This Privacy Policy outlines the types of information we gather about you, how we use it, 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.

If you have any questions about the privacy practices of Morningstar.com or this Privacy Policy, please e-mail
Premium@morningstar.com.

1. WHAT INFORMATION IS COLLECTED BY MORNINGSTAR AND HOW IS IT USED?
   
   Internet Provider IP Addresses
   Cookies
   3rd Party Web Analytics
   Personal Profile (and e-mail preferences)
   E-mail a Friend
   Portfolio/Watch List Information
   The Discuss Area
   Saved Screens
   Options Customized Views
   Hedge Fund Accreditation Data
   Your Credit Card and Billing Information
   Security
   Use of Personally Identifiable Information
   


2. WHAT INFORMATION IS COLLECTED BY ADVERTISERS AND HOW IS IT USED?
   
   Cookie Information
   How is this Cookie Information Used?
   How to Stop the Ad Serving Companies from Collecting Your Cookie User Information?
   


3. LINKS TO OTHER SITES
   


4. CHANGES TO PRIVACY POLICY

WHAT INFORMATION IS COLLECTED BY MORNINGSTAR AND HOW IS IT USED?


Internet Provider IP Addresses


Morningstar.com logs the IP addresses of the users accessing it, but we do not attempt to link these IP addresses to users’ personally identifiable information. This means that, while we might be aware of what areas on the Web site a particular computer accesses, we do not try to determine the identity of the person using it. We gather this access/usage information to analyze trends, administer the site, and collect broad demographic information to be used on an aggregated basis.

Cookies


Cookies are small pieces of information stored on your computer's hard drive. We collect information from cookies in much the same way and for many of the same reasons as we collect information through IP addresses. We use cookies to help us identify the types of content on Morningstar.com that are of most interest to both the individual user and to our user base as a whole. This allows us to provide more relevant content, to develop better tools and information, and to recommend Morningstar products to enhance each user’s experience on the Web site. Because we do not collect personally identifiable information through cookies, your privacy and security are not compromised when you accept a cookie from Morningstar.com.

We also use cookies to remember the password(s) associated with a particular computer to eliminate the need for you to keep re-entering them each time you come back to the Web site and to better target the types of advertising on the site that we think will be of most interest to particular users (based on the content accessed by their computers).

One thing to note, however, is that advertisers on our Web site may also serve you their own cookies when you click through to their separate sites. We do not control, nor do we have access to, any of the information that they may collect from your access/use of their sites. To learn more, see the section below titled What Information Is Collected by Advertisers and How Is It Used?

Of course, you can choose not to accept a cookie by adjusting your browser settings. However, if you choose to do so, you may not be able to take full advantage of certain customized content on Morningstar.com.

Third-Party Web Analytics


We also employ the services of third-party Web analytics companies to monitor and analyze user behaviors on Morningstar.com. We use this information to enhance and develop new content and services for our users. These third-party analytics services do not provide us with any personally identifiable information about users.

Personal Profile (and email preferences)


When you register for or subscribe to Morningstar.com products, you get access to a number of tools and content on the Web site that are not available to visitors. During registration, you will be asked to complete a registration form that:

• Asks you for certain demographic and preference information including certain personal information. This information includes, but is not limited to: your first and last name, address, zip code, phone number, and e-mail address; demographic information such as gender, occupation and year of birth; and information about your investing interests, confidence and skill level. You will also be asked to create a password for your account.
• Allows you to receive special offers from certain advertisers.
• Offers you various Morningstar e-mail newsletters, alerts, and postal mail.

We may use your name, e-mail address, street address, phone number, demographic and investing interests, confidence and skill level information to inform you of Morningstar.com tools and content that may be of interest to you, or to make you aware of other Morningstar products/services we think you might find useful. We will also use this information to provide any products that you order from Morningstar. In addition, if Morningstar offers you e-mail newsletters, alerts, or other related products outside of the registration process, you may be required to submit similar information to us in order to receive them. We will use this information in the same manner as that submitted by you during registration.

