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Halbert Hargrove Privacy Policy

1. Information Collected
In order to access certain services and areas (collectively, the “Services”) within Halbert Hargrove ‘s website located at (the “Website”), Halbert Hargrove (“HH”) requires that you provide certain identifying information (the “Registration Data”) listed in the online My Accounts page or other pages within the Website. This information may include your user name or “screen name,” password and security identification number used to access your account information and the Services. HH reserves the right to request any additional information necessary to establish and maintain your account for use of any of the Services available on the Website.

The personal information you provide us is transmitted using Secured Socket Layer encryption technology to a secured database server. Once you become a “Registered Member”, HH stores such information in order to customize your experience on the Website.

HH places Internet “cookies” on your computer’s hard drive solely for session information, including information needed to provide you a certain level of functionality when navigating through the Website. Once your browser is closed, the session cookie is not saved.

2. Confidentiality
Registration Data is the property of HH, subject to and protected by applicable laws. Unless otherwise authorized as part of your registration with HH or as a part of your experience navigating the Website, including any framed areas available through the Website, HH will not sell, rent, swap or otherwise disclose your Registration Data to any third party. HH uses Secured Socket Layer encryption technology to transmit Registration Data, and stores all Registration Data in a secured database server protected from Internet access by a fire wall. Your Registration Information is accessible only by authorized personnel.

3. Uses Of Registration and Other Data
HH reserves the right to disclose to third parties information about your usage of the Website and any related services, including information gathered during your use of the Website, or when appropriate to comply with applicable law or to enforce or apply our Terms and Conditions of Use or other applicable agreements. Any third party to which HH rents, sells, shares or otherwise discloses personal data will be carefully pre-screened by HH, determined by HH to be reputable, and will use the personal data for marketing products and services which HH determines, in its sole judgment, that you might find of interest. Unless authorized by you as a part of your registration with HH or as a part of your experience on the Website, HH will disclose such information to third parties only in the form of aggregate data (such as overall patterns or demographic reports) that does not describe or identify any individual user.

In addition, personal data collected by HH will be used by HH for editorial and feedback purposes, for marketing and promotional purposes, for a statistical analysis of your behavior while using the Website, for further development of the Services, for content improvement, and to customize content and layout of the Website. User names or “screen names,” Internet Protocol addresses and e-mail addresses collected may be added to HH’s databases and used for future communications and mailings regarding updates to the Website, new products and services and upcoming events.

Unless you select the “Opt-Out” option as described in Section 4 below, HH reserves the right to use your Registration Data to send you information about HH and its affiliates, the Website, services provided by HH or its affiliates and other topics in which you may have an interest.

HH does not currently accept any information submitted to or posted at its Website from children under the age of 13. No information should be submitted to or posted at the Web Sites by children under 13 years of age without the consent of their parent or legal guardian. HH does not allow children under 13 to register as members or to receive direct marketing communications arising from their use of the Website and, therefore, HH does not provide any personally identifiable information from children under 13 to any third party. HH does encourage parents and guardians to spend time online with their children and to participate in the interactive activities offered on the Internet.

4. Opt-Out Right
If you do not wish to receive any special offers or other communications from HH, its affiliates or third parties, or to instruct HH to remove your personal information from our database or to no longer receive access to our Service, you can send an e-mail to our Webmaster, telephone your investment counselor at 800-435-3505 or send us a letter with your request at the following address: Halbert Hargrove, 111 W. Ocean Blvd., 23rd Floor, Long Beach, California 90802, attn: Webmaster.

5. Halbert Hargrove’s Right to Contact You
HH reserves the right to contact all visitors to the Website regarding account status and changes to the Terms and Conditions of Use, Privacy Policy or any other policies or agreements relevant to visitors or users of the Website.

6. User Updates to Information Collected
You may request to access, modify, correct, change or update your Registration Data at any time through the My Accounts page by contacting our Webmaster, telephoning us at 800-435-3505 or sending us a letter with your request at the following address: Halbert Hargrove, 111 W. Ocean Blvd., 23rd Floor, Long Beach, California 90802, attn: Webmaster.

7. Lost or Stolen Password or Security Identification
If your password or security identification is lost or stolen, you should immediately notify Halbert Hargrove by telephoning your investment counselor at 800-435-3505 or writing your investment counselor at the following address: Halbert Hargrove, 111 W. Ocean Blvd., 23rd Floor, Long Beach, California 90802.

8. Cancellation
You can cancel access to your account through the Website at any time by writing your investment counselor at Halbert Hargrove, 111 W. Ocean Blvd., 23rd Floor, Long Beach, California 90802

9. No Liability for Acts of Third Parties
Although HH will use all reasonable efforts to safeguard the confidentiality of the Registration Data, transmissions made by means of the Internet cannot be made absolutely secure. HH will have no liability for disclosure of Registration Data due to navigating in any third party websites which may be available through the Website by way of framing, errors in transmission, unauthorized acts of third parties or through the use of third party cookies including those of advertisers when you view or click on their advertisements. Once you leave the Website, including accessing any third party website as framed within the Website, you will be subject to third party privacy policies, which may differ significantly from our Privacy Policy.

10. Updates
HH reserves the right to change or update this Privacy Policy, or any other HH policy or practice, at any time. Any changes or updates will be effective immediately upon posting to the Website, and your use of the Website following such posting constitutes your acceptance of the Privacy Policy as so changed or updated.

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