PRIVACY STATEMENT

Why do we gather information?
There are several very important purposes. We collect information required to educate you on our products and services, verify and authenticate users accessing confidential data and to safeguard your privacy. But we also continually strive to improve our services and provide you opportunities to use additional products and services you may find of interest. To do this, we gather information to help us assess your needs and preferences. This may include conducting surveys that ask you to provide demographic information and other means to aid us in anticipating your needs and satisfying your requests.

What information do we collect?
The information we collect directly from you includes information required to communicate with you, including your name, mailing address, telephone number, e-mail address, fax number, social security number and your employer name and address.

To assess your investment experience and suitability, we may also collect your approximate annual income, approximate net worth, and other information to help us assess your financial position. We may also collect demographic information when you logon or request information through our site, including gender, birth date, education, occupation, etc.

In addition we may indirectly collect information from you, including your IP address, browser type, operating system, ISP, time stamps, and pages visited. We do this through the use of cookies, which are small text files sent from the Web server to your computer. Cookies help us to know you better by providing operational data we can use to aid your interaction with our web site and improve its navigation and usability.

When do we obtain information?
You directly provide us the majority of information we collect. You do this by completing the information request form and related documentation, sending us an e-mail for questions or comment or submitting information in response to a promotion or special offer. Other ways we may obtain information are by 1) observing your usage of our web site, 2) providing products and services to you, and 3) through other sources such as affiliates and business partners. This information enables us to offer you products and services that we feel may be of interest to you.

How do we use your personal information?
Again, the trust of our clients is our most valued asset. Therefore, we use personal information only as appropriate to provide you quality service and increased security.

For example, Markpoint may use the information collected from you to verify your identity and contact information. We may also use this information to establish and set up and issue you an account number and a secure password, maintain your portfolio and investment activity, and contact you with account information. This information helps us improve our services to you, customize your browsing experience and inform you about additional products, services or promotions that may be of interest to you.

Markpoint may also use demographic information provided by others on our clients so that we can develop products and services for our clients.

What information does Markpoint share with affiliates and with alliances and partners?
Markpoint may share information with affiliates if the information is required to provide the product or service you have requested or to provide you the opportunity to participate in the products or services our affiliates offer. Markpoint may also forge partnerships and alliances with other companies who offer high quality products and services that might be of value to our clients. In order to ensure that these products and services meet your needs and are delivered in a manner that is useful and relevant, Markpoint may share some information with partners, affiliates and alliances. This allows them to better understand the offers that are most relevant and useful. We may also compare our client lists with those of our partners and affiliates to ensure that they are not sending messages to you if you've elected not to be so notified. In our strategic relationships, we will require that it be identified that an offer is being extended because of the relationship with us. The use of your personal information is limited to the purposes identified in our relationship with the partner or affiliate.

Do we share the information collected with any other third parties?
The cornerstone of Markpoint's Privacy Statement is the commitment to keep our clients' personal information confidential. Markpoint does not sell, license, lease or otherwise disclose your personal information to any third party for any reason, except as noted earlier and as described below:

To help us improve our services to you, we may engage another business to help us to carry out certain internal functions such as account reporting, fulfillment, client satisfaction surveys or other data collection activities relevant to our business. We may also provide a party with client information from our database to help us to analyze and identify client needs and notify clients of product and service offerings. Use of the information shared is strictly limited to the performance of the task we request and for no other purpose.

Periodically, we may invite you to participate in advertisements, promotions and special offers offered by Markpoint or by other sponsoring organizations. These could include retailers, airlines and Internet service providers. Your participation may require us to gather and share your personal information or may require you to supply personal information to the promotion sponsor. For example, a referral program may require that we provide your name as a reference to a prospective client. It is always your choice whether or not to participate.

All third parties with which we may share personal information are required to protect personal information in a manner similar to the way we protect personal information. Examples of information shared are identifying information such as name, mailing address, e-mail address, telephone number, and information on account activity.

If at any time you choose to purchase a product or service offered by another company, any personal information you share with that company will no longer be controlled under our Privacy Policy.

Markpoint also reserves the right to disclose your personal information where required by law to regulatory, law enforcement or other government authorities. We may also disclose your information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property.

Does our Privacy Statement apply to the sites to which we link?
No. We are not responsible for the privacy policies or the content of sites we link to and have no control of the use or protection of information provided by you or collected by those sites. Whenever you elect to link to a linked Web site, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third party and you should familiarize yourself with the privacy policy provided by that third party.

What steps do we take to protect our clients' personal information?
We have made a significant investment in leading-edge security software, systems, and procedures to offer you a safe and secure browsing environment. While no security system is absolutely impenetrable, we have taken steps to review, refine and install security technology to protect our client’s personal information.

When you open an account with us, you are issued a unique account number and a password or personal identification number (PIN) to access your account information. Only a limited number of Markpoint employees who have a need to know this information will have access to both your account number and password or PIN. Remember: you are ultimately responsible for maintaining the secrecy of your account number and password or PIN. We strongly recommend that you do not disclose this information.

On our web site, we also use an industry standard encryption technology known Secure Socket Layer (SSL) protocol to encrypt information transmitted by or to you through our web site. In order to activate this technology, you need to utilize a browser like Netscape Navigator® or Microsoft® Internet Explorer 4.0 or higher. We recommend that you choose a browser with strong encryption capabilities.

What about "cookies" and other tracking devices?
We use cookies to assist us in securing your information and to enhance the performance of our web site (cookies are small text files sent from the Web server to your computer.) The Markpoint web site uses a common technique, HTTP-header cookies, to identify one-page request from another. The cookies this site creates do not contain any personal information nor do they contain account or PIN information. While your browser may allow you to "reject" cookies, activating this setting may prevent you from viewing certain sections of our web site.

Cookies may also be placed by third parties when you access their sites through linking from this web site. We do not have access to these cookies or any information that these cookies may contain. Please contact the third party site for more information on these cookies. Although we encourage third parties to adhere to appropriate privacy policies and standards, we are not responsible for the actions or policies of such parties.

Markpoint may share web site usage information about visitors to our web site with reputable advertising companies for the purpose of targeting our Internet banner advertisements on this site and other sites. For this purpose pixel tags (also called clear gifs) may be used to note the pages you've visited. The information collected by the advertising company through the use of these pixel tags is not personally identifiable.

Can I opt out of sharing my personal information with non-affiliated third parties?
Yes. As previously discussed in our Privacy Statement, we may disclose non-public personal information to non-affiliated third parties. However, you may direct us not to disclose non-public personal information to certain non-affiliated third parties.

If you want to opt out of sharing of non-public personal information with non-affiliated third parties, please send an e-mail to info@markpt.com with the words "opt out" in the subject line and your Markpoint account number and/or name in the body copy. In so doing, you will be identified as a client whose non-public personal information is not to be shared with an unaffiliated third party.

NOTE: You cannot opt out of the disclosure of non-public personal information if we need to disclose the information to effect, service, administer or process a transaction, product or service you have authorized or requested; to protect against fraud, liability or damages to property; to respond to judicial process; or in connection with settling a transaction.

Can I opt out of receiving certain information?
Yes. If you want to opt out of receiving direct communication from Markpoint, please send an e-mail to info@markpt.com with the word "unsubscribe" in the subject line and your Markpoint account number and/or name in the body copy. In doing so, you will be identified as a client who prefers to not be contacted by us through direct communication for additional product and services offerings or inquires. This opt out will not apply to communications required under law or regulations.