Barrington Research Associates, Inc. ("Barrington") has a long-standing
commitment of protecting the confidentiality and security of information
we collect from our clients. It is our policy that we do not share nonpublic
information about you outside of Barrington Research without your consent
except for the specific purposes described below, in accordance with all
applicable laws. The following describes the information we may gather
and the circumstances under which it may be disclosed.
Collection of Information
In conducting our business and providing our clients with products and
services, we collect nonpublic personal information ("Information") about
our clients. This Information includes information we receive from you
on applications or other forms; information about your transactions with
us, our affiliates, or others; information we receive from nonaffiliated
third parties (e.g. consumer reporting agencies); and information obtained
through the use of our website.
Disclosure of Information
We do not disclose Information about our clients or former clients to
any nonaffiliated third parties, except as permitted by applicable law
or regulation. We may share Information with affiliates of Barrington,
as well as with nonaffiliated companies that perform various services
such as transfer agents, custodians, broker/dealers and other service
firms and financial institutions with whom we have relationships. One
service provider relationship, which we maintain in particular, is with
Bear Stearns Securities Corp. Bear Stearns clears all of Barrington's
transactions on behalf of our clients. We may also share Information with
nonaffiliated companies with which we have joint marketing agreements,
such as an agreement with another broker/dealer or registered investment
adviser enabling us to offer you certain of its products or services.
Protection of Information
All employees are required to protect the confidentiality of Information
and to comply with our established policies. We restrict access to Information
about you to those employees who need to know that Information to provide
products or services to you. We maintain physical, electronic, and procedural
safeguards, within the applicable laws, to guard your Information.
Affiliates of Barrington Research Associates, Inc.
The following companies are under common control with Barrington Research
Associates, Inc:
Barrington Asset Management,
Inc.
HMR Publishing Company,
Inc.
Further Information
For questions concerning Barrington's Privacy Policy, write us at Barrington
Research Associates, Inc., Attn: Compliance Department, 161 N. Clark Street,
Suite 2950, Chicago, Illinois 60601, or telephone Gregory Paris at (312)
634-6000. We reserve the right to change this Privacy Policy at any time.