When we refer to "Contact Information" we mean your name, address, telephone number, employment status, fax number and e-mail address. "Personal Nonpublic Information" refers to personally identifiable information about you and transactions in your account, including your social security number, account numbers, and information about your assets, accounts, transactions and tax status.

 What information does ShareBuilder collect?
In order to provide financial services to you, we will ask you to provide Contact Information and Personal Nonpublic Information. We will collect Personal Nonpublic Information about you from applications or other forms, your transactions with us, correspondence between you and ShareBuilder and, in some cases, consumer reporting agencies, demographic marketing companies and third parties with whom we jointly market financial products or services.. We collect information about usage of our web sites (for instance the number of visitors that click on advertisements and links displayed upon our site), and reserve the right in the future to link such usage information to Contact Information or Personal Nonpublic Information for each customer or visitor to our web sites in order to better understand which information or services are of more value to our customers.

At times, we conduct online surveys to better understand the needs, profiles and experiences of our customers and visitors to our web site. Participation in such surveys is strictly voluntary.

How does ShareBuilder use this information?
We may use your Contact Information and Personal Nonpublic Information to service your accounts with us, to communicate with you about your accounts, to obtain your views on the quality of our services, and to bring to your attention new products and services that we are offering or that are offered by a third party with whom we jointly market financial products or services. We may also use Contact Information from time to time to offer to you other promotional opportunities. If you do not wish to receive communications about new products and services, you may "opt out" by updating your Personal Profile as described below.

 Will ShareBuilder share my information with others?
ShareBuilder does not, in conducting its business, sell information about its customers and we will only share your information under very limited circumstances - always under strict controls against further disclosure. We may share your Contact Information and Personal Nonpublic Information with (i) third parties with whom we have an agreement to jointly market financial services or products, such as our co-brand credit card, and (ii) third parties that perform services for us or you, for example, with outside vendors who assist us in sending communications, shareholder reports and proxy materials to you, vendors who provide marketing services on our behalf, securities transfer agents who effect transactions in securities on your behalf, and trust companies that assist us in providing products to you such as our Individual Retirement Accounts. We require these vendors to keep your information confidential and we prohibit them from using your information for their own purposes.

We also may share Contact Information and Personal Nonpublic Information with certain banks and credit unions whose web sites link to "co-branded" versions of our ShareBuilder product, identified with that bank's or credit union's name, logo and other graphics. If you open your ShareBuilder Account through one of these co-branded ShareBuilder web sites, most likely hosted by your own bank or credit union, except where prohibited by law, we may share your Contact Information and your Personal Nonpublic Information with that bank or credit union in order to protect you from fraud, to monitor and enhance the success of our co-branded ShareBuilder program with that bank or credit union and to provide you with new product features. Additionally, if you open a ShareBuilder Account by linking to us from a company's investor relations website, except where prohibited by law, we may share your name and e-mail address with that company. In all cases, our agreements with third parties require them to keep your information confidential and prohibit them from using your information for other purposes.

In addition to the above, we may disclose Contact Information and Personal Nonpublic Information to unaffiliated third parties when, in our good faith judgment, one of the following circumstances exists:

1. Where necessary for security purposes, to protect against fraud or unauthorized transactions, to resolve customer disputes or inquiries, or to respond to requests from persons who are acting in a fiduciary or representative capacity for you, or who hold a legal or beneficial interest in your account;
2. To perform necessary credit checks or collect or report on debts owed to us; or
3. As permitted by applicable law, including in response to legal process or to our regulators.

If you close your account with us, we will retain information about you and your account in an "inactive" status. We will not use Contact Information or Personal Nonpublic Information about inactive customers for any purpose other than as required in order to carry out our responsibilities with respect to the inactive account.

How does ShareBuilder use cookies?
"Cookies" are elements of data that a website can send to your browser and store on your computer. Our cookies do not collect or contain personal information about you or compromise the confidentiality of your personal information.

Our system automatically gathers information about the areas you visit on our sites and about the links you may select from within our site to other areas of the Internet or elsewhere online. We use such information in the aggregate to understand how our users as a group use the services and resources provided on our sites. This way we know which areas of our sites are favorites of our users, which areas need improvement, and what technologies are being used so that we may continually improve our sites. We may link such usage information to Contact Information or Personal Nonpublic Information in order to securely verify your identity, to personalize aspects of your experience on our web sites and to better understand which information or services are of greater value to our customers.

We may share aggregated statistical information with our partners, suppliers and other third parties, but we will not share any individual names, personal navigational or other personal information.

We may use third-party advertising companies to serve ads on our behalf. These companies may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous. If you would like more information about this practice and your choices, click here.

You can choose whether to accept cookies by changing the settings of your browser. You can reset your browser to refuse all cookies, or allow your browser to show you when a cookie is being sent. You can also erase cookies already stored on your computer. If you choose not to accept these cookies or if you erase them, your experience at our site and other web sites may be diminished and some features may not work as intended. For more information on working with cookies, you should consult the User Manual, FAQ or Help function of your specific browser and operating system software.

While you are browsing our web sites, you might be directed to web sites operated by third parties. These other web sites may send their own cookies to you and collect data or solicit personal information. We do not control and are not responsible for what third parties do on their separate web sites, or how they handle information about you.

ShareBuilder also uses the services of Coremetrics to provide additional tracking and analysis of Web site browsing and usage of our Web sites in order to better understand how our customers and other Web site visitors use our Web sites and the services we offer. Although ShareBuilder does not allow Coremetrics to capture or transmit any transactional information, banking information, credit card information or other personal financial information, the data collected does include your email address and a unique customer identifier that ShareBuilder (not Coremetrics) can use to associate the data collected with individual customers. We use this data in order to continually improve our Web site and the services we offer, and also to help us deliver the most relevant products and services to our customers. If you wish to opt out of the collection of such data through Coremetrics, see "What are my opt out rights?" below.

What are my opt out rights?
You may choose to not receive information about new products and services from ShareBuilder, as well as other information that we provide for the educational benefit of our customers. To do so, simply click on Account Profile on the web site and amend your Email Preferences to check the box stating that you do not wish to receive such information. Even if you choose to "opt out", you will continue to receive notifications concerning transaction activity in your account, account statements, tax information and other matters relevant to your brokerage account or required by law. Your opt out election will remain in effect until you amend your Email Preferences by checking the box stating "Yes, please keep me up to date." In the case of joint accounts, your election to opt in or out covers all persons listed on the account.

If you would like to deactivate our ability to analyze your browsing behavior through the use of Coremetrics' web analytics services or wish to find out more about Coremetrics, including its privacy policy, click here.

Maintenance of accurate information.
We strive to insure that the personal information we maintain about you is accurate, current, and complete. We will respond to your requests to correct inaccurate information in a timely manner. If you ever find that your personal or account information is incomplete, inaccurate or not current, you should update your Account Profile by clicking on that link on the web site or, if appropriate, by contacting Customer Care through the Customer Care link on the web site.

Security.
ShareBuilder takes the security of information very seriously and has established security standards and procedures to prevent unauthorized access to customer information. We use industry standard means such as physical, electronic and procedural safeguards, including data encryption and secure socket layer technology. We update and test our technology regularly to maintain and improve the protection of our customers' information. We restrict access to personal information to employees and service providers for legitimate business purposes to assist in providing services to you. Employees who violate our privacy policy are subject to disciplinary action.