Fiduciary Trust International

Privacy Policy

Fiduciary Trust Company International respects your privacy and is committed to protecting the information you have entrusted to us.

We at Fiduciary Trust Company International, including our subsidiary companies Fiduciary Trust International of California, Fiduciary Trust International of the South, Fiduciary Investment Management International, Inc., Fiduciary Trust International of Delaware, Fiduciary International Inc., and Fiduciary Trust International Limited ("FTCI," "we," "our," or "us") consider the responsible use of non- public personal information to be a critical element in providing services, including services through our website, to our clients. We are committed to protecting privacy and want to explain FTCI’s privacy practices.

This privacy statement identifies our privacy practices with respect to information about individuals who obtain or seek to obtain products and services from us for personal, family or household use ("Clients"). It is important that you read our entire privacy policy. In general, this statement identifies:

• the personally identifiable information about you that we collect;
• our policies for sharing that information;
• the security procedures in place to protect against the loss, misuse or alteration of information under FTCI control; and
• how you can correct any inaccuracies in the information.

If you feel that FTCI is not abiding by this privacy policy, you should contact PrivacyPolicy@fiduciarytrust.com, your account manager, or FTCI at the address or telephone number indicated in Section 5.

1. Information Collection and Use

We collect non- public personal information about our Clients from:

• information we receive on applications or other forms, such as name, address, birth date, Social Security number, email address, assets and income;
• information resulting from Clients’ transactions with us and our affiliates, such as account balances and transaction history; and
• information received from third party client intermediaries.

If you use fiduciarytrust.com, ftci.com, or ftciinvestorservices.com, we may also obtain general information from a "cookie." The cookie is a small file that is placed on your computer during your session to track your session and enable us to enhance your visit to our site. When you log out, the cookie is deleted and we store no information personally identifiable to you unless you have indicated on the Client Account Access page that you do not want to be asked a security question when you log in from the same computer during future visits. The computer must accept a cookie in order to skip the security question. In addition, our web servers automatically collect and store limited information about your computer’s connection to the Internet, including your operating system, browser, and network address. Your network address is logged to track your session but we do not link your network address to anything personally identifiable to you. We analyze this data for certain trends and statistics, such as the parts of our site that are visited and how long our visitors spend there.

If you are not a Client, but visit our website to learn more about FTCI, we do not collect any non- public personal information about you.

2. Sharing Information About You—Only as Permitted by Law

We may share the information we collect about our Clients and former Clients, as described above, with certain parties to provide you with better services.

Affiliates. We may share the non- public personal information that we collect about you with our affiliated companies, which may include our U.S. and non- U.S. affiliated companies, to better service your accounts and process transactions or services you have requested. From time to time we may also send you information about products and services offered by our affiliated companies although we will not share your non- public personal information with these companies for this purpose. These affiliated companies include all those companies that are directly or indirectly owned by FTCI or with whom FTCI is under common control and include providers of financial services, such as our securities broker/dealers, investment advisers, and a bank and trust company.

Nonaffiliated third parties. We may share non- public personal information about you with nonaffiliated third parties as permitted by law. Examples may include:

• parties that perform business functions for us and help us service your account. These parties have agreed that they will not use or disclose such information for any purpose other than the purpose for which the information was provided to them;
• parties that represent you (e.g., custodians, consultants, accountants or other third parties) at your consent or direction; and
• as may be permitted or required by, or as deemed necessary to comply with law, such as in response to or compliance with a subpoena or other legal or regulatory process or obligation, or to prevent fraud.

3. Access to Your Files

To provide superior service, we seek to keep Client files accurate, complete and current. You may at any time correct or update the file of your personal information as maintained by FTCI by contacting us using the contact information provided in Section 5.

4. Security

We handle your information securely. We require our employees to adhere to high standards of ethics and integrity in performing their jobs with us and conducting business on behalf of FTCI. We also require high standards of confidentiality from the service vendors that assist us. We maintain physical, electronic and procedural safeguards that comply with applicable standards and regulations to protect your non- public personal information.

If you are accessing our website, please view our Security Statement on our website at the bottom of each page, which explains how we secure data transmission between your computer and our servers.

5. Contacting Fiduciary Trust

We welcome your questions and comments about our privacy policy. You may contact us by delivery or postal service at:

Fiduciary Trust Company International
600 Fifth Avenue New York, NY 10020-2302
Attention: Privacy Policy

You may also contact our Privacy Officer by calling (212) 632-3000, during business hours, Monday through Friday, except for days on which banks in the State of New York are authorized to be closed, or by sending us an email at PrivacyPolicy@fiduciarytrust.com.

We ask that you do not send confidential information via a public e mail system.

6. Updating Our Privacy Policy

We will notify you annually of our privacy policy as federal law requires. While we reserve the right to modify our policy at any time, if any change materially alters our policy, we will promptly provide you with any advance notice required by law and, if applicable, the opportunity not to participate in any proposed disclosure changes. We will also post those changes on our website so our website users are aware of the information we collect, how we use it, and the circumstances under which we disclose any of it.

As of December 30, 2009