Privacy & Security

Consumer Privacy Notice

Privacy and Information Policy for Account Aggregation Service (Passportfolio®)

Consumer Privacy Notice

Privacy at Northern Trust - Keeping Your Finances a Private Matter
When it comes to your financial affairs, you expect a relationship built on privacy and integrity.

That's why Northern Trust does not sell client lists or any other client information to outside companies.

This notice outline what we do to protect your personal information and describes how you can limit the sharing of this information. If you already have instructed us not to share this information, you do not need to do anything. We will continue to honor your request.

Keeping Your Information Secure
To keep information confidential and appropriately protected, we have policies that limit access to your personal information to only those employees who need it to perform their jobs and provide services to you. We also maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your personal information.

Collecting Information

We collect information you provide us:

Sharing Information

Only under certain circumstances, and only as permitted by law, will we disclose any of this information about our clients and former clients to unaffiliated third parties, such as a corporation that performs marketing services and other services for us. In addition, we may share the information we collect about our clients and former clients with our affiliated financial institutions and we may share with other financial institutions with which we have joint marketing agreements.

Your Privacy Preferences
Northern respects your right to restrict the information we disclose to our affiliates and joint marketing partners for marketing purposes. You may direct us not to share certain information about you for marketing purposes by calling 1-866-260-9550, Monday through Friday, 7 AM to 7 PM Central Time; by writing to us at Northern Trust, P.O. Box 92929, Chicago, IL 60675; or by stopping in one of our locations.

If you have a joint account or have a guarantor of your account at Northern, we will assume your request applies only to your information unless you tell us.

Please note that even if you ask us not to share certain information for marketing purposes, we still may share that information for other reasons, such as to service your existing accounts. In addition, the Northern affiliate that originally collected the information still can use it for its own marketing decisions.

Keeping You Informed

This privacy notice applies to the Northern Trust family of corporation. If our information-sharing practices change, we will send you a revised notice. *Member FDIC

Private Passport Security

As a recognized leader in providing technology solutions to clients, Northern Trust continually evaluates the latest developments and strives to implement the latest in security technologies. We constantly review processes and procedures to ensure that the highest standards of controls and security are in place. Your account information is managed in a physically secure, state of the art data center. We have incorporated techniques to ensure that your account information is secure in transit between your computer and our data center. The information below summarizes the security framework in place and also summarizes your responsibilities as a user of Northern Trust Private Passport.

Your Computer
Northern Trust Private Passport requires that you use an SSL (Secure Sockets Layer) compliant browser. SSL is a protocol that allows your personal computer to establish a secure connection to our Internet server. We recommend the use of Netscape Navigator Version 4.06 or higher or Microsoft Internet Explorer Version 4.0 or higher set for 128 bit encryption. SSL uses encryption techniques that turn all information transmitted into a series of unrecognizable numbers as the information travels through the Internet. Our servers turn the meaningless numbers into recognizable information after the secure connection has been made. You can recognize if your session is encrypted by looking for the KEY symbol in the lower left corner of your screen in Netscape Navigator, or when the PADLOCK symbol appears in Internet Explorer. SSL also utilizes the additional protection of a digitally signed certificate that assures you that you are communicating with the Northern Trust.

Cookies
Northern Trust Private Passport utilizes "cookies." Cookies are small pieces of information that are sent from Northern Trust Private Passport to your browser. The software we use to run our web sites requires the use of cookies, but these cookies do not collect personally identifiable information. Instead, they are used to ensure secure online service while visiting our sites. The cookies only can be read by Northern Trust&146;s web sites and disappear from your computer once you close your Web browser.

Establishing a Session with the Server
Once a secure connection is made between your personal computer and Northern Trust's server, you will be prompted for a valid User ID and Password. The first time you sign on to Northern Trust Private Passport, you will be required to change the initial password provided to you during enrollment. Although we require you to select a six character password, we recommend a password length of eight characters. You must have at least one numeric character in your password. All numeric passwords are not allowed. We also recommend that you change your password often, with an interval of no more than 30 days between password changes. As additional security precautions, after 15 minutes of inactivity you will be required to re-enter your password and a limit is placed on the number of invalid sign on attempts. Three consecutive logon failures will result in suspension of your User ID requiring you to contact the Northern Trust Private Passport Help Desk for assistance.

The Server
After you have entered your User ID and Password, we will authenticate your sign on information and pass your request to the Northern Trust Private Passport server. This server is protected by firewall technology. The firewall protects the server against unwarranted intrusion and ensures that only approved customer requests are processed. Both the firewall and the server are in physically protected locations. All activity on both platforms is logged and monitored to ensure that no attempts have been made to breach security. After your request is processed by the Northern Trust Private Passport server, the information is encrypted and returned via the Internet to your personal computer.

Additional Security Tips
The following tips will further ensure secure usage of Northern Trust Private Passport:

Privacy and Information Policy for Account Aggregation Service

When it comes to your financial affairs, you expect a relationship built on privacy and integrity. You can trust Northern to meet and exceed these expectations.

We respect the premium you place on keeping your personal finances a private matter. That's why Northern Trust does not sell client lists or any other client information to outside companies.

In order to provide the account aggregation service, we will gather the information you authorize us to collect. We will not sell any of this information to any organizations outside the Northern Trust family of companies. We also have policies that limit access to your information to only those people who need it to perform their jobs and provide services to you. Please note, Northern employees in the locations where you opened your accounts or do business may use this information in making decisions about marketing Northern products and services to you.

However, you may direct us to not share this information with Northern's affiliates where you do not have accounts for their use in marketing decisions. You may direct us to not share this information with our affiliates by calling 1-866-260-9550, Monday through Friday, 7 AM to 7 PM Central Time; or by writing to us at Northern Trust, PO Box 92929, Chicago, IL 60675.

If you have asked that we not share your information with Northern affiliates after receiving a prior Privacy Notice from Northern, no action is necessary. We already have your preference noted in our records. You may view our general privacy policy by clicking on the Privacy & Security link at the bottom of any page.