At Security Capital Management, we recognize the importance of protecting your privacy and we have policies in place to maintain the confidentiality and security of your personal information.  The following policy is designed to help you understand what information we collect from you and how we use that information to serve your account, working on behalf of you, your family or business.

Confidentiality and Security:  We restrict access to non-public, personal information about you to those employees and agents who need to know that information to provide products or services to you.  We maintain physical, electronic, and procedural safeguards to protect your non-public, personal information.  All business relationships with third party entities are for the express purpose of assisting Security Capital Management in servicing client accounts and are governed by strict privacy guidelines that provide for information confidentiality.

Categories of Information that Security Capital Management Discloses and Parties to Whom Security Capital Management Discloses:  We do not disclose any non-public, personal information about our customers or former customers to anyone, except to comply with requests that have legal or regulatory force; that are authorized by the client, or are for the express purpose of maintaining or servicing a client account.

Categories of Information that Security Capital Management Collects:  We collect non-public, personal information about you from the following sources:

• Information we receive from you on applications or other forms;
• Information about your transactions with us, our affiliates, or others; and
• Information we receive from a consumer-reporting agency.

Internet Account Access:  If our customers visit the Security Capital Management internet web site, we may occasionally use a “cookie” in order to provide better service, to facilitate our customers’ use of the web site, to track usage of the web site, and to address security hazards.  A cookie is a small piece of information that a web site stores on a personal computer and which it can later retrieve.  We may use cookies for some administrative purposes, for example, to store our customers’ preferences for certain kinds of information.  None will contain information that will enable anyone to contact our customers via telephone, e-mail, or any other means.  If our customers are uncomfortable with the use of cookie technology, they can set their browsers to refuse cookies.  Certain of our services, however, could be dependent on cookies and our customers may disable those services by refusing cookies.

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