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CONNING.COM PRIVACY POLICY

Conning & Company ("Conning") and its subsidiaries, Conning Asset Management Company and Conning Research & Consulting, Inc. respect the privacy rights of our users and are committed to protecting your privacy online. This Privacy Policy applies to this Web site, www.conning.com, and does not apply to other products or services of Conning or its affiliates.

Collection and Use of Personal Information

Conning and its subsidiaries collect personal information that you voluntarily provide on this Web site, which may include your name, address, e-mail address, phone number, employer information, issues of interest, credit card number, billing information, etc. For example, we collect personal information when you register to receive certain services or products, purchase products and/or services, or submit information to receive marketing or other promotional materials. We use this information to communicate with you and to provide you with your requested service and/or product. Conning or its subsidiaries may also provide you with information, special offers and promotions. You may instruct Conning and its subsidiaries at any time not to use your personal information to provide you with information, special offers or promotions by e-mailing us at Questions@ConningResearch.com. Please note that this opt-out process may take up to thirty (30) days to complete. For your protection, your credit card information is deleted in its entirety upon confirmation that the transaction has cleared the bank.

Disclosure of Personal Information

Conning or its subsidiaries may disclose your personal information to affiliated or unaffiliated third parties if we believe in good faith that such disclosure is necessary to: (a) comply with the law or in response to a subpoena, court order, government request or other legal process; (b) protect the interests, rights, safety or property of Conning or others; and (c) enforce any terms of use on this Web site.

Accuracy and Security of Personal Information

Any personal information you provide to Conning or its subsidiaries is kept on secure servers. Conning and its subsidiaries use reasonable administrative, technical, personnel and physical measures to: (a) safeguard personal information against loss, theft, unauthorized use, disclosure or modification; and (b) ensure the integrity of the personal information. To help us protect your privacy, you should maintain the secrecy of the username and password that may have been set up in connection with your participation in this Web site’s service.

Use of Cookies

We may use "cookies" or similar electronic tools to collect information to enhance your experience with this Web site. A cookie is a small text file placed on your computer that collects information about your use of this Web site, such as the Web pages visited and the date and time of a visit, and enables the Web site to recall your preferences and settings between visits.

Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. The "help" function on most browsers contains instructions on how to set your browser to notify you before accepting cookies or to disable cookies entirely. However, because cookies allow you to take advantage of some of the Web site’s essential features, we recommend that you leave them turned on. For instance, if you block or otherwise reject our cookies, you may not be able to add items to your Shopping Cart, proceed to checkout, or use other Web site products and services that require you to sign in.

Accessing and Updating Your Personal Information

If you have given Conning or its subsidiaries personal information in the past in connection with publications, products and/or services and would like to access and update this information, please send an e-mail to Questions@ConningResearch.com. If you would like to render your account inactive, please send an e-mail to Questions@ConningResearch.com. All requests must include the following information: first name, last name, and e-mail address. While we will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such access requests, if permitted or required by applicable laws. We do retain personal information from inactive accounts to comply with law, prevent fraud, collect any fees owed, resolve disputes, and enforce this Web site's User Agreement and to facilitate audits.

Modifications To This Privacy Policy

This Privacy Policy is subject to change. Whenever there are changes, the modified Privacy Policy will be posted on the Web site and will be effective at that time. Accordingly, it is recommended that you regularly check the Web site for updates to this Privacy Policy. At the time we post an updated Privacy Policy, we will also post a conspicuous notice on the Web site notifying you of the change. If the changes to the Web site are not acceptable to you, we recommend that you consider discontinuing your use of the Web site.

Last Updated: April 1, 2008

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