You can view your profile and e-mail preferences by clicking the Membership tab found in our top navigation.

E-mail a Friend


If you recommend content to a friend through our “E-mail Article to a Friend” service, you will need to provide us with your friend's e-mail address, your name and e-mail address and a message for your friend. We will then send your friend a one-time e-mail with your name, e-mail, message and a link to the recommended post.

Portfolio/Watch List Information


The Web site allows you to create and maintain both transaction and watch list portfolios as part of your account. We recognize that this information is potentially sensitive, and make protecting it a high priority. The contents of your portfolios are kept strictly confidential within Morningstar and are never voluntarily shared with any third parties. However, Morningstar may analyze them for internal research purposes, and use the results to send you information on Morningstar content and products that may be useful to you.

The Discuss Area


The Discuss area allows users to participate in lively discussions with a community of intelligent investors. For participants in the Discuss area, Morningstar collects additional profile data, including but not limited to: your location, occupation, investment interests, biography, birthday, personal Web site address, and investment preferences. This optional profile information, posting history, Discuss area usage statistics, and selected favorite content/users is publicly available in your Discuss User Profile. Further, Discuss area users may opt to share their Transaction or Watch List Portfolio(s) with others. This portfolio sharing option must be turned on by the user in order for other users to see your portfolio information. Users can modify or remove their profile information and hide their selected favorite content/users, they cannot modify or hide their Discuss area usage statistics or posting history. Users can edit their profiles by logging into their Discuss account and accessing the Discuss User Profile feature.

In the Discuss area, Morningstar utilizes user e-mail addresses to send notifications related to forum and blog activity, and to forward user-generated messages. If users do not wish to have their e-mail addresses disclosed to others users, they may opt to communicate through the Discuss “private message” (PM) service. Users can change their Discuss e-mail notification settings through the Discuss User Profile feature.

Please remember that any information you post in the forums or blogs will be available to anyone who accesses those portions of the Web site. In addition, by submitting any content, you are agreeing that Morningstar may make use of it elsewhere on the Web site or on any other Web site maintained by Morningstar or its affiliated companies or partners and it may be syndicated via RSS or e-mail feeds, all without your permission and without any obligation to compensate you. This could result in your post being repeated in part or in its entirety on sites not affiliated with Morningstar. Please note that when you disclose contact information or private information in the Discuss area, that information becomes publicly available and may result in your receiving unsolicited communications from parties outside of Morningstar.

We encourage you to maintain a healthy skepticism about any information posted to the Discuss area and to do your own research before making any investment decisions. People writing in the Discuss area may not be who they say they are, may not know, what they say they know or may not be affiliated with whom they say they are affiliated. The Discuss area of Morningstar.com is offered for entertainment purposes only. Morningstar expressly disclaims any responsibility for the content or accuracy of any information posted to this area and for any trading, investment or other decisions made on the basis of this information. Further, posts may have links to other sites that are not covered by our Privacy Policy statement.

Saved Screens


Because Premium Members have the ability to save customized screens, we also collect information on any such screens you decide to save. Morningstar may use this information to see how users are interacting with our Premium Screeners and to suggest new content and products that might be of interest to them.

Options Customized Views


Within the Options Chains function, users can customize and save views. To customize/change a view, you need to log in to Morningstar.com, adjust your view preferences, and hit "Save View." Morningstar may use this information to see how users are interacting with our Options Custom Views functionality and may also use it to suggest new content and products that might be of interest to you.

