Smith Barney Online Privacy Statement

Keeping your personal information secure and ensuring your understanding of how we use that information is important to us. Our goal is to help you understand how the personal information you choose to share with us through this Web site is collected, used and maintained. You may review our Online Privacy Statement (“privacy statement”) at any time by clicking on the Privacy link appearing on the bottom of one or more pages of the Web site.

Registered Users
You can visit this site to read about our firm, its products and services, get market quotes, check for career opportunities, use our branch locator or other features, all without giving us any personal information about yourself. We may collect anonymous, aggregate information about how our site is accessed by you, such as IP address, domain name, time spent at the site or Web pages visited.

Categories of Information Collected
Registration Information
Some of the features on the site require registration before you can use them. If you register to use the site, you choose to provide us with certain personal information such as your name, address, email address and telephone number and agree to the Terms and Conditions governing this site. You can update registration information online. You may change your password at any time.

Service & Transaction Information
When you use a password or a similar identifier to access the site, we will recognize your identifier and may collect various categories of information about you such as information you give us, data related to your use of the site and its services (such as calculators, Watch Lists and other features), and information about your transactions, interactions, and communications with us.

Cookies
In addition to the online information that you voluntarily provide to us, we may use cookies and retain cookie information separately or with the information you provide to us online. A cookie is a small piece of data assigned to the browser on your computer when you visit a Web site. We may use cookies for various purposes such as maintaining continuity during a session, gathering data about the use of our site, storing preferences or recognizing return users. We may use cookies or other tracking technology to monitor our online promotions. (See “Online Advertising”) Your Web browser may alert you or permit you to refuse, disable or delete cookies. If you refuse cookies, you may not be able to use certain features or services on the site. For example cookies may be used to help complete or record a transaction or combined with your other data such as when you use tools or calculators so that we may retain online information for your use in subsequent sessions. For more information about cookies used on this site please see FAQs About Cookies.

Use of Collected Information
We do not sell or market your personal information or personalized data to unaffiliated organizations. The personal information you provide and the personalized data you create and save on the site is used to provide superior service to you and to inform you of products, services or other opportunities that may be available through our firm or our affiliates. This may include disclosure of such information to employees, representatives, officers, agents, affiliates, government and regulatory entities, third parties, and service providers. Such information and data will also be used to administer our business, the site, and our services in a manner consistent with this privacy statement, the Terms and Conditions that govern your use of this site and all applicable laws, rules, regulations, or other legal obligations. If you provide us with your name, address, telephone number, fax number, or email address, or have done so in the past, we or our affiliates may contact you by telephone, fax, mail or email. Our affiliates are in several different lines of business, including banking, consumer finance, insurance and securities. Nonaffiliated third parties are those not part of our family of companies and can include financial services providers, such as companies engaged in consumer finance and insurance and non-financial organizations, such as companies engaged in offering new products or services. Email or other electronic communications sent to us through the site will be maintained in a manner consistent with our legal and regulatory requirements regarding client and public communications.

Aggregate Information
If you anonymously visit or browse the site without registering or logging on with a User name, Password or other registration code, we do not collect your personal information (e.g., email address) unless you disclose it to us. We may collect aggregate, technical information that tracks site use including browser type, IP address, domain name, number or type of pages visited and time spent on the site. We may use such information in a variety of ways including analyzing trends, visitor interests or to improve the site.

Privacy Preferences
Your browser software may contain a feature intended to notify you of the cookie policies of the Web sites you visit. For example, the Microsoft® Internet Explorer 6 browser software contained in Microsoft® Windows® XP contains such a cookie-filtering device commonly known as P3P. General information about P3P can be found at www.w3.org/P3P. This site has attempted to be compatible with the P3P privacy-filtering tool. However, P3P is still an evolving standard. Therefore, we are not responsible for any problems you may experience when using a P3P filter, or any discrepancies between the machine-coded privacy statements which are read by the P3P tool and our human readable policies that you see referenced here, including this privacy statement and our privacy notice(s) for our individual clients, which are the controlling documents to which you should refer if you have questions about privacy and this site.

Electronic Authentication
Collection and use of information about you for pattern recognition and other authentication procedures are part of the log on process for clients registered to use the site. The process is intended to assess the authenticity of a request by registered users to access, transact business through or otherwise use the site. A combination of multiple authentication elements about you such as your individual and user information, transactional data, session surveillance, device fingerprint, IP information, and pattern recognition may be collected and used by us in a manner that will generally be transparent to you during your sessions on the site. If the authentication elements do not meet our satisfaction at any time as determined by us in our sole discretion you may be required to pass through additional authentication assessments such as supplying specific answers to challenge questions or other procedures. We will collect and use information from or about you for such assessments, procedures and other administrative and business reasons as we may determine from time to time.

Online Advertising
Our online advertisements may be posted by other companies on third-party sites that carry our advertising. These companies may set cookies and use related technology, such as encoded URLs or other tracking mechanisms that may note how Internet users respond to an online advertisement. For example, browsers that click on an online advertisement may be redirected to our site with an encoded URL or other tracking technology that may collect and store information about site visits, time spent or a specific advertisement. Generally reported as aggregate and anonymous data, such information can help us understand for example the performance of online advertising. Third-party sites that show our online advertising are often independent businesses that provide their own privacy statements. We are not responsible for such statements or sites. You should always review the privacy representations of those third-party sites that you visit before you use them and particularly before you share personal information.

Other Sites and Services
This site may contain links to other Internet sites not under our direction or control. This privacy statement does not apply to those sites. We are not responsible for such sites, cannot control how such sites use personal information, cookies or other data, and their representations do not apply to this site. You should always review the privacy representations of those sites that you link to before you use them and particularly before you share personal information. If you use other sections of this site that have additional privacy statements, those apply in addition to this statement to the use of that section or service as described.

smithbarney.com
Clients can review their accounts through statements, smithbarney.com or by contacting their Financial Advisors. Contact information such as our Internet or mailing addresses and telephone numbers are found on statements or other correspondence. Non-clients registered to use the site who provide personal data online can update it through the same online registration or other section of the site. There may be a charge for requested information. To protect your privacy, proof of identity or other authentication may be required.

Security
We maintain your personal information and data according to strict standards of security and confidentiality as described in the Terms and Conditions that govern your use of this site. Online access to your account portfolio is only possible through a secure (SSL capable) Web browser. SSL capable Web browsers support encryption technology, which helps prevent unauthorized users from viewing your account information as it travels over the Internet. Learn more about security.

Protection of US Social Security Numbers
Our businesses that collect US Social Security numbers in the course of business protect the confidentiality of such Social Security numbers, prohibit the unlawful disclosure of such Social Security numbers and limit access to such Social Security numbers.

Changes
We may change this privacy statement at any time. Any changes or updates will be effective immediately upon posting to this site. The effective date of this privacy statement, as stated below, indicates the last time this statement was materially changed. Checking the effective date below allows you to determine whether there have been such changes since the last time you reviewed the statement. This privacy statement does not supersede the Terms and Conditions that govern your use of this site. Any conflict between the two shall be determined in favor of such Terms and Conditions.

Questions
Your Financial Advisor can assist you or direct your inquiries on these matters. Otherwise, for further direction regarding inquiries concerning this privacy statement, you may contact our Help Desk by email or telephone as described on the site.

Effective Date
This online privacy statement was last modified: June 1, 2009.