Future Scholar Internet Privacy Statement

Information we collect about you online
We want you to get the most out of your visits to our website. From providing clients of Columbia Management and Columbia Management entities with secure online account access and management options, we strive to make the most of every unique user visit to our website. To provide our users with these and other online tools, we will, from time to time, request that you provide us with your personal information, such as your name, address, email address and telephone number.

Website users: We will ask you for certain contact information when you register for online services and products, or request information online.

Columbia Management clients: We will ask you for certain personal information if you want to access your Columbia Management accounts online or request online services and products so we can provide you with secure online account access or the requested services or products.

We will maintain information about your account, online account activity, online services and products requested and your usage of our website to help us administer your online account needs and to continually improve your online experience by providing you with customized relevant information.

TO PARENTS OF CHILDREN UNDER 13: We do not knowingly solicit data online from or market online to children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe that personal information may have been collected about your child, please read "How we use the information we collect" below. For more information about the Children's Online Privacy Protection Act (COPPA), visit the FTC website: www.ftc.gov.

How we use the information we collect
Whether you are a new website user or a Columbia Management client, we use personal information collected on our website to handle the transactions you initiate. Your personal information will not be rented or sold to any third party for marketing purposes. In some instances, we will share your contact information with carefully selected service providers to assist us in processing your online transactions or to deliver the services and products. For example, in order to mail you statements, we will supply your contact information to a third party vendor who will process and mail the statements and other materials on the behalf of Columbia Management.

We may disclose personal information collected on our website when disclosure is required or permitted by law. For example, we may be required to disclose personal information to cooperate with law enforcement and regulatory authorities, as part of the sale, merger or similar change of a Columbia Management business, or to perform authentication procedures to prevent fraud.

Tracking activity on our website
In order to make your visit to our website as productive as possible, we track activity on our website. However, we want you to know that the tracking technology we use does not identify any personal information about you. It cannot retrieve data from your hard drive, pass on computer viruses, or capture any personal information about you, such as your name, address, phone number, or email address. We only know who you are if you tell us. You may, however, be asked to provide personal information such as name, address, phone number or email address to us when you register for online services or products.

• Cookies: One way we track activity is by using cookies. A "cookie" is an electronic file that holds small strings of text. When you visit our website, we send a cookie to your browser so that we can recognize it when you or another user of your computer return to our website. We want to recognize your browser so we can make the best use of your time when visiting our website. For example, when you visit our website, we present an introductory page to all new users. The fact that you have already visited the introductory page is recorded in a cookie so you won't see the introductory page again. For your security, if you are registered for online services and/or have an account with Columbia Management, we can not give you access to your account information on our website unless your browser is set to accept cookies from us.
• Browser settings: You can adjust many browser preferences so that you are alerted when a cookie is placed in your browser, or adjust preferences to decline cookies altogether. Recognize that cookies enable you to visit our website without reviewing introductory information. In addition to allowing us to recognize you, cookies also enable us to securely provide our registered users with account information.

How we use your email address
We recognize that email can be the preferred mode of communication for some of our website users. If you provide us with your email address when registering for an online service or product or when accessing your account online, we will use it to contact you about online services and products for which you have registered or about your account.

We may use your email address to send you the following types of email messages:

• Services you are enrolled in
• Optional email communications which you have signed up for (e.g., newsletters on a selected financial topic)

Also, once you have requested information from us, we may communicate with you via email regarding your request to provide additional information related to your initial information request. However, we will never ask you to send personal information such as account or Social Security numbers by non-secure email.

We do not share your email address with non-affiliated companies for them to market their products or services directly to you.

Ads that link to our website
Columbia Management may use third parties to place banner ads on other websites and will perform tracking and reporting activities through use of ad servers. We do not provide ad servers with your personal information and ad servers do not collect your personal information.

Ad servers are subject to their own privacy policies. If you would like more information about the privacy policies of these ad servers, including information on how to opt-out of their tracking methods, please visit the Network Advertising Initiative Website ( http://www.networkadvertising.org/ )

Websites that we link to
Web sites that you link to from the Columbia Management site may contain privacy provisions that differ from the provisions of our Privacy Statement. To ensure your privacy is protected, we recommend that you review the privacy statements of other Internet sites you visit.

How We Safeguard Your Information
Columbia Management realizes how important security is to you, so we've taken a number of steps to enhance the protection of personal or confidential information sent to or from Columbia Management over the Internet. First, we require that a "secure session" be established, using Secure Socket Layer (SSL) Technology. This is done any time you supply or access personal or confidential information in one of our secure online areas.

