This notice applies to individual consumers who are clients or former clients of the Wealth Management division of BNY Mellon, N.A., The Bank of New York Mellon, The Bank of New York Mellon Trust Company, N.A., and BNY Mellon Trust of Delaware. It does not apply to other business lines of any of these entities. It describes our policies and practices for collecting, disclosing, and safeguarding "nonpublic personal information," which may include financial or other customer information.

This notice replaces all previous notices of our consumer privacy policy, and may be amended at any time.  We'll keep you informed of changes as required by law.

We collect a variety of nonpublic personal information about you, which may include:

• Information we receive from you, as provided, for example, on applications or other forms, such as your name, address, social security number, assets, and income.
  
• Information about your transactions with us, our affiliates, and others, such as, your account balance, payment history, parties to transactions, and debit/credit card usage.
  
• Other information we receive from affiliates and nonaffiliated third parties, including credit reporting agencies such as your creditworthiness and credit history.
  

We may disclose any of the information we collect to our affiliates and to nonaffiliated third parties as described below.

Our affiliates include financial service providers such as banks, securities broker-dealers, investment advisors, insurance agencies, and transfer agents, as well as firms that provide technology and other services to us.  We may disclose information to affiliates as permitted or required by law.  For example:

• We may disclose information for administrative purposes, such as to process your transactions and service your accounts.
  
• We may disclose information to our affiliates so that they can tell you about their services and products that may be of value or interest to you, subject to your right to opt out as described below.
  
  We may disclose information to third parties that are not affiliated with us, as permitted or required by law.  For example:
  
• We may disclose information to companies that provide services to us, in order to process transactions and service accounts.
  
• We may disclose information to companies who perform marketing services on our behalf, or financial institutions with which we have joint marketing agreements.
  
• We may disclose information in response to subpoenas, court orders and other legal process.

Our internal data security policies restrict access to nonpublic personal information to authorized employees.  We maintain physical, electronic and procedural safeguards that are designed to comply with federal standards to guard our customers' non-public personal information.  Employees who violate our data security policies are subject to disciplinary action, up to and including termination.

You may tell us not to disclose nonpublic personal information about you to our affiliates for the purpose of enabling them to market their products and services to you.  These affiliates include the following:


The Bank of New York Mellon
BNY Mellon, N.A.
The Boston Company Asset Management
Boston Safe Advisors, Inc.
Boston Safe Deposit Finance Co., Inc.
Dreyfus Service Organization, Inc.
EACM Advisors LLC
Founders Asset Management LLC
G Trade Servicing LLC
Ivy Capital Management Corp.
Lockwood Advisors
Lockwood Capital Management
MBSC Securities Corporation
Pershing LLC
Standish Mellon Asset Management Company LLC
Urdang Securities Management

and all other banks or companies whose names include "BNY" or "Mellon."  Your opt-out will also apply to banks or other companies that may become our affiliates in the future.

Your opt-out will continue to be effective unless and until you revoke it.  You can notify us of your preference by completing and returning the form below.  You may notify us about your privacy preferences at any time by contacting us at the address below.  If you have already opted out, you do not need to do so again.

For joint consumer accounts, any one of the joint account holders has the right to exercise the option described above.  If you are a joint account holder, your decision will also apply to others with whom you jointly hold accounts.  If you have more than one consumer account with us, you need only respond once.  It is not necessary for you to respond for each account.

If our account records show that you live in Vermont then we will not disclose nonpublic personal information about you to our affiliates for the purpose of enabling them to market their products and services to you.  There is no need for you to opt out to prevent that kind of disclosure.

Exclude me from information sharing among your affiliates as described above.

_________________________________________________________________
Name (please print)
_________________________________________________________________
Address      Apt #
_________________________________________________________________
City   State     Zip Code
_________________________________________________________________
Last 4 digits of Social Security Number

Detach this form, and mail it back to us at the following address:

Room 151-1159
Customer Privacy Preference Department
The Bank of New York Mellon
P.O. Box 535009
Pittsburgh, PA  15253-5009