At Ciena Capital, protecting your privacy is important to us. Our goal is to treat information you furnish us with respect, and in accordance with this Privacy Policy. The Ciena Capital products and services are currently available only to United States customers and Web site visitors. Please read on for more details on our practices for handling and securing your information.

WHAT INFORMATION DO WE COLLECT? HOW DO WE USE IT?

Anonymous Browsing
You can visit Ciena Capital on the World Wide Web without revealing any information about yourself or your company. In those cases, our Web servers collect the name of the domain you used to access the Internet (e.g., AOL.com), the Web site you came from and the one you will visit next. This information is used by us and our business partners to measure statistics, including the number of visits, average time spent and pages viewed; monitor site performance and make our site easier and more convenient for our Web site visitors.

Information Collection

When you choose to provide information about you and your company, it allows us to better meet various needs you may have, including:

• Providing products or services you have requested.
• Servicing your account.
• Improving our services.
• Developing useful products or services.
• Informing you of products and services that may be of interest to you.
• Answering questions you may have.

Categories of Information Collected

We collect and use various types of information to better respond to your financial needs.  The customer information we collect is categorized as follows:

• Application Information — information that you provide to us on applications and through other means. Examples include the physical address, zip code, phone number, financial assets, income and debt for you and/or your company. 

• Transaction and Experience Information — information about your transactions with us, as well as information about our communications with you. Examples include your account balances, payment history, requests for information and our responses.

• Consumer Report Information — information from a consumer credit report. Examples include your creditworthiness and credit history.

• Information from Outside Sources — information from outside sources regarding your credit and other relationships. Examples include your loan balances, credit card balances, property insurance coverage and other verifications.

• Other General Information — information from outside sources, such as data from public records, that is not assembled or used for the purpose of determining your eligibility for a product or service.

• As required by the USA PATRIOT Act, we also collect information and take actions necessary to verify your identification.

Children's Online Privacy Protection

Please note that Ciena Capital does not knowingly solicit information from children (e.g. persons under the age of 13) and does not knowingly market our products or services to children.

Cookies

If you are browsing Ciena Capital's Web site, we use a technology called "cookies" to help us measure the number of visits, average time spent, pages viewed, and other statistics relating to our Web site. If you decide to register online with one of our business units, we may collect additional information to provide offerings or content tailored to your needs. In this case, we use cookies to help personalize your experience and help us recognize you on subsequent visits to our Web site. Cookies are small pieces of data that can be sent to your computer, which then may be stored by your browser on your computer's hard drive. They cannot be used to get data from your hard drive, get your e-mail address or any personally identifying information. Most web browsers have features that can notify you when you receive a cookie, and that give you the option to prevent cookies from being sent. Please note, however, that by not accepting cookies, you will limit the personalized functionality we can provide to you when you visit our site.

SHARING OF INFORMATION AND CHOICE

In order to better meet your needs and offer you other products and services that may be of interest to you, we may share information about you from each of the categories listed under the heading “Categories of Information Collected” above with our business units, affiliates and unaffiliated third parties.  We may also aggregate statistics we gather about our customers, sales, traffic patterns, and services, and provide these statistics to unaffiliated third parties; provided, however, that any statistics we provide will not include any personally identifying information.

Who We Share Information With

We may share information from each of the categories listed in the “Categories of Information Collected” section above with the following third parties:

• Banks.

• Credit Card Companies.

• Stock Brokerage and Investment Companies.

• Insurance Companies.

• Real Estate Agents and Brokers.

• Business Services Providers.

• Appraisers and other Third Party Reporting Agencies.

• Government Agencies.

E-Mail Communication and Online Surveys

Occasionally, we may send you e-mail communications with useful information about our products and services, or about offerings from affiliates or unaffiliated third parties. At times, we may conduct online surveys to better understand the needs, profiles and online experience of our customers and visitors.

Online Advertising

Ciena Capital sometimes contracts with advertising companies to advertise our accounts and services on Web sites not affiliated with us. These internet ads are often called "banner ads."  If you click on one of our ads, you link to the Ciena Capital site that offers the advertised account or service. These ads may contain cookies that allow tracking of your response to our advertisements. These cookies do not identify you personally. We prohibit any company that places our banner ads from using this information for any purpose other than to assist us in measuring the effectiveness of our ads.

Linking to Other Sites

We may provide links to unaffiliated companies, such as credit bureaus or merchants. If you choose to link to web sites not controlled by Ciena Capital, we are not responsible for the privacy or security of these sites, including the accuracy, completeness, reliability or suitability of their information. if you are asked to provide information on one of these web sites we strongly urge you to carefully study their privacy policies before sharing your information.

Honoring Your Preferences

You have choices when it comes to how Ciena Capital shares and uses your information.

At any time, you may correct all the information we have gathered from you.  You may also elect to limit how we share your information and who we share it with as more particularly described below.  If you want to amend your information, or do not want Ciena Capital to share your information, call our customer service center at 1 (800) XXX-XXXX (Monday-Friday, 8 a.m. - 6 p.m. E.S.T.).

