Privacy Policy

Our Commitment to Privacy

· We will always value the trust of our clients and the importance of keeping their personal financial information confidential.

· Dunham Trust Company client information is not disseminated to any nonaffiliated third parties for marketing purposes. Therefore, clients will neither need to nor have the opportunity to opt out of the disclosure of non-public personal information.

· We will provide our clients with our policy on using their personal financial information.

· We will hold our employees and independent contractors to the highest standards of conduct in ensuring the confidentiality of client information. We will also take appropriate disciplinary measures to enforce employee privacy responsibilities.

· We will hold any personal medical information about our clients sacred and will not use it for marketing purposes or in making credit decisions.

· We will use information responsibly in order to provide our clients with significant benefits including fraud prevention, improved products and services, and to comply with the laws.

· We have established procedures to maintain accurate information and will respond in a timely manner to our clients’ requests to change or correct information.

· We will use a combination of safeguards to protect our clients against the criminal use of their information and to prevent unauthorized access to it.

· We will not share client information with anyone who does not agree to keep your information confidential.


Dear Valued Client

At Dunham Trust Company, protecting the confidentiality and security of clients’ information has always been an important part of our customer service and business practices. We want to assure you that we are committed to safeguarding your privacy while assisting you in achieving your financial goals. Our business has developed its own privacy policy to reinforce this commitment and to address the concerns of the Gramm-Leach-Bliley Act of 1999, which requires each member of the financial services industry to communicate its privacy policy to consumers and existing clients. This Privacy Policy brochure describes how we safeguard the information of our clients.

Our policy covers all of the Dunham & Associates companies including Dunham & Associates Investment Counsel, Inc., Dunham Trust Company, Asset Managers, Inc., and other related entities. If you have any questions regarding privacy and your account(s), call us toll free at (800) 442-4358.

At Dunham Trust Company, maintaining your privacy, trust and confidence is as important to us as ensuring that you are channeled to the best resources available to help you achieve your financial goals. Sincerely,

Jeffrey A. Dunham
Founder & CEO

Dunham & Associates
Investment Counsel, Inc.
P.O. Box 910309, San Diego, CA 92191
(800) 442-4358

241 Ridge Street, Suite 100, Reno, NV 89501
(888) 438-6426

Maintaining Privacy for our Clients

How & Why We Obtain Information

Dunham Trust Company uses personal information collected about you to provide you with the superior service you have come to expect from us. We may use this information in order to develop, offer, and deliver products and services, to process transactions in your account, to respond to inquiries from you or your representative, or to fulfill legal and regulatory requirements. We do not share clients’ personal information with other companies for marketing purposes.

Dunham Trust Company may receive non-public personal information from you, your representative or from any of the following sources:

· From your applications or forms (for example, name, address, Social Security number, birth date, assets, and income)

· From transactional activity in your account (for example, trading history and balances)

· From other interactions with Dunham Trust Company (for example, discussions with our investor relations staff or your access of our websites)

· From you or your representative regarding your investment preferences

· From other sources with your consent or with the consent of your representative (for example, from other broker/dealers or institutions when you transfer positions to Dunham Trust Company)

Privacy Online

Dunham Trust Company considers privacy, security, and service to be just as critical in the online environment as in the rest of our operations. We therefore employ all of the safeguards previously described while conducting business over the Internet.

In addition, Dunham Trust Company uses a variety of protections to maintain the security of your online session. For example, no one has access to your proprietary data online without the use of a personalized password and the corresponding account number.

When we conduct business online, we may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our websites. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our Web design and functionality. We do not share email addresses with other companies for marketing purposes.

How We Protect Your Information

Dunham Trust Companyv has always considered the protection of sensitive information to be a sound business practice and a foundation of client trust. We maintain information protection controls in keeping with industry standards and practices, and we regularly adapt these physical, electronic, and procedural controls to respond to changing requirements and advances in technology.

Within the Dunham & Associates companies and among our service providers, we restrict access to information to those who require that access in order to provide products and services to you.

We may share the personal information that we receive about our clients, prospects, or former clients with their broker/dealers, with their representatives or with the following types of entities:

· Affiliates, including affiliated service providers (for example, Dunham & Associates Investment Counsel, Inc. back office, investment advisory and other services for Dunham Trust Company)

· Unaffiliated service providers (for example, accounting firms that prepare tax reporting information and banks that handle wire transfers)

· Government agencies and law enforcement officials (for example, for tax reporting or in response to subpoenas)

· Other organizations, as permitted by the laws that protect your privacy (such as for fraud prevention)

· Other organizations, with your consent or as directed by your representative (for example, if you request personalized performance reporting)

Business Relationships

Dunham Trust Company may work with other companies to service your account. You will receive separate information regarding privacy policies from these other companies if they service your account.

We are proud of our privacy and confidentiality practices, and we want you to know how we work with all of our companies in order to protect your information and to use your information to service your account.