Privacy Policy

Whose Policy is this?
Acceptance of Policy and Amendment
Protection of Personal Information
How We Collect Information About You
Disclosure of Personal Information
Right of Refusal
How do we Protect Personal Information?
Questions Concerning this Policy


Whose Policy is this?

This notice, as it may be amended from time to time, describes the privacy policies of OFI Institutional Asset Management, Inc. and its subsidiary, Trinity Investment Management Corporation. (“we”, “our” or “ours”) as to the personal information described below. 

In this notice “personal information” means information by which a particular individual client, individual former client or individual prospective client (“you”,”your” or yours”) can be identified. Such information may include your name, postal address, phone number, email address, Social Security number and date of birth, as well as details about your financial interests, investments and investment experience. You are entitled to know how we collect such personal information and how use and protect it.

Acceptance of Policy and Amendment

Your usage of this website constitutes your agreement to the terms of this policy and your continued usage of this website constitutes your agreement to amendments to this policy. We reserve the right to amend this policy at any time. In the event that it is amended, a notice to that effect will be posted on our website, www.ofii.com. In our discretion an updated notice may be mailed to our clients.

This notice was last updated April 10, 2007

Protection of Personal Information

We do not disclose any personal information to anyone, except with your consent and as permitted by law.

How We Collect Information About You

We obtain personal information about you from the following sources:

• Contracts or other forms, such as applications and registrations
• Oral and written communications with you concerning your account and normal administration of your account
• Information provided by investment consultants and other third-party information providers (such as to verify identity and financial information provided to us)
• Usage of this website
• Transactions we undertake for or with you.
  

Disclosure of Personal Information

We provide personal information to third parties, such as brokers, custodian banks and proxy services in connection with the administration of your account and otherwise in the ordinary course of doing business. In addition, in accordance with instructions from you, we will provide information to your consultants or other interested parties. We may also use details about you and your investments to help us, our financial service affiliates, or firms that jointly market their financial products and services with ours, to better serve your investment needs or suggest financial services or educational material that may be of interest to you. If this requires us to provide you with an opportunity to "opt in" or "opt out" of such information sharing with a firm not affiliated with us, you will receive notification on how to do so, before any such sharing takes place.

We may also transfer personal information (a) to government agencies, and regulatory and law enforcement authorities as necessary or required; (b) as part of the sale, merger or other disposition of some or all of our business; and (c) or as permitted or required by law, rule and/or regulation.

Right of Refusal

We will not disclose your account information to unaffiliated third parties (except as permitted by law), unless we first obtain your permission to do so.

How do we Protect Personal Information?

We maintain physical, electronic and procedural safeguards to protect your personal information. Our employees have access to that information in the normal course of performing their duties so that they may provide service to you, for example, when responding to your account questions. However, we work to limit access to this information to employees who need it for the purposes stated in this policy. Our employees are trained about privacy and are required to safeguard personal information.

Companies we use to provide support services are not allowed to use information about our clients for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of information to the performance of the specific services we have requested.

To protect your personal information this website uses the Secure Sockets Layer (SSL) protocol and user names and passwords. You can help these protections to work by not providing your account information, user name, or password to anyone else.

This web site offers features that require our use of “cookies”—tiny pieces of information that we ask your browser to store. We do not use cookies to obtain data from your computer, to learn your e-mail address, or to view data in cookies created by other web sites. We do not share the information in our cookies or give others access to it unless it is necessary to provide products and service you have requested.

As a security measure, unless requested to do so by the client, we do not include account information in nonsecure emails, and we advise you not to send such information to us in nonsecure emails. Account information available on our website is encrypted and can be accessed only with a unique security password assigned to each account.

From time to time, we review our security procedures in order to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.

Questions Concerning this Policy

If you have any questions about this privacy policy, please contact:

Lori Proper
301 North Spring Street
Bellefonte, Pennsylvania 16823
ph: 814.355.1000
fax: 814.355.7439
lproper@ofii.com

Any personal information that you provide in communications to the above e-mail and postal mail address will not be used to send you promotional materials, unless you so request.