Douglas C. Lane & Associates, Inc. (DCLA™) places a high priority on the confidentiality of our clients, and we are committed to safeguarding your privacy.  We understand your concerns about protecting the confidentiality of your personal and account information and want to assure you that we have taken steps, and will continue to take steps, to maintain the privacy of such information. 

What personal information do we collect?

To better serve you and manage our business, it is important that we collect and maintain accurate information about you and your account.  Generally, we obtain this information from materials that you provide to us and from reports regarding transactions for your account provided by third parties.  For example, we obtain:

·         Personal information such as your address, phone number, date of birth and social security number, and other documents that you submit to us;

·         Security transaction reports from brokers who execute trades for your account; and

·         Account valuation information from the custodian who holds the assets we manage for you.

Is your personal information disclosed to others?

We do not provide your personal information to any other affiliated or non-affiliated third party unless permitted by law or you specifically ask us to do so.  Permitted disclosures include the provision of transaction information to both the custodian for your assets and brokers who execute trades for your account.  In addition, if you so direct us, we will provide information about your account to your accountant, attorney or other financial service provider. 

How do we protect the confidentiality and security of your personal information?

We restrict access to your personal and account information to those employees of DCLA™ who need to know such information in the course of their job responsibilities.  Those individuals have an obligation to keep such information confidential and to use it solely for the purposes of performing services on behalf of your account.  We also have procedures in place to maintain the physical and electronic security of the information we collect about you and your account. 

If you have any questions about this policy or would like to update your account information, please call or e-mail Gay Lane at (212) 262-7670 or glane@dclaonline.com.

Again, we are confident that we have taken every essential precaution to shelter your privacy.  We have always been faithful to our clients in respecting their confidentiality, and we will continue to do so.

Revised 04/14/2008