Effective 4/2019

Section I - General Privacy Policy

Protecting the privacy of your personal information is important to us. We hope that these policies regarding your privacy (the "Privacy Policy" or "Policy") demonstrate our commitment to making your experience on our Web site (the "Site") thoroughly enjoyable. This General Privacy Policy describes our overall privacy practices for the website. Section II is our privacy policy for nonpublic personal information used in the provision of financial services.

In the event we amend the Privacy Policy, posting the amended version will serve as notice to you of that change and the policy will note its effective date.

Some information collected is non-identifying. For example, although our website servers collect information about a user's internet protocol address, our server is not able to automatically associate that information with a particular user. We may collect non-identifying information associated with that address, such as the time and date of a visit, the originating domain name, the browser type, and the particular pages or products viewed on the website.

The website may utilize a "cookie." A "cookie" is a small text file that a website can place on your computer's hard drive or on your mobile device's memory in order to collect information about your activities on our website. Most browsers automatically accept cookies, but you have the option to change your browser to decline them. We use cookies on certain areas of our website, but these cookies are not used to identify anonymous website visitors. Our cookies enable you to proceed smoothly through our website and enable us to know whether you've used our website before to eliminate some steps that are directed to new visitors. Similarly, a cookie may be placed by our third-party advertising companies. These companies may use aggregated statistics about your use of our website and third-party websites, which may be used to provide you with advertisements about goods and services that you may be interested in. The information they collect does not include your personal information.

Image tags work in conjunction with cookies. An image tag, also referred to as a clear GIF or web beacon, is a small image file that may be located on select areas of our website.

The third-party advertising companies may also employ technology that is used to measure the effectiveness of ads. Any such information is anonymous. They may use this anonymous information about your visits to this and other sites in order to provide advertisements about goods and services of potential interest to you. No personal information about you is collected during this process. The information is anonymous and does not link online actions to an identifiable person. At this time, we have contracted with companies to collect information about how users navigate our website. This information will not be disclosed and will be used only to generate anonymous visitor profiles, which do not contain personally identifiable information.

This Site uses Adobe® Site Catalyst to help us measure the use of the Site or tailor our online ads based on the likely interests of our users. You can opt out of the use of Adobe cookies for these purposes by clicking here: Opt Out.


With respect to unrelated, third party web sites, such as third party online retailers, advertisers, or unrelated sites that we may happen to link to, or web sites that link to our website, those third parties may collect personal information directly from you. The information policies and practices of these unrelated parties are not covered by this privacy policy. We do not control the privacy policies of third parties even if we may provide hyperlinks or other access to their web sites. We are not responsible or liable for their independent policies and practices. Please review their privacy policies and practices. It is your responsibility to review them and decide if you are satisfied with their protections.

Our Site does not respond to browser-based, DO NOT TRACK requests.


We collect certain personally identifying information that users voluntarily provide to us. For example, we collect the email addresses of those who contact us by email. We also collect information that you voluntarily provide to us in surveys and online. As described above, we use that information to serve you, to improve the content of our website, and to contact you for marketing purposes. Third parties may collect, process, and/or share the personal information you submit on the website. As a reminder, if you provide personal information to us for the purposes of a financial service, the please see Section II for the applicable privacy policy.


We take commercially reasonable steps to protect the information we collect online. However, as effective as these measures are, no security system is impenetrable. We do not provide an absolute guarantee of the security of our information databases, nor do we guarantee that the information you may choose to supply will not be intercepted while you transmit it from your computer, over the internet, or along other third party networks, and to our systems. However, with respect to security: when we intend to transfer and receive certain types of sensitive information, such as financial information, we redirect visitors to a secure server.

We work with analytics companies to help us understand how our websites are being used, by how many users, for how long, and how frequently. Using analytics, we receive counts of the screens and features of our website that are used, the countries from which they are used, device language settings, demographics and interests information, including age, gender, and affinity categories, and the types of devices, operating systems, browsers, carriers, IP addresses and wireless connections our users are using.

We maintain presence on several social networking and blogging platforms, such as Facebook, and we also incorporate some third party social networking features onto our website. Through these platforms and features, we may receive some usage information about you, and this Privacy Notice applies to that information as well. In addition, third party social networking platforms and blogging platforms have their own privacy policies which explain how the third parties that provide them will use and protect your information.

 Section II - Financial Privacy Notice