Freedom Investments, Inc. is a wholly owned subsidiary of Oppenheimer & Co. Inc. located at 125 Broad Street, New York, New York 10004. Freedom Investments owns and operates the BUYandHOLD website.

How We Use and Protect Your Personal Information

Freedom Investments, Inc. shares your concerns about privacy. We understand that you want to know how we treat the personal information that we obtain from you or other sources in the course of providing you with products and services, including those of our Freedom Investments and BUYandHOLD websites.

As our customer, you may be wondering...

• What do we do with the personal information we have about you?
• What kind of personal information do we have, and where did we get it?
• How do we protect that information?

We hope this notice will help answer those questions. We want you to know that we respect the privacy of our customers. We apply the same rules to former customers as current customers. We require all of our customers to log in to the Freedom Investments or BUYandHOLD website before they are permitted to gain access to their account information. You must enter your unique username and enter your personal password in order to log into our website. Ultimately, you are responsible for keeping your password secret, which means that you should not tell anyone what your password is. We recommend that you change your password regularly by going, at anytime, to the View Accounts page and entering a new password.

What do we do with the personal information we have collected about you?

Freedom Investments does not disclose your personal information to companies or organizations not affiliated with us that would use the information we have provided them to contact you about their own products and services. The BUYandHOLD website is a self-directed investment website, as a result no financial consultant of Freedom or its affiliates may use your personal information for investment purposes or to help you with your overall investment program. Freedom or its affiliates may use your personal information to communicate with you about products or investments that you have expressed an interest in or that we believe may be of interest to you. In addition, we may, as permitted by law and without your prior permission, provide personal information about you contained in our records or files to persons or organizations such as: persons who perform a business function for us, regulatory or law-enforcement authorities, or our affiliated companies.

What kind of personal information do we have, and where did we get it?

Much of the personal information that we have about you comes directly from you. You disclosed much of this information on your new account application or other documents, which you have provided to us. We may have contacted you by telephone, email or mail for additional information. We also keep information about the investments you purchase from us, account balances and payment history. We may also collect personal information from outside sources, including consumer-reporting agencies. This information may include credit reports.

Depending on the nature of your relationship with us, you may be required to provide us or our affiliates with certain information. That information may include, for example, your name, address, birth date, phone number, Social Security number or E-mail address.

How do we protect your personal information?

When we share personal information with companies working on our behalf, we protect that personal information where required by law with a confidentiality agreement that obligates those companies to conform to our standards and keep confidential any information about you that we give them. Within Freedom, your personal information is available to those individuals who may need to see it to fulfill and service your needs. We also protect your information from those individuals who have access to it, through established physical, electronic, and procedural safeguards. Finally, should your relationship with Freedom end, your personal information will remain protected in accordance with our privacy practices as outlined in this policy.

We may provide aggregate statistics about our Freedom and BUYandHOLD website customers, traffic patterns, and related site information to outside parties (i.e., third party partners, industry analysts or the media); however, these statistics will not include personally identifiable information or account information about any of our individual customers.

From time to time, BUYandHOLD may run special offers and promotions from our third party partners. However, we will not provide any of your personal information to these partners without your authorization or unless you choose to accept or participate in the offer or promotion.

In addition, we may sell, buy, transfer, exchange, or merge all or a portion of a business or an operating unit. In such proposed or actual transactions, nonpublic personal customer information may be shared and may be one of the transferred business assets.

How we use "cookies" and other electronic devices on the BUYandHOLD website.

A "cookie" is a small file stored on your computer by a website which gives you a numeric user ID and stores certain information about your activity on the site. We use cookies and other electronic devices to establish a user session and monitor certain usage while you are on our site. Your usage is tracked primarily so that we can (i) if necessary, modify the website according to your usage to make the information you are looking for easier to find in the future, (ii) maintain sufficient hardware, software and personnel to provide you with a high level of service, and (iii) let third parties know about certain usage on our site. The cookies and electronic devices passed to you are seamless, do not reveal your personal identity, will not follow you as you surf on to other websites. The electronic devices may allow third parties to identify your usage on our website with your consent to accrue or recognize incentives or bonuses provided by the third parties to you in connection with your activity on our website. Most web browsers automatically accept cookies, but most allow you to instruct your browser to prevent the use of cookies. However, if you disable this feature, certain aspects of our website may not function properly.

Third-party Advertising

We use third-party advertising companies to serve ads when you visit our website. These companies may use information (not including your name, address, email address, or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here.

Security

As explained above, we restrict access to personal information about you to those employees who use the information to provide products or services to you. We maintain physical, electronic, and procedural safeguards to guard your personal information. For example, we use secure server software when you place buy or sell orders, transfer money or access your account information, as well as fire walls and secure socket layers, when appropriate. However, "perfect security" does not exist on the Internet and you should take necessary precautions to protect your information.

Your Account Information; Corrections

To view your account information; you must first login. Freedom Investments customers that would like to update or correct personal information previously provided must call our toll free number for additional instructions. BUYandHOLD customers must go to the View Accounts page at any time to change their e-mail and/or home address and password. All other changes can be made after you select "View" for a specific account. Certain requests to change personal information must be received in written form with applicable legal documentation.

Links to Third Party Sites

If you choose to click on certain links on this website, you may link to third party websites. The linked sites are not under the control of Freedom or BUYandHOLD, and neither Freedom nor BUYandHOLD are responsible for the contents of any linked site or any link contained in a site. These links are provided for your convenience in accessing other sites that may be of interest to you, and the inclusion of any link does not imply endorsement by Freedom or BUYandHOLD of any such linked site or its contents. Any opinions or recommendations expressed on such sites are solely those of the providers of such websites and are not the opinions or recommendations of Freedom or BUYandHOLD. If you decide to access any third party sites linked to or from our website, you do so entirely at your own risk. You should note that the privacy policy of the third party will govern the use of the information that you provide to that party and the use of that party's website. Of course, our privacy policy no longer applies to the information that you provide to the third party or the use of that party's website while you are on that party's website.

Your Consent and Changes to this Policy

Subject to the above provisions, by using our website, you acknowledge that this privacy policy is part of our Copyright and Other Legal Terms Agreement and you agree to be bound by all of its terms and conditions. If we decide to change our privacy policy, we will post those changes on this page and changes will become effective upon posting.If you have any questions or would like more information, please don't hesitate to contact us in writing at: Customer Service, BUYandHOLD, c/o Freedom Investments, Inc., 375 Raritan Center Parkway, Edison, NJ 08837 or via the Internet at: service@buyandhold.com.