At SWP Investment Management (SWPIM), we understand that your trust in us depends on how well we keep your personal, business and account information secure. We utilize industry accepted security practices that are appropriate for the way you choose to do business with us. No matter which channel you choose to take advantage of, we validate who you are before allowing you access to your accounts for your protection. Our systems employ the use of technologies such as firewalls and encryption to protect your information from other individuals. We take this seriously and keeping your information safe and secure is every employee’s responsibility. We also encourage you, the customer, to take steps in protecting your personal information. Please review our Privacy Policy for additional information. An excellent source of information on how to prevent identity theft and what to do if you are a victim of identity theft is the Federal Trade Commission’s Website at http://www.ftc.gov/idtheft. Our Privacy Policy Statement explains how we protect the privacy of your customer information and manage it carefully to provide financial products and services to you. Due to the unique nature of the Internet, there is some additional information you may wish to know when you visit http://swp-invest.com. This section describes the Internet-specific privacy practices governing swp-invest.com and supplements our corporate Privacy Statement.

How We Gather and Manage Information Online

When you use online (Internet) products and services, we may request information such as your e-mail address as well as for tracking purposes, such as site navigation, customer contact, optional surveys and other information. We use this information to respond to your requests, personalize our online services and improve our site to make it more responsive to your needs. See the topics below for more detail on the tools we use to serve you better. SWP requires the use of secure browsers to protect you while you access our online services as well as accessing your account(s) through our clearing firm, Charles Schwab and Fidelity. Secure browsers allow you, the customer, to communicate with SWPIM in a protected session by encrypting information that flows between you and SWPIM. To verify your session is secure, look for “https:” instead of “http:” on the URL, and a secure symbol (For example, closed padlock or key) on the status bar of your browser located on the lower part of the screen. For greater security when viewing your account information over the Internet, we recommend that you use a browser with 128-bit encryption.

Cookies

This term is used across the Internet to describe bits of information that some websites create when you visit their sites and are then stored on your computer. A cookie is uniquely yours and can only be read by the website that gave it to you. Cookies are a basic way to identify the computer you happen to be using at the time and does not identify you personally. They cannot be used to obtain data from your hard drive, your email address or personal information stored on your computer.

How Cookies Are Used

We use cookies for various reasons specified below. We do not collect any personally identifiable information from or store personal information in cookies. Cookies do not contain viruses. To facilitate online transactions, we use session cookies. Session cookies are necessary if you want to conduct online transactions or use specific services, such as Online Brokerage. Session cookies do not remain active after you log off the service, which requires their use. To evaluate our website, we may use cookies to facilitate online surveys or to track how visitors use our site, such as which pages are viewed the most. This information is used to improve the content, usability, and functionality of our website. Although these cookies remain on your computer after you log off, you may delete them from your computer at any time. If you have set your browser options to allow cookies on your computer, SWPIM will still treat the information supplied through these cookies, which do not contain any personal information, with the same security and privacy protections as any other client information we receive. We may contract with other companies to assist us in setting cookies or tracking technology for the purposes described above, and compiling and analyzing anonymous ad or web site response information. These companies are prohibited by legal agreement from using the information they gather for their own purposes or from sharing this information with others.

Do you have to accept cookies?

No; you can disallow cookies by making the appropriate selection from your browser options to inform you when cookies are sent or to prevent cookies from being sent. You should understand, however, that certain services require cookies for effective delivery. Therefore, if you set your browser options to disallow cookies, you may limit the functionality we can provide when you visit our site.

Additional Helps

While SWPIM continually provides security control to protect your information, we believe it is extremely important for you, our customer, to take responsibility for security too. The following are some ways that you can protect yourself and your accounts: Consider using a personal firewall to prevent hackers from invading your personal computer; especially if you are using DSL or a cable modem to access the Internet; Install virus protection software and scan all downloaded software as well as all disks before use. Also, do not accept e-mail attachments from unknown sources. When you are done with your transactions, always click on the logoff button on the site to exit out of the application. When using a public PC (such as in a library or school), close the browser when you are finished. Any links to websites outside swp-invest.com are provided for informational purposes only. We do not own, sponsor, or endorse these sites, nor are we responsible for their content.

E-mail From Other Sources

SWP takes your e-mail marketing preference seriously and will not send marketing messages if you tell us you do not want to receive them. Additionally, we will send you e-mail servicing messages only when necessary or at your initiation to quickly deliver important product enrollment, account or service information potentially requiring action on your part. Rest assured, when you receive such messages, they will be clearly marked as coming from SWP and will not request confidential information such as an account number, Social Security Number, permanent login name and/or access code to be provided and sent back through unsecured e-mail. Should you receive a suspicious message that appears if it may be coming from SWPIM, please let us know by calling 216-800-9000, or e-mailing us at [email protected]. You may also wish to contact your Internet Service Provider (ISP) for support in blocking e-mails or subscribing to a spam filter they may offer.

IP Addresses

When you enter swp-invest.com you pass through a “firewall” we use for security purposes. As you pass through it, we may identify the Internet Protocol (IP) address associated with the device you are using, such as a personal computer or handheld device. The IP address does not identify you personally, but it may allow us to identify the device you’re using. We store IP addresses in case we ever need to track a connection to its point of origin for security reasons.

Working With Other Companies

We work with a number of other companies to ensure that we’re providing the value and service you expect from a leader in financial and Internet services. Occasionally, you will notice on swp-invest.com that services are “Powered by,” “Provided by,” or “Developed by” content providers or technology service providers. We contract with these specialists to help us serve you better. We’re highly selective in choosing these companies, and they are only allowed to use your information for the purpose of providing the services we’ve contracted with them to provide.

Linking to Other Websites

Links to third-party sites are provided for your convenience. Such sites are not within our control and may not follow the same privacy, security, or accessibility standards as ours. SWPIM is not responsible for the products or services offered by, or the practices, content or availability of third-party sites, their partners, or advertisers. We encourage you to review the privacy policies of third parties before providing information on their sites.