Morningstar® Office^SM / Morningstar^® Advisor Workstation^SM

Privacy Policy

Your privacy is very important to us. At Morningstar, we want to make your experience with us is satisfying and safe.

This Privacy Policy outlines the types of information we gather from you, the advisor (“You”) based on your access to and/or use of this Morningstar product, how we use that information, with whom we might share it, the means by which we keep it secure, and the choices You have about the information You choose to share with us. This Privacy Policy is intended to supplement, rather than supersede any pre-existing license agreements in place between You and Morningstar.

If You have any questions about the privacy practices of Morningstar Office, Morningstar Advisor Workstation or this Privacy Policy, please e-mail Morningstar Support or contact your home office.

PERSONAL INFORMATION WE COLLECT

The types of personal information we collect depend on the specific product or service we make available to You. This information may include, but is not limited to:

• Personal Advisor Information: advisor name, phone number, physical and e-mail addresses

• Personal Client Information: client name, phone number, physical address, social security number/Tax ID, salary, and portfolio holdings

PERSONAL INFORMATION WHY WE COLLECT IT

Morningstar may collect certain Personal Advisor Information and/or Personal Client Information (collectively, “Personal Information”) to provide You with investment information and tools, to perform marketing and research related activities, to supply other administrative services (e.g., setting up new accounts), to respond to inquiries, etc. In addition we may from time to time review your usage of the product to better provide you with information about other products or services that we believe may be of interest to you.

PERSONAL INFORMATION HOW WE COLLECT IT

The Personal Advisor Information Morningstar collects may be captured from a variety of sources. These sources include, but are not limited to:

• Registrations/applications/subscription agreements to receive products or services
• Voluntary submissions (e.g., responses to surveys, requests for information on our products or those of our advertisers/marketing partners)
• Reviews of product usage patterns
• Likewise, the Personal Client Information we collect may be:
• • Imported into the application by You and/or the institution with which You are associated using integration capabilities
  • Input directly into the application by You

USE AND ACCESS TO PERSONAL INFORMATION BY OTHERS

As a general rule, Morningstar will not make any Personal Information gathered using Morningstar Office or Morningstar Advisor Workstation available to anyone outside of Morningstar and its affiliates -- except as instructed by You or where required to comply with law. Please note, however, that there are several exceptions to this policy. First, if Morningstar uses service providers, these service providers may have access to Personal Information to perform contractually specified services on behalf of Morningstar or You. Second, if You indicate that You are interested in receiving information about a particular third party’s products/services, or you opt to receive certain products or services through Morningstar, we may provide Advisor Personal Information to that third party for purposes of fulfilling your request(s).With respect to its service providers, Morningstar contractually requires that all Personal Information be kept confidential. Additionally, Morningstar takes reasonable steps to ensure that third parties receiving Personal Information maintain the confidentially of that information.

LINKS TO OTHER WEB SITES

Morningstar may provide links to one or more other Web sites via this product. We encourage you to read the individual privacy policies of those sites before providing them with any of your personal information.

PROTECTION OF YOUR PERSONAL INFORMATION

Morningstar puts reasonable security measures in place to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of Personal Information. These measures include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where Morningstar stores personal data.

Morningstar operates secure data networks protected by industry standard firewall and password protection systems. Morningstar’s security and privacy policies are periodically reviewed and enhanced as necessary and only authorized individuals have access to the information provided.

USE of COOKIES

Morningstar uses Cookies to set users’ preferences, gather basic tracking information (such as login and password), date, time of visit and preferences, and monitor the presentation of our site. This information allows us to personalize the user experience and to improve the quality of our site navigation. Cookies do not reveal the identity of the individual user but only identify the computer utilized by that user.

ACCURACY OF PERSONAL INFORMATION

You are responsible for periodically checking to ensure that any Personal Information included is updated and correct.

HOW TO UPDATE PERSONAL INFORMATION

If You desire to update any Personal Information, You may do so by accessing Morningstar Office or Morningstar Advisor Workstation

WHAT ABOUT CHILDREN'S PRIVACY

Morningstar does not separately identify, or collect, any information that is specific to children.

YOUR CONSENT

By using Morningstar Office or Morningstar Advisor Workstation, You consent to the collection and use of any Personal Information and any related information in the manner described in this Privacy Policy. Please note that Morningstar’s systems are not currently configured to handle “do not track” requests.

CHANGES TO THE PRIVACY POLICY

Morningstar reserves the right to change this policy at any time by distributing and/or posting a new privacy policy without notice. We encourage You to review our privacy policy postings on a regular basis so that You will be aware of any changes.

If You have further questions about our privacy practices, please contact Morningstar Support or contact your home office.