ONLINE PRIVACY

We take the issue of privacy very seriously. This statement outlines our commitment to ensure that all information that you, as a visitor to our Web site, share with us will be handled with care and respect for your concerns and privacy.

PRIVACY OF INFORMATION GIVEN BY YOU
If you do provide personal information about yourself, such as name, address or telephone numbers, we will endeavor to maintain that information in accordance with our internal policies governing use and disclosure of confidential information. We may disclose that information within our corporate enterprise. We may also disclose that information to unaffiliated third parties in order to respond to your inquiries, to provide services to you, to provide you with information concerning products and services that we offer, or to prevent or investigate fraud, illegal activity or misuse of this Web site. We may also disclose that information to unaffiliated third parties for other purposes if we have notified you in advance and you have not objected, you have requested or authorized us to do so, or we are required to do so by law.
USE OF COOKIES
Cookies are small pieces of information that are passed through a browser and stored on your hard drive for later retrieval. The use of cookies is a common practice on the Internet. Many Web sites use cookies to personalize customer experience and most browsers are automatically set up to accept cookies. You may choose to reject cookies by changing designated settings on your Web browser. BNY Mellon uses cookies to provide better service, track usage of its Web site and to address security hazards. We also may use cookies for some administrative purposes, such as storing your preferences for certain kinds of information or to remember a password so that you do not have to input it every time you visit our site.
USE OF ACTION TAGS
When you utilize the Web site, we may receive certain non-personally identifiable information about your use of the Web site. Such information is collected passively using various technologies, including, without limitation, action tags, and is anonymous and used in aggregrate.

We may use third party advertising companies to serve ads on our behalf across the Internet and to measure and track the effectiveness of such ads. These companies employ cookie and Web Beacon (also referred to as 1x1 pixel.gifs or action tags) technology to measure and improve the effectiveness of ads and to determine click through rates for our advertising. To do so, these companies may use information about your visits to our Web site. These technologies do not collect personally identifiable information ("PII"). In addition, the data collected is not linked with any information you may voluntarily provide in your visit to our Web site.
COVERAGE OF THIS POLICY
Specific privacy policies apply to non-public personal information concerning consumers of certain products and services that we offer. We make those policies available to our customers in accordance with federal law.

NOTICE TO CALIFORNIA USERS REQUIRED BY STATE LAW: We retain information we receive through this Web site, including information you give us to open an account or purchase a product or service from us, information you give to us in inquiries and other communications, and records of any transactions you perform. We share this information with affiliated and nonaffiliated parties only as necessary to process and service your transactions with us, or as required by law. Such parties may include those who provide services to us in connection with your accounts or transactions, or who are involved in providing you the services you request. In certain instances they might include a purchaser or potential purchaser of an account. We also report information to credit bureaus in appropriate cases. And we share information with government agencies and law enforcement as necessary.
PROTECTION OF SOCIAL SECURITY NUMBERS
"We" refers to the family of companies owned by The Bank of New York Mellon Corporation.

Like all financial services companies, we collect a variety of information about individuals, including but not limited to our customers and employees. In many cases that information includes individuals' Social Security numbers. We use records of Social Security numbers for many purposes, especially to comply with federal and state laws such as tax laws and anti-money-laundering laws.

Our policy is (i) to comply with all laws restricting the use and disclosure of Social Security numbers, (ii) to protect the confidentiality of Social Security numbers, (iii) to prohibit the unlawful disclosure of Social Security numbers, and (iv) to limit access to Social Security numbers to our employees, and in certain cases to nonaffiliated parties that provide services to us, based on their responsibilities. To safeguard Social Security numbers, we maintain physical, electronic, and procedural safeguards that are designed to comply with applicable legal standards. Our employees are prohibited from disclosing Social Security numbers for unauthorized purposes.

We may share Social Security numbers among our affiliated companies or with nonaffiliated parties for administrative purposes, such as to process transactions, verify identities, and service accounts. We disclose Social Security numbers as required or permitted by law, such as to the Internal Revenue Service or to credit bureaus. When necessary, we disclose Social Security numbers to regulatory agencies, law enforcement agencies, courts, and parties to lawsuits.

We may share Social Security numbers among our affiliated companies for marketing purposes, but only in compliance with legal restrictions, including required opportunities to opt out of such sharing. We do not, without consent of the individual involved, share Social Security numbers with parties not affiliated with us to enable them to market their own products or services.

The above information is effective December 13, 2011. Any changes to our policy will be reflected in this location.
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