INFORMATION WE COLLECT ABOUT YOU ONLINE

We want you to get the most out of your visits to our website, so we make certain offers and services available to you, like secure online account access and management options. When we provide you with these and other online tools, we will, from time to time, request that you provide us with your personal information, such as your name, address, email address and telephone number.

Website users: We will ask you for certain contact information when you register for online services and products, or request information online.
 

• Clients/Individual Investors: If you choose to register for the site, you will be asked to provide the following personal information: name, email address, Social Security number, fund and account numbers and phone numbers (optional). We may use the information to provide you with secure online account access or services or products you may request.

• Financial Professionals: If you choose to register for the site, you will be asked to provide the following personal information: name, firm name and email address.  We may use the information you provide to enhance your website experience in the future. See "Tracking Activity on Our Website" below for more information.

We will maintain information about your account, online account activity, online services and products requested and your usage of our website to help us administer your online account needs and to continually improve your online experience by providing you with customized relevant information.

TO PARENTS OF CHILDREN UNDER 13: We do not knowingly collect data online from or market online to children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe that personal information may have been collected from your child, please read "How we use the information we collect" below. For more information about the Children's Online Privacy Protection Act (COPPA), visit the FTC website: www.ftc.gov.

HOW WE USE THE INFORMATION WE COLLECT

Whether you are a new website user or a client, we use personal information collected on our website to handle the transactions you initiate and provide services you request. In some instances, we will share your contact information with carefully selected service providers to assist us in processing your online transactions or to deliver the services and products. For example, to mail you statements, we will supply your contact information to a third-party vendor who will process and mail the statements and other materials on our behalf.

We may disclose personal information collected on our website when disclosure is required or permitted by law. For example, we may be required to disclose personal information to cooperate with law enforcement and regulatory authorities, as part of a sale, merger or similar change of business, or to perform authentication procedures to prevent fraud.

TRACKING ACTIVITY ON OUR WEBSITE

To enhance the quality of your visit to our website, we track website activity. The information we gather helps us:

• Develop a better understanding of website activity to improve our site offerings
• Resolve issues clients may encounter in using our website, including the submission and completion of online transactions
• Monitor against fraudulent activities
• Provide you with customized and relevant information and offers

We may gather information such as:

• Your name, address, email address, mobile and home telephone number
• Your IP address, browser type and version
• Which pages you view; which page, if any, linked you to our site; and which link, if any, you follow when leaving our site

Cookies:  A "cookie" is an electronic file that holds small strings of text. When you visit our website, we send a cookie to your browser so that we can recognize it when you or another user of your computer returns to our website. For example, when you first visit our website, we present an introductory page designed for new users. The fact that you have already visited the introductory page is recorded in a cookie so you won't see the introductory page again. For your security, if you are registered for online services or have an account with us, we cannot give you access to your account information on our website unless your browser is set to accept cookies from us.

Browser settings: You can adjust many browser preferences so that you are alerted when a cookie is placed in your browser, or adjust preferences to decline cookies altogether. Keep in mind that cookies enable you to visit our website without reviewing introductory information. In addition to allowing us to recognize you, cookies also enable us to securely provide our registered users with account information.

Response to web browser "Do Not Track signals": While most modern web browsers include a "Do Not Track" setting, we do not currently respond to these signals. Using the "Do Not Track" setting will not prevent tracking across the networks of websites and online services in which we participate. If we do respond to these signals in the future, we will describe how we do so in this privacy policy. For more information about how to control data collection from your browser, visit the Digital Advertising section of this privacy policy.

HOW WE USE YOUR EMAIL ADDRESS

We recognize that email can be the preferred mode of communication for some of our website users. If you provide us with your email address when registering for an online service or product or when accessing your account online, we will use it to contact you about your account or online services and products for which you have registered.

We may use your email address to send you the following types of email messages:

• Services for which you are enrolled
• Optional email communications for which you have registered (e.g., newsletters on a selected financial topic)
• Occasional updates about our products and services as well as Columbia Threadneedle Investments marketing offers

Also, once you have requested information from us, we may communicate with you via email regarding your request to provide additional information related to your initial information request. However, we will never ask you to send personal information such as account or Social Security numbers by non-secure email. We do not share your email address with non-affiliated companies for them to market their products or services directly to you.

DIGITAL ADVERTISING

We may partner with ad networks and other ad serving providers ("Advertising Providers") who serve ads on our behalf, as well as for others on non-affiliated sites. Some of those ads may be personalized based on information Advertising Providers collect about your use of our applications, visits to this site, and elsewhere over time to provide ads relevant to your interests. These partners may use cookies, web beacons, or other similar technology to collect this information from our websites.

 

You may visit www.aboutads.info or www.networkadvertising.org to learn more about this type of advertising that occurs in your browser, and how to opt-out of it for companies participating in the Digital Advertising Alliance (DAA) self-regulatory program or the Network Advertising Initiative, respectively. We adhere to the DAA Principles. In addition, some Advertising Providers participating in the DAA may also collect data from our applications and others that you use. You can exercise choice with respect to these Advertising Providers via DAA AppChoices, which is available from the major app marketplaces. You may also be able to use your device settings to help limit data collection for this type of advertising. For iOS devices, you may be able to set "Limit Ad Tracking." For Android devices, you may enable "Opt-out of interest-based advertising".

 

Note that electing to opt-out will not stop advertising from appearing in your browser or applications. It may make the ads you see, however, less relevant to your interests. In addition, note that if you use a different browser or erase cookies from your browser, you may need to renew your opt-out choice. Even after you opt out via the DAA or NAI, Advertising Providers may continue to collect data from your browser or application for other purposes, including analytics and reporting.

