EACM_PrivacyNotice2

PROTECTING YOUR PRIVACY
(Important Privacy Choices For Consumers)

This notice applies to individuals who obtain or apply for a financial product or service for personal, family, or household purposes, or have done so in the past, from EACM Advisors LLC, or any of its affiliates listed below. It describes our policies and practices for collecting, disclosing, and safeguarding “nonpublic personal information,” which may include financial or other customer information. It also provides you the opportunity to opt out of certain disclosures of information about you.

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.

INFORMATION WE COLLECT AND SHARE

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.

• Information about your transactions with us, our affiliates, and others.

• Other information we receive from affiliates and nonaffiliated third parties, including credit reporting agencies.

INFORMATION WE DISCLOSE

We may disclose any of this information to our affiliates or to nonaffiliated third parties for appropriate purposes, as described below.

Our affiliates include financial service providers such as banks, securities broker-dealers, investment advisors, insurance agencies, and transfer agents. We may share customer information with affiliates as follows:

• We may disclose information for administrative purposes, such as to process your transactions and service your accounts.

• We may disclose information with our affiliates so that they can tell you about 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, as required or permitted by law, to third parties not affiliated with us. For example:

• We may disclose information with companies that provide services to us, in order to process your transactions and service your accounts.

• We may disclose information to those who perform marketing services on our behalf, or financial institutions with which we have joint marketing agreements that provide for the confidentiality and security of customer information.

• We may disclose information in response to subpoenas, court orders and other legal process.

CONFIDENTIALITY AND SECURITY OF NONPUBLIC PERSONAL INFORMATION

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.

YOUR RIGHT TO OPT OUT OF CERTAIN INFORMATION SHARING WITH AFFILIATES

You may tell us not to disclose nonpublic personal information about you with 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
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 sharing information with 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.

SPECIAL NOTICE FOR RESIDENTS OF VERMONT

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.

OPT-OUT FORM

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

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

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

EACM Advisors LLC
200 Connecticut Avenue, 6th Floor
Norwalk, CT 06854
Attn: Compliance Dept.

Ver 11-2011

Terms And Conditions | Privacy Notice | Contact Us


	PROTECTING YOUR PRIVACY (Important Privacy Choices For Consumers)
This notice applies to individuals who obtain or apply for a financial product or service for personal, family, or household purposes, or have done so in the past, from EACM Advisors LLC, or any of its affiliates listed below. It describes our policies and practices for collecting, disclosing, and safeguarding “nonpublic personal information,” which may include financial or other customer information. It also provides you the opportunity to opt out of certain disclosures of information about you. 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.
	INFORMATION WE COLLECT AND SHARE 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.
		• Information about your transactions with us, our affiliates, and others.
		• Other information we receive from affiliates and nonaffiliated third parties, including credit reporting agencies.

	INFORMATION WE DISCLOSE
	We may disclose any of this information to our affiliates or to nonaffiliated third parties for appropriate purposes, as described below.
	Our affiliates include financial service providers such as banks, securities broker-dealers, investment advisors, insurance agencies, and transfer agents. We may share customer information with affiliates as follows:
		• We may disclose information for administrative purposes, such as to process your transactions and service your accounts.
		• We may disclose information with our affiliates so that they can tell you about 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, as required or permitted by law, to third parties not affiliated with us. For example:
			• We may disclose information with companies that provide services to us, in order to process your transactions and service your accounts.
			• We may disclose information to those who perform marketing services on our behalf, or financial institutions with which we have joint marketing agreements that provide for the confidentiality and security of customer information.
			• We may disclose information in response to subpoenas, court orders and other legal process.

	CONFIDENTIALITY AND SECURITY OF NONPUBLIC PERSONAL INFORMATION
		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.

	YOUR RIGHT TO OPT OUT OF CERTAIN INFORMATION SHARING WITH AFFILIATES
	You may tell us not to disclose nonpublic personal information about you with 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 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 sharing information with 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.
	SPECIAL NOTICE FOR RESIDENTS OF VERMONT
	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.

	OPT-OUT FORM Exclude me from information sharing among your affiliates as described above. _______________________________________________________________________________ Name (please print) _______________________________________________________________________________ Address Apt # _______________________________________________________________________________ City State Zip Code _______________________________________________________________________________ Last four (4) digits of Social Security Number Detach this form, and mail it back to us at the following address: EACM Advisors LLC 200 Connecticut Avenue, 6th Floor Norwalk, CT 06854 Attn: Compliance Dept.

		Ver 11-2011

Terms And Conditions \| Privacy Notice \| Contact Us
Copyright 2012, EACM Advisors LLC. All Rights Reserved.