We Take Important Steps to Help Safeguard the Personal Information We Collect About You.
At UBS, we are committed to safeguarding your personal information. This notice describes: - The types of personal information we may collect about you
- The purposes for which we use the information
- The circumstances in which we may share the information
- The choices you have with regard to sharing and use of the information
- The steps that we take to safeguard the information to protect your privacy
As part of our normal business practices, we distribute our policy annually or when significant changes are made to it. This notice is being provided on behalf of UBS Financial Services Inc., all partnerships and registered funds managed by UBS Financial Services Inc.'s Alternative Investment Group,1 UBS Financial Services Incorporated of Puerto Rico, UBS Trust Company of Puerto Rico, UBS Bank USA, UBS Credit Corp., UBS Trust Company, N.A., UBS International Inc., and their insurance agency affiliates and subsidiaries. This notice applies to personally identifiable information about a consumer's or an individual's current or former client relationship with these companies. If your relationship with us is part of an employee stock benefit plan, please see "Special Note for Clients With Limited-Purpose Employee Stock Benefit Plan Accounts Administered by Us" below for specific information about these types of accounts. Why and How We Collect Personal Information
We collect personal information to enable us to provide products and services to you and to improve and conduct our business. For example, we collect personal information to: - Help us evaluate your financial needs
- Process your requests and transactions
- Inform you about products and services that may be of interest to you
- Provide you with effective and efficient customer service
- Assess products and services
We collect information from a variety of sources, including: - Account applications and other forms that you submit to us, which provide information such as your name, address, e-mail address, telephone number, date of birth, Social Security number or other tax identification number, occupation, financial goals, assets and income
- Your transactions or experiences with us and our affiliated companies
- Outside companies, such as credit bureaus, regarding your credit history or employment status
- Your employer, if we have been engaged to provide stock benefit administration services on its behalf
Who Has Access to Personal Information
Only those employees who need to have access to personal information to perform their jobs are authorized to use your personal information. They may need access to your personal information to conduct business on your behalf, service your account, help you and your Financial Advisor pursue your financial objectives, and to conduct our business. How We Safeguard Your Personal Information and Protect Your Privacy
UBS is committed to protecting the privacy and confidentiality of your personal information. Employees who have access to your personal information are required to maintain and protect the confidentiality of that information and must follow established procedures. We maintain physical, electronic and procedural safeguards to protect your personal information to comply with applicable laws and regulations. Why and How We Share Information With Our Affiliates
We may share your personal information (as described above in "Why and How We Collect Personal Information") with our affiliates as required or permitted by applicable law. Our affiliates are companies controlled or owned by us, or companies that control us, such as our corporate parent, UBS AG, or are under common control with us. For example, we may share information with our affiliates in order to:
- Process transactions relating to your account
- Service your account
- Provide you with information about products and services
We may share with our affiliates your name, contact information and information about our transactions and experiences with you so that they and we can efficiently service your account(s) and conduct our business. For example, we may share this information with one of our affiliates to facilitate a transaction on your behalf or conduct maintenance of your account(s). We also may share with our affiliates personal information that was collected to determine your eligibility for products and services you previously requested from us. This "eligibility information" includes information used to determine creditworthiness, such as net worth, income or credit history. As an example, we may share your eligibility information with our affiliates in arranging specialized services such as asset management, advisory, and trust services. In addition, we may share your personal information with our affiliates, including both transaction and experience and eligibility information, so that they may offer products or services that may be appropriate for you. As one example, we may share your personal information with our bank or mortgage affiliates so that they could offer their products or services directly to you. You have a right under some circumstances to instruct us not to share certain eligibility information and/or personal information with our affiliates. For more information on this right, please read the "How You Can Direct How Your Information Is Shared and Presented" section below. Why and How We Share Information With Nonaffiliated Third Parties
We do not and will not rent or sell your personal information. However, we may share your personal information (as described above in "Why and How We Collect Personal Information") with companies that we hire to perform services for us, such as vendors that provide data processing, computer software maintenance and development, transaction processing and marketing services. In addition, to help us service your account or to offer products and services that may meet your financial needs, we may share your name, contact information, and information about our transactions and experiences with you with nonaffiliated financial service institutions with which we have agreements to market financial services or products that we jointly offer, endorse or sponsor. Nonaffiliated financial service institutions include mutual fund companies, securities brokers, clearing brokers and banks. In the two cases above, the nonaffiliated companies and nonaffiliated financial service institutions with which we share your personal information are required to limit their use of such information to the particular purpose for which it was shared and they are not allowed to share your personal information with others except to fulfill that particular purpose. Finally, we may disclose personal information to others, including nonaffiliated companies, credit bureaus and regulatory authorities, as either required or permitted by applicable law. For example, we may disclose personal information to: - Comply with investigations by regulatory authorities or law enforcement agencies
- Protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liabilities
- Respond to judicial or legal process, such as subpoena requests