SSL Technology is intended to create a private conversation that only your computer and Columbia Management systems can understand. The SSL Technology encodes information as it is being sent over the Internet between your computer and Columbia Management systems, helping to ensure the transmitted information remains confidential. The use of SSL requires two components: an SSL-compatible browser and a Web server to perform the "key-exchange" that establishes a secure connection to Columbia Management web server systems. In addition, all of our secure sites require that your browser support 128-bit encryption.

Second, many areas of the site require the use of a user ID and password as an additional security measure that helps protect your confidential information. This allows Columbia Management to verify who you are, thereby allowing you access to your account information while seeking to prevent unauthorized access.

When you have finished using a secure area of Columbia Management, make sure you always click on the "Log Out" link which appears on the top of every secure page. When you click on it, no further secure transactions can be conducted without re-entering your user ID and password. This also helps prevent unauthorized access to your account if you walk away from your computer.

You should be aware that browser software often "caches" a page as you look at it, meaning that some pages are saved in your computer's temporary memory. Therefore, you may find that clicking on your "Back" button shows you a saved version of a previously viewed page. Caching in no way affects the security of your confidential user ID or password. If you use a computer in a public place to access your account information, simply quit/exit the browser software before leaving to minimize the possibility of anyone else viewing your confidential information.

Lastly, Columbia Management computer systems are protected by a firewall that seeks to block unauthorized access. This means that no one without the proper web browser configuration can view or modify information contained on our systems. Only authorized people – employees, advisors, approved contractors, etc. – are authorized to use Columbia Management computer systems, and only people who need to know confidential client information are assigned access to that information.

How you can protect yourself online

Spyware, Anti-Virus and Firewall Software.
Spyware is software that is installed on your computer without your consent to monitor the way you use your computer. It can be used to display pop-up ads, send you to websites you did not mean to visit, monitor the websites you surf or record keystrokes, meaning the software could record your usernames and passwords.

Clues that spyware may have been installed on your computer are:

• Onslaught of pop-up ads
• Your browser taking you to sites you did not enter in the address box
• A change to your Internet home page that you did not make
• New toolbars
• New icons in your browser window
• Keys that don't work properly
• Random error messages
• Slow performance when opening programs or saving files

Tips to help protect your computer from spyware

• Update your operating system and Web browser software to make sure you have the latest protection.
• Only download free software from sites you know and trust.
• Don't install any software without knowing exactly what it is.
• Set your security setting to at least "medium" to avoid unauthorized downloads.
• Avoid links in pop-up windows.
• Don't click on links in spam that claim to offer anti-spyware software
• Install a personal firewall to stop uninvited users from accessing your computer.

How to get rid of spyware
If you think your computer might have spyware on it, follow these steps:

• Get an anti-spyware program from a vendor you know and trust, choosing one that can undo changes spyware makes to your system.
• Set it to scan on a regular basis — at least once a week — and every time you start your computer, if possible.
• Delete any software programs the anti-spyware program detects that you don't want on your computer.
• Source: onguardonline.gov
• Anti-virus software and a firewall can help protect you when you make financial transactions online.

Anti-virus software works by removing or quarantining suspected viruses. It's best to choose one that updates regularly so that you don't have to worry about making sure the software is up-to-date. A firewall functions much like a fire door in a building by preventing unauthorized parties to access your computer or network. It is important to set up your firewall properly.

Personal information and phishing
Phishing refers to the unlawful and fraudulent attempt to acquire sensitive information, such as usernames, passwords, Social Security numbers and credit card information. Phishers send email or create pop-up windows posing as reputable companies, such as Internet service providers (ISP), banks and online payment services, and ask consumers to update, validate or confirm account or other personal information on a website that looks legitimate.

Consider these tips to help you avoid phishing scams:
Use anti-virus and anti-spyware software and a firewall. Some phishing emails contain software, such as spyware, that harm your computer or track your activities on the Internet. Anti-virus software and a firewall can protect you from inadvertently accepting such unwanted files.

Don't email personal or financial information.Regular email is not a secure method of transmitting personal information. Some companies, including Columbia Management, offer a secure email service that you can use when you need to exchange sensitive information.

Use caution when opening attachments or downloading files from email.
These files can contain viruses or other software that can weaken your computer's security.

Report phishing attempts to the company being impersonated.
Most organizations have information on their websites about where to report suspected phishing incidents. To report an incident to Columbia Management, you can email us at service.inquiries@columbiamanagement.com.

If you have any questions or concerns about this Privacy Statement, please write us at:

Columbia Management
P.O. Box 8081
Boston, MA 02266-8081

Former customers
If, for whatever reason, our customer relationship with you ends, we will preserve your information as necessary to comply with applicable laws. The measures we take to protect the privacy of customer information will continue to apply to you.

We reserve the right to change this Privacy Statement, and any of the policies described herein, at any time. The examples contained in this Privacy Statement are illustrations; they are not intended to be exclusive.