We are committed
to protecting our customers' personal and financial
information. In the course of providing financial
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.
What types of nonpublic personal information do we
As you apply for, open, or maintain an account with us, or when you apply
for a financial product or service, we collect the
following types of information:
you provide online and on applications or other
forms, such as your name, address, Social Security
number, date of birth, employment information,
investment experience, and risk tolerance.
about your transactions with us, such as your
account balance, trading activity, loan amount, and
about you from consumer-reporting agencies.
What types of
nonpublic personal information do we disclose?
We may disclose nonpublic personal information we
collect, primarily to make available to you the
financial 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
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 financial products
and services, improve your experience with us, and
better serve your financial 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
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.
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, 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.
In addition to our security measures, you can also take
steps to maximize your security online and to protect
your confidential information. Additional information on
these topics can be found as following.....
What should I know about "cookies"?
"Cookies" are small amounts of data that a Web site can
send to your web browser and store on your computer.
Cookies do not contain personal information about you
(unless you knowingly provide it). Cookies can note that
your browser was used to visit certain sites, pages, or
advertisements on a certain date.
functionality of our Web site, to securely verify your
identity, and to personalize aspects of your experience
visitors are using our Web site, so that we can improve
our site and your experience on it. We permit certain
third party ad servers to set cookies and use related
technology (such as web beacons) through our Web site to
track performance of advertisements and to collect
aggregate data on web page viewing.
You do have control over cookies. Most browsers can be
set to notify you when a cookie is being placed on your
computer. You can set most browsers to refuse to accept
cookies, although this may affect your internet
You can also erase cookies that are already on your
computer. For more information on working with cookies,
consult the user manual, FAQ, or "Help" function of your
How can customers access and update their nonpublic
personal information that we collect?
We take measures to ensure that customers' nonpublic
personal information is accurate and up-to-date. You can
also access and update certain nonpublic personal
information that we collect about you. To access and
update your mailing address or your home or work phone
numbers for your account, log on to our Web site using
your user name and password. From the home page, click
on the My Info tab just under the Accounts
tab and select the information you want to change.