How You Can Direct How Your Information Is Shared and Presented
Our ability to share information with our affiliates helps us and them to more readily provide you with quality products and services to meet your financial needs and goals. Nevertheless, to respect your wishes with regard to how we share and use your information, we offer "opt out" alternatives. These permit you to direct how your information is shared with our affiliates, in some cases how those affiliates use the information, and how the information is presented in statements and periodic "playback" mailings. If you have a joint account, your direction for us not to share personal information with our affiliates and for those companies not to use your personal information for marketing will be applied to all account holders on that account. Eligibility Information Sharing With Our Affiliates
If you do not want us to share eligibility information (see "Why and How We Share Information With Our Affiliates" above for a definition of "eligibility information") about you with our affiliates, you may opt out of these disclosures. That is, you may instruct us not to share eligibility information with our affiliates. Please note that, even if you direct us not to share eligibility information with our affiliates, we may still share your personal information — including eligibility information — with our affiliates as permitted by law, for example, to process transactions or to service your account. Moreover, we may also share certain other types of noneligibility information with our affiliates, such as your name, address, telephone number, e-mail address and account number(s), and information about your transactions and experiences with us. If you wish to opt out of the disclosure of eligibility information, please call your Financial Advisor at the toll-free number listed on your account statements. Marketing From Our Affiliates
You may limit our affiliates' ability to market their products and services to you based upon your personal information that they receive from affiliated UBS companies. Please note that even if you limit our affiliates' use of your personal information for marketing purposes, there are exceptions. For instance, a UBS company with which you maintain a relationship may still offer you information about its products and services. Your choice to limit marketing offers will apply until you tell us to change your choice. If you have already made a choice to limit marketing offers from other UBS companies, you do not need to act again. If you wish to opt out from our affiliates' use of your personal information for marketing purposes, please call your Financial Advisor at the toll-free number listed on your account statements. Statement Householding
As a convenience to you, we may consolidate some or all account statements with the same address in the same envelope. This practice is known as "householding." Accounts may be added to or excluded from householding as clients move to or from the address to which the householded account statements are sent. Additionally, the individual selected to receive the householded account statements may also change over time. Where owners of joint accounts live at different addresses, the statements will be sent to at least to the address of one account owner, and if householding is already in place at that address, then such joint account statements may be householded with any other householded account statements sent to that same address. If you wish to opt out of householding, please call your Financial Advisor at the toll-free number listed on your account statements to receive individual statements mailed in separate envelopes. Periodic 'Playback' Mailings
After a new account is opened, whenever your investment objectives or financial information is updated, and on a periodic basis during the year, we confirm your personal information in your statement to verify that our records are correct. These mailings, known as "playbacks," confirm certain account information such as date of birth, employment status and annual income. If you are concerned about other account holders in your statement household (as outlined above in "Statement Householding") viewing this information, you may call your Financial Advisor at the toll-free number listed on your account statements and request that your playbacks be mailed in separate envelopes. Special Note for California and Vermont Accounts
Additional requirements beyond federal law are imposed by Vermont and California law for residents of those states. Accordingly, we do not share information with third parties for accounts with a primary mailing address in those states except as required or permitted by applicable federal and state law. To comply with California and Vermont laws, we do not household account statements without written consent for accounts with a primary mailing address in California or Vermont. Therefore, these accounts are automatically opted out of statement householding. Additionally, Vermont accounts are automatically opted out of the sharing of eligibility information and use of personal information for direct marketing by our affiliates (as described in "How You Can Direct How Your Information Is Shared and Presented" above). If this paragraph applies to your accounts and you would like to have your statements householded or receive marketing communications from our affiliates, please contact your Financial Advisor at the toll-free number listed on your account statements. Accessing and Revising Your Personal Information
We strive to keep our customer files complete and accurate. We encourage you to review information in account statements and notify us if you believe any information should be corrected or updated. If you have questions or concerns about your personal information or this privacy notice, please contact your Financial Advisor at the toll-free number listed on your account statements. Special Note for Clients With Limited-Purpose Employee Stock Benefit Plan Accounts Administered by Us
If your relationship with us is solely through a limited-purpose employee stock benefit plan account, we share personal information only for the purposes of administering and providing stock benefit plan services. These limited-purpose accounts are excluded from sharing of personal information with our affiliates and nonaffiliated third parties except in connection with performing those services or completing transactions authorized by you, or for regulatory or legal purposes. For example, we share information with mailing vendors that produce statements and confirms on our behalf, but we do not disclose your personal information to affiliates or nonaffiliated third parties for marketing purposes. Accordingly, these accounts have been opted out automatically from the sharing of eligibility information and direct marketing by our affiliates described in "How You Can Direct How Your Information Is Shared and Presented" above. Because your plan sponsor provides us with your personal information, please contact your personnel or human resources department for changes to your personal information.
Last updated: July 1, 2008
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