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Privacy Policy At AST Capital Trust Company ("AST"), we are committed to safeguarding the privacy of information we maintain about you. We have established policies and practices that respect the financial privacy of all individuals who use our products and services. We believe it is critical to comply with the laws and regulations designed to secure your financial privacy. Your relationship with us as our client is very important to us and we want you to understand our policies and practices about handling your personal information.
This Policy applies to our relationships with individual clients with whom we have a relationship, as well as former clients.
Safeguarding your Information We take the security of information very seriously. We have established security standards and procedures to prevent access to client information. We maintain physical, electronic and procedural safeguards to guard client information.
We take precautions to ensure that the information we collect about you is protected and accessed only by authorized parties. We have established procedures to limit employee access to information to only those employees with a business reason for accessing such information. We educate our employees about the importance of confidentiality and client privacy. We take appropriate disciplinary measures to enforce employee responsibilities regarding client information.
Third parties we use to provide support services are not permitted to use information about our clients for their own purposes. Nonaffiliated parties are contractually obligated to use such information only to perform the services we request and to otherwise maintain strict confidentiality of such information.
Information We Collect About You We collect information about you to:
Accurately identify you
Protect and administer your records, accounts and funds
Help us provide you with better products and services
Understand your financial needs
Save you time when you apply for new products and services
Comply with applicable laws and regulations
We collect and maintain your personal information so that we can provide account management and other services to you. The types and categories of information that we collect and maintain about you include:
Information we receive from you to open an account and provide services to you (such as your home address, social security number, telephone, financial information, investment objectives and related information)
Information that we generate to service your account or from our transactions with you (such as account statements and other financial information)
Information on your transactions with nonaffiliated third parties to help us verify your identity and to better understand your needs
We have established procedures so that the financial information we collect is accurate, current and complete. We are committed to work with you to promptly correct any inaccurate information.
Disclosure of Information In very limited circumstances, we provide access to information about you to outside parties, including:
To nonaffiliated companies to help us service your account (such as providing account information to brokers and custodians or pursuant to an arrangement we have with another company in order to provide you enhanced services)
When requested or authorized by you
When required or permitted under law (such as to make required filings with governmental entities and to verify the identity of our clients)
We do not and will not sell your personal information to anyone or share your information with third parties for marketing purposes. If you terminate your relationship with us, we will continue to adhere to the privacy policies and practices described in this notice.
Last Updated: August 2005 Important Legal Information The information on this page includes important legal information governing the terms of use of this web site and regarding certain business programs that AST has implemented which may affect its clients.
Terms and Conditions of Use This web site is provided by AST Capital Trust Company ("AST", "we" or "us"). All references to this web site shall hereinafter include any affiliated web sites. AST has made the content of this web site available as a service to its clients and other interested persons. Such content is provided for general informational purposes only.
THE FOLLOWING REPRESENTS THE TERMS AND CONDITIONS OF USE OF THIS WEBSITE. PLEASE READ THESE TERMS AND CONDITIONS OF USE CAREFULLY. BY ACCESSING THIS SITE AND ANY PAGES THEREOF, YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OUTLINED BELOW. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS, DO NOT ACCESS THIS SITE, OR ANY PAGES THEREOF.
Certain sections of this web site may contain separate conditions of use, which are in addition to these Terms and Conditions of Use. Users should read those additional conditions of use carefully. In the event of a conflict, those additional conditions of use will govern access to and use of those sections. All documents and information contained on this web site are protected by copyright. Except as specifically provided herein, no documents or information on this web site may be reproduced in any form or by any means without the express written consent of AST. Third party trademarks, logos, and service marks appearing on this web site are property of their respective owners. All other trademarks, logos, and service marks are property of AST or a related entity of AST.
Unauthorized use of this web site, including, but not limited to, unauthorized entry into AST’s systems, misuse of passwords, or misuse of any information posted to this web site, is strictly prohibited. The information contained on this web site may be changed or updated without notice. AST may also make changes in the products and/or programs described in this web site at any time without notice to any party.
Except as otherwise specified elsewhere on this web site or as required by law, all information submitted to AST via this web site shall be deemed the property of AST and AST shall be free to use, for any purpose, any idea, concept, know-how or technique contained in information provided by any visitor to this web site AST shall not be subject to any obligations of confidentiality regarding submitted information except as otherwise specified in AST’s Privacy Policy or as required by law.
This web site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation.
Certain of the information contained on this site is provided by third parties. Although the information made available to you on this site is obtained or compiled from sources AST believes to be reliable, AST does not warrant or guarantee the timeliness, accuracy, completeness or applicability of such information. AST shall have no liability for any actions or investment decisions taken or made on account of such information, or on account of any other information contained in this web site. Except as otherwise indicated, AST does not sponsor, endorse, or approve the contents of any third party web sites and accepts no responsibility for information provided on any such sites. Except as otherwise specifically agreed in writing or as provided in any other applicable terms and conditions (i) nothing on this web site is an offer which can be accepted so as to create contractual obligations without further action by AST; (ii) AST provides no advice with respect to the use of the web site (including, without limitation, regarding the execution of transactions or any legal, tax or accounting advice or advice regarding the suitability or profitability of a security or transaction by means of the web site); and (iii) the web site is not intended as financial advice or as an offer, solicitation or recommendation of securities or other financial products, and users should obtain independent financial advice that addresses their particular investment objectives, financial situation and needs before making investment decisions. AST does not warrant that the functions contained in this web site will be uninterrupted or error-free, that defects will be corrected, or that this site or the servers that make it available are free from viruses or other harmful components.
