As our client, you have trusted us to help you manage a critical area of your operations. To maintain that trust, we are committed to protect the privacy and security of the personal information we have about our clients, and our client’s accounts. This notice is intended to help you understand how we safeguard that information.

Disclosure of Information
We do not sell your information to anyone, nor do we use any information about your accounts for market research or any other research that is shared outside of MicroEdge or Advent Software. We do not share nonpublic information about our clients outside of MicroEdge and Advent Software, Inc. other than in one of the following exceptional instances:

• We disclose personal information to those third party companies, MicroEdge companies, and Advent Software subsidiaries that help us process or service your accounts. Examples of services are pricing information, market data, and technical support.
• We disclose personal information to other organizations with your consent or as directed by your representatives or agents.

Collection of Information
We limit the collection of information to that which is necessary to deliver our service to our clients. This service includes informing you of how we conduct our business, as well as any other opportunities that may be of benefit to you, including processing your account data for you and your agents and maintaining accounts and their corresponding data delivery and account reconciliation. We get most information directly from you, your custodians, and from MicroEdge or Advent Software, Inc., either in person, by telephone or electronically.

Information that we collect may include some or all of the following:

• Contact information of your employees or agents
• Grant application information
• Information that you provide to us on other questionnaires or forms

Safeguarding of Information
Our employees or anyone acting on our behalf are required to protect the confidentiality of information and to comply with our written procedures, and are subject to disciplinary action if they fail to follow these procedures. We have established policies to maintain physical, electronic, and procedural safeguards to maintain the security and privacy of all client data and information. Our employees access information only to service and manage your account data and to monitor the information as it relates to your contract with MicroEdge. We limit physical access to our facilities through the use of guard personnel and security systems. MicroEdge also requires that third party business partners agree to contractually comply with privacy laws.

Local and International Transfer of Personal Information
You should be aware that by using this and other MicroEdge websites, and by using services and products provided by MicroEdge, your personal information may be acquired into, processed in, or transferred to, computer systems residing in the United States of America, United Kingdom, or India. Other countries may be involved with data acquisition, data processing, or data transfers in the future. By using this website, you fully agree and affirmatively consent that any of your personal data that is collected by this website may be managed in this way.

Adherence to Safe Harbor (data transfers from the European Union to the United States of America)
MicroEdge confirms that it adheres to the Safe Harbor privacy framework when handling personal information that is transferred from member states of the European Union to locations in the United States of America. The European Commission and the US Department of Commerce have agreed to a data protection framework called the “Safe Harbor” that consists of a set of privacy principle documents and related FAQs. These documents describe how organizations that receive personal data from the European Union should provide information about purpose of collection (Notice), participation (Choice), Onward Transfer, Security, Data Integrity, Access, and Enforcement. A discussion of these data handling issues can be found at the Commerce Department’s Safe Harbor website http://www.export.gov/safeharbor/SH_Overview.asp and a comprehensive Safe Harbor document set is currently at http://www.export.gov/safeharbor/SH_Documents.asp. Communications relating to data privacy at MicroEdge and its commitment to Safe Harbor can be sent to the legal department of Microedge’s parent company Advent Software, Inc. for which the email address is legal@advent.com.

Former Clients
Even if you are no longer a MicroEdge client, our Privacy Policy will continue to remain in effect.