MELLON CAPITAL MANAGEMENT CORPORATION WEB SITE PRIVACY STATEMENT

Mellon Capital Management Corporation ("Mellon Capital") takes the matter of privacy very seriously. This statement outlines our commitment to ensure that all information you, as a user of our Web site, share with us will be handled with care and respect for your concerns about privacy.

INFORMATION COLLECTED
As a visitor to Mellon Capital's Web site, we will necessarily collect information about you or your organization if you voluntarily choose to respond to our online surveys, send us an email, request information or ask to be contacted by one of our representatives. We respect the privacy of your children and do not knowingly collect or retain personally identifiable information from children under the age of 13 through our Web site.

If you provide us with information about yourself or your organization in the course of inquiring about the services offered by Mellon Capital, that information will be used by us only for the purpose of responding to your query. If you contact us via e-mail, please be aware that those e-mail communications will not be encrypted and, therefore, we cannot guarantee the security of the information you transmit and you will be doing so at your own risk.

If you inquire about employment opportunities posted on our Web site, or if you send us your resume electronically or by other means, we will hold your query in confidence and use the information you provide to us only for the purpose of responding to your interest.

During your visit to our Web site, some information (so-called "cookies") may be created to facilitate your navigation within our Web site, improve the presentation of our Web site and personalize your visit to our Web site. A cookie may store information about the browser on your computer to facilitate interfacing with it, but it will not retrieve other information about your computer or the programs on it. We may also utilize cookies to understand and measure visitors to our Web site. We hope that such information will enable us to improve our Web site. If you prefer not to accept cookies and set your browser accordingly, you may experience difficulties when visiting our Web site, including not being able to log into the password-protected area of our Web site.

USE OF COLLECTED INFORMATION
Mellon Capital uses information that you provide during a visit to our Web site to respond to your specific requests, to provide the best possible service to you, including providing the latest information about products and services offered by Mellon Capital, and to comply with any applicable legal and/or regulatory requirements. We also may maintain a log or record of the communications between you and us via our Web site to ensure that proper and timely follow-ups to your request or comments have occurred and to measure our Web site's effectiveness as a communications vehicle.

Certain employees of Mellon Capital may be given the information you provide to us via our Web site in order that they may respond to your requests. Such employees are instructed to use strict care in handling the information you have given to us and to share it with others only on a "need to know" basis for purposes of serving your interests. All employees of Mellon Capital are subject to BNY Mellon's Code of Conduct, which provides disciplinary sanctions including dismissal for failure to conform to the Code of Conduct's confidentiality rules.

A proper response to your queries or comments may require that they be forwarded to one or more unrelated entities. In such cases, we forward only the information about you or your organization that is necessary to ensure proper handling of your interests. Otherwise, Mellon Capital will not share your personal information with unaffiliated third parties without you consent unless required by law or regulation. Mellon Capital may share your personal information with its affiliated entities. Mellon Capital does not share information about you or your organization with third party vendors of marketing information services or mailing lists.

Mellon Capital may revise this Privacy Policy at any time by the posting of the revised Privacy Policy on the Web site. Please check the Privacy Policy from time to time for such revisions. If you have specific questions regarding this Privacy Policy or any information you have sent via the Mellon Capital Web site, please do not hesitate to send us an e-mail.

THE BANK OF NEW YORK MELLON CORPORATION POLICY ON THE PROTECTION OF SOCIAL SECURITY NUMBERS

“We” refers to the family of companies owned by The Bank of New York Mellon Corporation.

Like all financial services companies, we collect a variety of information about individuals, including but not limited to our customers and employees.  In many cases that information includes individuals’ Social Security numbers.  We use records of Social Security numbers for many purposes, especially to comply with federal and state laws such as tax laws and anti-money-laundering laws.

Our policy is (i) to comply with all laws restricting the use and disclosure of Social Security numbers, (ii) to protect the confidentiality of Social Security numbers, (iii) to prohibit the unlawful disclosure of Social Security numbers, and (iv) to limit access to Social Security numbers to our employees, and in certain cases to nonaffiliated parties that provide services to us, based on their responsibilities.  To safeguard Social Security numbers, we maintain physical, electronic, and procedural safeguards that are designed to comply with applicable legal standards.  Our employees are prohibited from disclosing Social Security numbers for unauthorized purposes.

We may share Social Security numbers among our affiliated companies or with nonaffiliated parties for administrative purposes, such as to process transactions, verify identities, and service accounts.  We disclose Social Security numbers as required or permitted by law, such as to the Internal Revenue Service or to credit bureaus.  When necessary, we disclose Social Security numbers to regulatory agencies, law enforcement agencies, courts, and parties to lawsuits.

We may share Social Security numbers among our affiliated companies for marketing purposes, but only in compliance with legal restrictions, including required opportunities to opt out of such sharing.  We do not, without consent of the individual involved, share Social Security numbers with parties not affiliated with us to enable them to market their own products or services.

Last updated: September 29, 2008