 

WEBSITES THAT WE LINK TO

Websites to which you link from our site may contain privacy provisions that differ from the provisions of our Privacy Statement. To ensure your privacy is protected, we recommend that you review the privacy statements of other Internet sites you visit.

HOW WE SAFEGUARD YOUR INFORMATION

We realize how important security is to you, so we've taken steps to enhance the protection of personal or confidential information sent to or from us over the Internet. First, we require that a "secure session" be established, using Secure Socket Layer (SSL) Technology. This is done any time you supply or access personal or confidential information in one of our secure online areas.

SSL Technology is intended to create a private conversation that only your computer and our systems can understand. The SSL Technology encodes information as it is being sent over the Internet between your computer and our systems, helping to ensure the transmitted information remains confidential. The use of SSL requires two components: an SSL-compatible browser and a Web server to perform the "key-exchange" that establishes a secure connection to our web server systems. In addition, all our secure sites require that your browser support 128-bit encryption.

Second, many areas of the site require the use of a user ID and password as an additional security measure that helps protect your confidential information. This allows us to verify who you are, thereby allowing you access to your account information while seeking to prevent unauthorized access. When you have finished using a secure area of our website, make sure you always click on the "Log Out" link which appears on the top of every secure page. When you click on it, no further secure transactions can be conducted without re-entering your user ID and password. This also helps prevent unauthorized access to your account if you walk away from your computer.

You should be aware that browser software often "caches" a page as you look at it, meaning that some pages are saved in your computer's temporary memory. Therefore, you may find that clicking on your "Back" button shows you a saved version of a previously viewed page. Caching in no way affects the security of your confidential user ID or password. If you use a computer in a public place to access your account information, simply quit/exit the browser software before leaving to minimize the possibility of anyone else viewing your confidential information.

Lastly, our computer systems are protected by a firewall that seeks to block unauthorized access. This means that no one without the proper web browser configuration can view or modify information contained on our systems. Only authorized people – employees, advisors, approved contractors, etc. – are authorized to use our computer systems, and only people who need to know confidential client information are assigned access to that information.

HOW YOU CAN PROTECT YOURSELF ONLINE

Spyware, anti-virus and firewall software

Spyware is software that is installed on your computer without your consent to monitor the way you use your computer. It can be used to display pop-up ads, send you to websites you did not mean to visit, monitor the websites you surf or record keystrokes, meaning the software could record your usernames and passwords.

Clues that spyware may have been installed on your computer

• Onslaught of pop-up ads
• Your browser taking you to sites you did not enter in the address box
• A change to your Internet home page that you did not make
• New toolbars
• New icons in your browser window
• Keys that don't work properly
• Random error messages
• Slow performance when opening programs or saving files

Tips to help protect your computer from spyware

• Update your operating system and Web browser software to make sure you have the latest protection
• Only download free software from sites you know and trust
• Don't install any software without knowing exactly what it is
• Set your security setting to at least "medium" to avoid unauthorized downloads
• Avoid links in pop-up windows
• Don't click on links in spam that claim to offer anti-spyware software
• Install a personal firewall to stop uninvited users from accessing your computer

How to get rid of spyware

If you think your computer might have spyware on it, follow these steps:

• Get an anti-spyware program from a vendor you know and trust, choosing one that can undo changes spyware makes to your system.
• Set it to scan on a regular basis — at least once a week — and every time you start your computer, if possible.
• Delete any software programs the anti-spyware program detects that you don't want on your computer.
• Source: onguardonline.gov
• Anti-virus software and a firewall can help protect you when you make financial transactions online.

Anti-virus software works by removing or quarantining suspected viruses. It's best to choose one that updates regularly so that you don't have to worry about making sure the software is up to date. A firewall functions much like a fire door in a building by denying unauthorized parties access to your computer or network. It is important to set up your firewall properly.

PERSONAL INFORMATION AND PHISHING

Phishing refers to the unlawful and fraudulent attempt to acquire sensitive information, such as usernames, passwords, Social Security numbers and credit card information. Phishers send email or create pop-up windows posing as reputable companies, such as Internet service providers (ISP), banks and online payment services, and ask consumers to update, validate or confirm account or other personal information on a website that looks legitimate.

Consider these tips to help you avoid phishing scams

• Use anti-virus and anti-spyware software and a firewall. Some phishing emails contain software, such as spyware, that harm your computer or track your activities on the Internet. Anti-virus software and a firewall can protect you from inadvertently accepting such unwanted files.

Don't email personal or financial information

• Regular email is not a secure method of transmitting personal information. Some companies, including us, offer a secure email service that you can use when you need to exchange sensitive information.

Use caution when opening attachments or downloading files from email

• These files can contain viruses or other software that can weaken your computer's security.

Report phishing attempts to the company being impersonated

• Most organizations have information on their websites about where to report suspected phishing incidents. To report an incident to us, you can email us at service.inquiries@columbiathreadneedle.com.

If you have any questions or concerns about this Privacy Statement, please write us at:

Columbia Threadneedle Investments
P.O. Box 8081
Boston, MA 02266-8081

FORMER CUSTOMERS

If, for whatever reason, our customer relationship with you ends, we will preserve your information as necessary to comply with applicable laws. The measures we take to protect the privacy of customer information will continue to apply to you.

We reserve the right to change this Privacy Statement, and any of the policies described herein, at any time. The examples contained in this Privacy Statement are illustrations; they are not intended to be exclusive.