ALL INFORMATION PROVIDED ON THIS WEBSITE IS PROVIDED ON AN “AS IS” BASIS. AST DOES NOT WARRANT THE ACCURACY, ADEQUACY, OR COMPLETENESS OF THE INFORMATION AND MATERIALS CONTAINED ON THIS WEBSITE AND EXPRESSLY DISCLAIMS LIABILITY FOR ERRORS OR OMISSIONS IN THE MATERIALS AND INFORMATION. FURTHERMORE, AST WILL NOT BE LIABLE FOR ANY DELAY, DIFFICULTY IN USE, FAILURE OR INTERRUPTION OF THIS WEBSITE, COMPUTER VIRUSES, MALICIOUS CODE, OR OTHER DEFECT IN THIS WEBSITE, ANY INCOMPATIBILITY BETWEEN THE WEBSITE AND THE USER’S FILES AND THE USER’S BROWSER OR OTHER SITE ACCESSING PROGRAM, OR ANY OTHER PROBLEMS EXPERIENCED BY THE USER. UNDER NO CIRCUMSTANCES WILL AST BE LIABLE FOR ANY DAMAGES, LOST PROFITS, LOST OPPORTUNITY OR ANY INDIRECT, CONSEQUENTIAL, INCIDENTAL, SPECIAL, PUNITIVE, OR EXEMPLARY DAMAGES ARISING OUT OF ANY USE OF OR INABILITY TO USE THIS WEBSITE OR ANY PORTION THEREOF, REGARDLESS OF WHETHER AST HAS BEEN APPRISED OF THE LIKELIHOOD OF SUCH DAMAGES OCCURRING AND REGARDLESS OF THE FORM OF ACTION, WHETHER IN CONTRACT, WARRANTY, TORT, (INCLUDING NEGLIGENCE), STRICT LIABILITY, OR OTHERWISE. AST PROVIDES NO REPRESENTATIONS AND WARRANTIES, EXPRESS OR IMPLIED, INCLUDING THE IMPLIED WARRANTIES OF FITNESS FOR A PARTICULAR PURPOSE, MERCHANTABILITY AND NON-INFRINGEMENT.
If you live in a state that does not allow disclaimers of implied warranties, this disclaimer may not apply to you. No license to the user is implied in these disclaimers.
All matters pertaining to accessing or using this web site shall be governed by, construed, and interpreted in accordance with applicable Federal law of the United States of America and the laws of the state of New York, without reference to the choice of law doctrine of that state. In the event any of the terms or provisions of these Terms and Conditions of Use shall be held to be unenforceable, the remaining terms and provisions shall be unimpaired and the unenforceable term or provision shall be replaced by such enforceable term or provision as comes closest to the intention underlying the unenforceable term or provision. AST reserves the right, in its sole discretion, to modify, add, or remove any of these Terms and Conditions of Use at any time without notice. Visitors should check this page for changes each time they visit this web site. Continued use of this web site following the posting of changes to these Terms and Conditions of Use will constitute acceptance of these changes.
Anti-Money Laundering Program As a financial institution, AST is subject to the USA PATRIOT Act which was enacted to help the government fight the funding of terrorism and money laundering activities. The USA PATRIOT Act requires that financial institutions establish a compliance program and system of controls designed to assist the government in these efforts. AST is dedicated to the fight against money laundering, and, to that end, has implemented a comprehensive program (“AML Program”) consistent with the requirements of law. AST’s AML Program includes:
A reporting system that allows us to detect and report suspicious transactions to the government and to ensure ongoing compliance with legal requirements;
An independent audit of the AML Program to test the effectiveness of the program;
A designated compliance officer to coordinate and monitor compliance on a daily basis; and specialized training for appropriate personnel.
The USA PATRIOT Act also requires all financial institutions to adopt a “Know Your Customer” identification program – this program should be designed to obtain, verify, and record information that identifies each client with whom the financial institution does business and to determine the source of funds in a client’s account. While we have always believed that we need to truly know our customers in order to best serve them, we have also implemented a “Know Your Customer” program compliant with the USA PATRIOT Act requirements. What this means for you is that, if you wish to open an account with AST, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.
While AST is committed to complying with the requirements of law, you may rest assured that your personal information will be protected and held confidential. Because your personal and financial data is your private information, AST holds itself to the highest standards in its safekeeping and use and has established policies and practices designed to ensure that your personal information remains confidential. Please review our Privacy Policy for how we protect our client’s confidential information.
Business Resumption Plan AST has always emphasized safety, security, and soundness as its core concerns. Maintaining the stability and viability of our clients’ data is of utmost importance. With this in mind, AST has established a Business Resumption Plan ("BRP") which will allow us to continue vital business operations in the event of an unplanned business interruption. AST is committed to employing all appropriate strategies for anticipating and controlling crisis situations.
To accomplish this, AST maintains an off-site co-location, which includes full backup of all data, daily differential backups, and real time replication of data and critical application databases. This facility also accommodates employee workstations for continued seamless operations.
All support data replication and disaster recovery capabilities are rigorously tested on a routine basis to demonstrate that AST is able to conduct all critical systems functions from the off-site location. Two-hour resumption of critical data processing operations, including all key operational and trading functions, is projected. Although we believe we have implemented a sound BRP consistent with industry best practices, we cannot be certain that we will be able to recover all of our systems in the event of a significant business interruption.
© 2007, AST Capital Trust Company of Delaware. All rights reserved.
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