Privacy Policy

PRIVACY POLICY - HOW WE USE AND PROTECT YOUR PERSONAL INFORMATION

In connection with providing financial services to you, our clients, it is necessary for Oppenheimer & Co. Inc. ("Oppenheimer") to collect items of nonpublic, personal information ("personal information") about you. Oppenheimer knows the importance of maintaining the privacy and confidentiality of your personal information. This Policy addresses Oppenheimer's treatment of client personal information and answers the questions most clients have regarding such treatment.

WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT/MAINTAIN AND FROM WHERE DO WE COLLECT IT?

When opening your account, Oppenheimer will collect information about you such as your name, age, address, citizenship, marital status, phone numbers, e-mail address and Social Security/Taxpayer Identification Number. Additionally, Oppenheimer collects background information, information concerning your creditworthiness and your credit history from consumer reporting agencies and other outside vendors when opening your account. Furthermore, in order to provide you with services and products best suited to your financial needs, Oppenheimer will collect information such as income sources, assets, financial/investment goals/objectives, and investment experience from you.

Oppenheimer collects much of your personal information directly from you. This is via your new account application, other documents that you may be asked to submit from time to time and through correspondence such as telephone calls or electronic mail. We also collect certain personal information (background information and credit history) from outside sources, including third party vendors who perform background checks and verify identities and consumer reporting agencies. Lastly, Oppenheimer collects/compiles information from your account records, such as what investments you hold, the transactions taking place in your account and your account balances.

HOW IS YOUR PERSONAL INFORMATION UTILIZED?

Oppenheimer uses your personal information in a variety of ways in connection with providing you with services to meet your financial goals and needs. As already stated, we use your information to establish your account here. Federal laws and regulations including, the Patriot Act, require financial institutions, like Oppenheimer, to obtain and maintain certain information about their clients. In addition, your financial advisor will use this personal information for investment purposes, to help you with your overall investment program and to communicate with you about products or investments that you have expressed an interest in or that they believe may be of interest to you.

From time to time, in the course of providing these services, Oppenheimer may share your personal information with nonaffiliated parties. Among the nonaffiliated third parties we may share your information with are: service providers that we use to generate statements or reports on your accounts, vendors who verify your creditworthiness or identity, companies we use to process transactions in your account, companies that provide marketing services for us and entities that provide legal or consulting services to Oppenheimer. Furthermore, Oppenheimer may enter into joint marketing agreements with nonaffiliated third parties. Please note that, in these cases, Oppenheimer only shares your personal information with nonaffiliated third parties after entering into a contractual relationship that: (1) limits the nonaffiliated third party from using your personal information for any purpose other than the purpose Oppenheimer intended and (2) requires the nonaffiliated party to keep your personal information confidential.

Additionally, Oppenheimer may also share your personal information to nonaffiliated third parties where permitted by law.

Occasionally, your personal information like your creditworthiness may be shared with companies that are affiliated with Oppenheimer in connection with marketing of their products or services.

In certain cases you may "opt out," of information sharing. Please see the section entitled OPTING OUT OF INFORMATION SHARING to learn when and how you can instruct Oppenheimer not to share your personal information.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

Oppenheimer has procedural, physical and technological safeguards that protect against loss or unauthorized disclosure of your personal information.

Procedurally, Oppenheimer employees are bound by, and held accountable to, a code of conduct and policies regarding confidentiality and the treatment of client information. Furthermore, only those Oppenheimer employees who require access to your personal information in order to provide customary services (investment, administrative, legal) to your account are granted access to your personal information.

Physically, Oppenheimer has policies that require our employees to store and destroy documents containing your personally identifiable information in accordance with federal guidelines.

Technologically, Oppenheimer uses methods such as encrypting files, locking down access to client information to prevent removal from the firm and masking of data on computer screens to protect your personal information.

As previously mentioned, before Oppenheimer shares your personal information with a nonaffiliated third party (other than for legal or regulatory purposes), we require that party to enter into a contractual agreement that limits the use of your personal information and requires that party to maintain the confidentiality of your personal information.

Finally, should your relationship with Oppenheimer end, your personal information will remain protected in accordance with our privacy practices as outlined in this Policy.

OPTING OUT OF SHARING YOUR INFORMATION

Oppenheimer reserves the right to disclose or share your personal information with the above-described nonaffiliated third parties, for the above-described purposes as permitted by applicable federal laws and regulations.

You may, however, instruct Oppenheimer not to share information with our affiliated companies about your creditworthiness or for marketing purposes, for purposes other than servicing or maintaining your account, as described above. Below is a description of how you may opt out of that information sharing.

You may also opt out of information sharing with nonaffiliated parties except in those circumstances described above. Below is a description of how you may opt out of that information sharing.

For your convenience, Oppenheimer provides several methods for you to opt out of sharing your information in the above circumstances and as permitted by law. You may:

(1) Contact the Financial Advisor who services your account and provide him or her with written instructions to add your name to Oppenheimer's "Opt Out" list; or

(2) Send an email to us at: optout@opco.com with your name and account number requesting that your name be added to Oppenheimer's "Opt Out" list;

REVISED POLICIES

This Policy may change from time to time to reflect changes in our practices and in regulations concerning the collection and use of personal information. Oppenheimer customers will receive notification of any revisions or changes to this policy. If you have any questions or would like more information, please do not hesitate to contact your Financial Advisor.