it has contracted to perform services on its behalf, such as printing, mailing, fraud prevention, and data processing services, as well as your nonaffiliated financial organization, which has a clearing agreement with Pershing. Pershing may also disclose nonpublic personal information about its customers as permitted or required by law.

5. Pershing does not disclose nonpublic personal information about former customers, except as permitted or required by law.

6. If Pershing's customers visit a Pershing Internet web site, it may occasionally use a "cookie" in order to provide better service, to facilitate its customers' use of the web site, to track usage of the web site, and to address security hazards. A cookie is a small piece of information that a web site stores on a personal computer, and which it can later retrieve. Pershing may use cookies for some administrative purposes; for example, to store its customers' preferences for certain kinds of information. None will contain information that will enable anyone to contact its customers via telephone, e-mail, or any other means. If Pershing customers are uncomfortable with the use of cookie technology, they can set their browsers to disable cookies. Certain of Pershing's services, however, could be dependent on cookies and its customers may disable those services by refusing cookies.