Privacy

The Bank of New York Mellon Corporation, BNY Mellon Asset Management and/or its subsidiaries and affiliates (referred to collectively as “we” or “us”) ") take the matter of privacy very seriously. This statement outlines our commitment to ensure that all information you, as a user of our website, share with us will be handled with care and respect for your concerns about privacy. Please note that our website provides links to other websites that we think might be of interest to our users ("Linked Sites"). Please note that when you click on one of these links, you may be moving to another provider's website. These Linked Sites and their providers are not controlled by us, and we are not responsible for the contents or the proper operation of any Linked Site. The inclusion of any link does not imply our endorsement. We encourage you to read the terms of use and privacy statements of these Linked Sites as their policies may differ from ours.

We may revise this Online Privacy Policy at any time by posting a revised policy on our website.  Therefore, please check this policy from time to time for such revisions. If you have specific questions regarding this policy or any information you have sent via the website, please do not hesitate to contact us.

You may visit this website and read about our products and services and read our corporate information without providing any information about yourself.

You may be asked to provide information in a number of ways, including by voluntarily responding to our on-line surveys, sending us an email,* requesting information or asking to be contacted by one of our representations. 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 respect the privacy of your children and do not knowingly collect or retain personally identifiable information from children under the age of 13 through our website. 

Consistent with applicable law and subject to any restrictions, we may disclose your information within our corporate enterprise. We may also disclose your 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 website. Except as noted below, we may also disclose your 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.

*  If you contact us by e-mail, please be aware that those e-mail communications will not be encrypted and, therefore, we cannot guarantee the security of the information you transmit and you will be doing so at your own risk

In order to provide better service (including facilitating your navigation within our website, improving the presentation of our website and personalizing your visit to our website), track usage of this website, and to address security hazards, we may occasionally use a "cookie." A cookie is a small piece of information which a website stores on your web browser on your PC and can later retrieve. We may use cookies for some administrative purposes; for example, to store your preferences for certain kinds of information, to store a password so that you do not have to input it every time you visit our website, or to understand and measure visitors to our website. We also may use a cookie to store information about the browser on your computer to facilitate interfacing with it, but will not retrieve other information about your computer or the programs on it. We hope that such information will enable us to improve our website. If you prefer not to accept cookies and set your browser accordingly, you may experience difficulties when visiting our website, including not being able to log into any password-protected areas of our website. A cookie will not contain information that will enable anyone to contact you via telephone, e-mail, or any other means.

We use information that you provide during a visit to our website to respond to your specific requests, to provide the best possible service to you, including providing the latest information about products and services offered by us, and to comply with any applicable legal and/or regulatory requirements. We also may maintain a log or record of the communications between you and us via our website to ensure that proper and timely follow-ups to your request or comments have occurred and to measure our website's effectiveness as a communications vehicle.

Certain of our employees may be given the information you provide to us via our website in order to respond to your requests. Such employees are instructed to use strict care in handling the information you have given to us and to share it with others only on a "need to know" basis for purposes of serving your interests. All of our employees are subject to our Code of Conduct, which provides disciplinary sanctions including dismissal for failure to conform to the Code of Conduct's confidentiality rules.

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 website, 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.

This notice is effective July 1, 2007. Any changes to our policy will be reflected in this location.

"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.

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