Sharing Among Ciena Capital Companies and Unaffiliated Third Parties

You may request that your information not be shared among the affiliates or other business units of Ciena Capital.

In addition, you may request that your information not be shared with all or any one of the categories of unaffiliated third party providers listed under the heading “Who We Share Information With” above.

During the normal course of doing business, we will continue to share your information among our business units, our affiliates and unaffiliated third parties as necessary in order to service your accounts with us.

Direct Marketing

You can choose not to receive marketing offers from us by direct mail, telephone and/or e-mail. This preference applies to offers from us about our products and services, and about other products that we think may be of interest to you.  To minimize the amount of telephone solicitation our customers receive, Ciena Capital does not offer nonfinancial products and services through telemarketing.

If you elect not to receive product information by direct mail, telephone or e-mail, you will continue to:

• Be contacted as necessary to service your account.

• Be contacted by your relationship manager or assigned account representative, if applicable.

• Receive marketing information included with your regular account mailings and statements, and when you visit us online.

To help you understand how we record your preferences, you should know that your preferences will be honored among all Ciena Capital business units and affiliates.  Since some marketing programs may already be in progress, it may take four to six weeks for your preferences to be fully effective

Tell Us Your Preferences

You can tell us your preferences by:

• Calling us toll free at 1 (800) XXX-XXXX (Monday-Friday, 8 a.m. - 6 p.m. E.S.T.).

• Notifying us at [www.Ciena Capital.net/privacy] by clicking on the [Contact Us] link.

When you contact us, please be prepared to provide the following information for each individual and/or company, as applicable:

• Full name.

• Address, city, state and zip code.

• Social Security number (if applicable).

• Telephone number.

• E-mail address (if applicable).

• If any of these pieces of information change, please notify us to ensure that your preferences are consistently honored.

Once you have told us your preferences, we will continue to honor them. You do not need to take any further action.

Guarding your own information

Ciena Capital recommends that you take the following precautions to guard against the disclosure and unauthorized use of your account and personal information:

• Never provide personal information (including full social security numbers or account and credit card information) over the phone unless you have initiated the call and know with whom you are speaking.

• Safeguard ATM, credit and debit cards.

• Memorize personal identification numbers (“PINs”) and refrain from writing PINs, social security numbers or credit card numbers where they can easily be found.

• Immediately change preassigned PINs to a personally memorized PIN.

• Do not use easily identifiable numbers such as birth dates, addresses, phone numbers or social security numbers when choosing your PIN.

• Store cancelled checks, new checks and account statements in a safe place.

• Tear up or shred unused preapproved credit offers.

• Report lost or stolen checks, and credit and debit cards immediately.

HOW IS YOUR INFORMATION SECURED AND PROTECTED?

Ciena Capital uses encryption tools to protect your personal information when it is submitted through our Web site. E-mails you send us are not necessarily secure when they are transmitted to us. If your communication is very sensitive, you may want to send it by regular mail instead.

In addition, we instruct our employees with access to your information that it is to be used only in adherence with the principles set forth in this privacy policy and laws applicable to Ciena Capital and its business units.  Employees who misuse customer information may be subject to disciplinary action including termination of employment.

Making Sure Your Information Is Accurate

Keeping your account information accurate and up to date is very important. You have access to your account information through various means, including account statements and via telephone call to our customer service center at (646) 723-5000 (Monday-Friday, 8 a.m. - 6 p.m. E.S.T.).  If your account information is incomplete, inaccurate or not current, please write to us at the address listed on your account statement or call our customer service center at (646) 723-5000 (Monday-Friday, 8 a.m. - 6 p.m. E.S.T.).  We will promptly update or correct any erroneous information. Please contact us if you have questions or feel that we have not handled information about you properly.

What Happens WHEN You Are No Longer a Customer?

If you are no longer a Ciena Capital customer for any reason, we will continue to secure and protect your personal information as described in this Privacy Policy.  We may also continue to share your information, including information from each of the categories listed in the “Categories of Information Collected” section above, after you are no longer a customer unless you have asked us not to share your information.  We will continue to honor your requests to restrict sharing of your information even after you are no longer an active customer of Ciena Capital.

WHAT IF WE CHANGE OUR PRIVACY POLICY?

We reserve the right to modify or supplement this Privacy Policy statement at any time. If we make any material changes, we will post a notice on our Web site's home page with a link to the updated policy statement. Please read any such notice and the new policy statement. Your continued use of this site after we post such notices will constitute your acceptance of our new terms and their application to your use of this Web site, and the information disclosed for such use, including information previously furnished us, as if they were the initial terms.

WE WANT YOUR FEEDBACK

Ciena Capital welcomes your feedback and suggestions about our Privacy Policy. If you have comments or questions about information security, privacy and their use at Ciena Capital, please contact us at: (646) 723-5000 (Monday-Friday, 8 a.m. - 6 p.m. E.S.T.).