A Commitment to Privacy

At Schwab Performance Technologies (SPT), our most important asset is our relationship with our clients. SPT is committed to maintaining your trust by protecting the confidentiality and security of the information about your business.

As part of this commitment, SPT and The Charles Schwab Corporation (Schwab) describe in this Privacy Statement how SPT handles information about you (Investment Advisor) and about the investors who are your clients (Investors).

SPT is a wholly-owned subsidiary of Schwab that provides portfolio management and accounting solutions to Investment Advisors that custody their clients' assets with Charles Schwab & Co., Inc. (CS&Co), and is not a broker-dealer.

SPT considers the information about Investment Advisors and Investors that is collected solely through your relationship with SPT to be confidential (SPT Confidential Information). SPT Confidential Information includes:

• Non-public information relating to an Investment Advisor that SPT obtains solely through its provision of products or services to the Investment Advisor;
• Non-public personal information about Investors that SPT obtains through its provision of products or services to an Investment Advisor.
• Information collected by CS&Co or another Schwab company other than SPT through its relationship with an Investment Advisor or an Investor, as well as information that does not identify an Investor, is not SPT Confidential Information.

Limits on Using SPT Confidential Information for Marketing by Schwab

SPT Confidential Information will not be used by SPT or another Schwab company for purposes not related to the operation of the SPT business. Schwab will not solicit any business from an Investment Advisor based on SPT Confidential Information without the prior consent of the appropriate Investment Advisor.

How SPT and Schwab Use SPT Confidential Information

SPT Confidential Information maintained by SPT may be shared with CS&Co or another Schwab company as necessary for providing SPT products or services to Investment Advisors or Investors. SPT will share only the SPT Confidential Information that enables Schwab to provide services to the Investment Advisor.

SPT Confidential Information may be shared with Schwab to provide services and platform capabilities relating to the Investment Advisor and its assets custodied at Schwab.

In addition to the foregoing, SPT Confidential Information may be shared with and used by Schwab under these limited circumstances:

• Trouble-shooting technical or production-support issues; or
• Addressing audit, supervisory, regulatory, legal, privacy or data security issues.

SPT protects the confidentiality and security of information about Investment Advisors and Investors, consistent with Schwab's data security policies. SPT limits access to SPT Confidential Information to those who have a business need to know the information. For example, SPT keeps SPT Confidential Information in a controlled and secure environment, separate from Schwab's maintenance of information about the customers of Charles Schwab & Co., Inc. SPT maintains written policies and procedures regarding the confidentiality and security of information held by it. In addition, all SPT employees who have access to SPT Confidential Information are subject to training on the safeguarding and proper handling of the information in compliance with this policy.

When you visit our website, our computer may use devices known as "cookies," graphic interchange format files (GIFs), or other similar web tools to enhance your web experience. These tools enable us to recognize you when you return to our site, maintain your web session while you browse, as well as help us provide you with a better, more personalized experience at Schwab. To learn more about our policies regarding using our website and the use of web tools, please visit our website Terms & Conditions.

Certain pages of our Website allow you to request information about our products and services. Our Website also contains forms that allow you to request support or ask us to update our records. In completing a form you may provide us with contact information such as your name, email address and phone number. By submitting a form, you indicate your consent for SPT to use this information. We may use the information in the forms to respond to your request and update our records so that future communication with you is accurate and appropriate.

SPT and Schwab reserve the right to amend this Privacy policy.