At Ira Epstein & Company (IECO) and its affiliates, maintaining client trust and confidence is a high priority. We understand that you are concerned with how we treat nonpublic information ("Client Information") that we obtain from you or from other sources about you in the course of providing you with our products and services. Privacy is an important issue both for our valued clients as well as visitors to our website. For this reason, we want you to understand how we work to protect your privacy when we collect and use information about you and the steps we take to safeguard that information.

General Information About Browsing IECO's Website

At IECO, no account or personal information is retrieved from IECO's servers when a client or visitor browses the public, pre-login areas of our website. Although IECO uses website data to improve the content and services offered to its website visitors, such data is reported on an aggregate, anonymous basis. We associate no personal information with such gathering of data. Such data may include: how many people visit our website; the pages they visit; how long they stay on our website; and the domain name of the site visitors connect from (e.g., yahoo.com).

Cookie Information

Cookies are small text files that a website transfers to your hard drive or browser to help you move faster through that particular website, or are used for tracking your website usage. IECO does not use cookies to gather personal information such as a person's name or e-mail address. We do however, use cookies to identify repeat visitors to our website, to determine the path visitors take to our website and to identify visitors who came to IECO's website as a result of a Banner Advertisement on a third party website. Although your browser might allow you to 'reject' cookies, we require that you accept all cookies in order for our website's features and security mechanisms to function fully.

Third parties might also create cookies when you access their sites through links posted on our site. We do not have access to these cookies or any information that these cookies may contain. Please contact the third party site for more information on its policies regarding cookies. Although we expect third parties to adhere to our privacy policies, and terms and conditions of use, we are not responsible for the actions or policies of such third parties.

IECO Security Technology Concerning Credit Card Purchases

If you use a credit card to purchase IECO products, the credit card number is encrypted as it passes over the Internet. IECO uses several different vendors, including Verisign to address IECO credit card purchases. Your credit card number is not kept or recorded by IECO on our computers. Rather, it is simply passed through to the credit card company to purchase the product or software that we offer. IECO keeps no record of your credit card number.

Chatrooms

The IECO Chatroom area is not in our site environment. Any information divulged in the Chatroom may be observed by other people and should not be considered secure. Neither IECO nor its affiliates are responsible for the actions of our visitors in these Chatrooms. IECO and its affiliates are not responsible for maintaining the privacy of discussions carried on inside these environments. While your login may be on the Ira Epstein & Company website, iepstein.com, an IECO controlled environment, the User Name (User ID/Identity Name) may be passed to the Chatroom, which is not an IECO controlled environment.

A Word About Hyperlinks

IECO's website contains hyperlinks or 'links' to other web sites, and other web sites may 'link' to our website. Web sites linking to and from our site may have privacy practices different from IECO's. This Website Privacy Policy applies solely to information collected by IECO. IECO is not responsible for the privacy policies or the content of sites you link to. IECO has no control over the use or protection of information provided by you or collected by those sites. If you elect to link to a co-branded website or to a linked website, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third party and you should familiarize yourself with the privacy policy provided by that third party.

Nonpublic Personal Information

In the event visitors provide IECO with nonpublic personal information about themselves (e.g., name, address, phone number, e-mail address) for the purpose of receiving information about our products and services, or if you are an IECO client and we obtain from you or from other sources nonpublic personal information, the following sections describe the steps we take to safeguard such nonpublic personal information ("Client Information").

Security Procedures:

IECO restricts access to Client Information about you to:

• Those of our employees and affiliates who need to know that information in order to provide the products and services you receive from us.
• Those unaffiliated third parties whose access to such information is permitted or required by law and who need to know that information in order to assist us in providing you with the products and services you receive from us.
• Those unaffiliated third parties whose access to such information is necessary in order for IECO to engage in joint marketing efforts with such unaffiliated third parties

To protect the security of Client Information, we maintain physical, electronic, and procedural safeguards that comply with federal standards for guarding the information we collect about you (see IECO'S SECURITY TECHNOLOGY, above).

Information We Collect:

In providing you with financial products and services, or information about such services, IECO may collect the following types of Client Information:

• Information we receive from your account applications, whether written or electronic, or on other forms (including on-line forms). This information would include your name, address, social security number, income, investment experience, and so forth.
• Information about your transactions with us, our affiliates, or others. This information could include your trading through us, our affiliates and others, your history of meeting margin calls, and your use of the various products and services that we and our affiliates provide.
• Information about your credit worthiness, credit history, and other information about you that we receive from consumer reporting agencies, our affiliates, or providers of other demographic information, such as your purchasing or investment preferences.
• Information about you obtained in connection with our efforts to protect against fraud or unauthorized use of your account(s) with us.

Information We Disclose:

IECO or its affiliates may disclose to unaffiliated third parties with which IECO or its affiliates is engaged in a joint marketing arrangement, Client Information such as:

• Information we receive from you from your account application, whether written or electronic, or on other forms. This information would include your name, address, social security number, income, investment experience, and so forth.
• Information about your transactions with us, our affiliates, or others. This information could include your trading through us, our affiliates and others, your history of meeting margin calls, and your use of the various products and services that we and our affiliates provide.

Categories of Parties to Which We May Disclose:

IECO may disclose the types of Client Information listed above (see INFORMATION WE COLLECT) to the following types of third parties:

• Companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements to sell IECO products or services.
• Financial service providers, such as broker-dealers, futures commission merchants, investment companies, investment advisers, commodity trading advisors and commodity pool operators.
• We may also disclose Client Information to other nonaffiliated third parties as permitted or required by law, such as in response to a subpoena or legal process or in order to complete a transaction which you initiated and authorized.

Website Privacy Policy Updates:

IECO may, from time to time, make changes to this Website Privacy Policy. We recommend that frequent visitors to our website reread this Website Privacy Policy periodically to learn of any updates and changes we have made to this Policy. Should you become a IECO client, obtaining a User ID and Password by completing forms on-line or by other means we provide, we will notify you of any changes we make to this Policy in the following manner. The first time you logon to our website, after we have modified our Website Privacy Policy, you will be required to click-through our revised Website Policy. You will not be able to access the client areas of our website until you acknowledge receipt of the revised Privacy Policy.

Online Services:

If you register for our online products or services, we retain your User ID and Password and other information about your use of our website so that we may recognize you as a registered user. We may obtain your e-mail address from you or from another source. We may send you e-mail offers for our affiliates' products and services. We may also send you e-mails for third party products and services that we think may be of interest to you. All e-mail offers we send to you include an opportunity to opt out from future e-mail offers.

If you opt out from receiving e-mail offers, we may still send (via e-mail or otherwise) important information pertaining to your relationship with IECO and applicable products and service information.