Hedge Fund Accreditation Data


U.S. securities law provides that, if a hedge fund markets itself in the U.S. to anyone other than an “Accredited Investors” (as that term is defined in Rule 501 of Regulation D under the Securities Act of 1933, as amended), the hedge fund in question must register as an “Investment Company” (as the term is defined in the Investment Company Act of 1940, as amended) and automatically becomes subject to the jurisdiction of the SEC. To avoid this outcome, hedge funds are only willing to make their information available to persons who represent that they are “Accredited Investors”. This representation requirement means that, every 365 days’, Premium Members who wish to access the Morningstar.com hedge fund database must certify to Morningstar that they meet the necessary accreditation standards. Morningstar retains this certification information in the event that it is required to provide it to the SEC. However, other than required disclosures, Morningstar does not voluntarily share this information with anyone.

Your Credit Card and Billing Information


Morningstar collects much of the same information from paid subscribers of its products as it does from Free Members of Morningstar.com. However, there are some differences. When you subscribe to any paid service on, or purchase any product through Morningstar.com, we also require your credit card information. Morningstar uses highly secure third-party card transaction service providers to authorize credits cards and to charge subscription fees. Morningstar employs industry standard card encryption processes and dedicated connections to better ensure that your credit card information is secure. For subscriptions to the Web site and various Morningstar retail products, Morningstar’s current credit card billing provider is PaymenTech for card charges and PayPal for card authorizations. If you need to make changes to your credit card and billing information, you may do so by going to the My Account section of the Membership section.

Security


Morningstar takes precautions to protect Morningstar.com members' personal information. We use industry-standard online security measures, such as encryption and authentication, to protect your personal profile, preferences, and credit card information. Please note, however, that no transmission over the Internet can be 100% secure and Morningstar can’t guarantee that it won’t be intercepted or divulged by a third party.

Morningstar also works to protect user information offline. All of your information is housed in secure, access-restricted areas. Only employees who need the information to perform a specific function are granted access to personally identifiable information.

Use of Personally Identifiable Information


It is Morningstar’s policy not to voluntarily share personally identifiable information that you provide us with anyone outside of the Morningstar family of companies. There are only two exceptions to this policy, where:

1. You opt in to receive special third-party advertiser offers on the site.

   You may opt to receive products, services, or information from one or more of the third-party advertisers listed on site. To opt in to these special offers, you must check the appropriate boxes or enter the information requested. We then forward your contact information (including your phone number and e-mail address) to those advertisers in whose products or services you have indicated an interest. These special offers may be made available to you during the registration process, as well as on an ongoing basis on different areas of the site.

2. You opt in to receive offers from well-screened companies via e-mail or postal mail.

   You may also elect to be contacted via e-mail or postal mail by certain well-screened companies. If you opt in to receive offers from these companies, we provide your name and address (but not your phone number or e-mail address) to those in whose products or service we think you might be interested. We may also forward you select e-mail advertisements that we think might be of interest to you from certain of these well-screened companies. However, to better preserve your privacy, we do not provide them with your e-mail address or other information about you. If you would like to change your preferences – for instance, to stop receiving such offers--you may do so at any time by going to the Membership Center, accessing the My Profile feature, and making the appropriate changes to your preference information. Remember, you’ll need to provide your e-mail address and password to access your own Personal Profile and Preferences.

---

WHAT INFORMATION IS COLLECTED BY ADVERTISERS AND HOW IS IT USED?


Cookie Information


Advertisers (or the companies that serve up advertisements on their behalf) often track and store certain information about the users of a site. While Morningstar does not control this process or have access to the information gathered by these advertisers/ad servers on Morningstar.com, we did want to make your aware of the practice.

Although different advertisers may collect different information, the information gathered generally includes such things as: (i) the cookie ID associated with the user's computer; (ii) portions of the user's Internet Protocol (IP) address that identify the user's domain name and the general geographical area in which the user is located; (iii) the particular ad(s) viewed by the user and the date, time, and duration of that viewing; and (iv) whether the user clicked on an ad (or any information within it). This tracking process is not supposed to reveal the user's name, phone number, mailing address, e-mail address, or any other personally identifying information. Instead, such a tracking system is designed merely to show the advertiser how and when the user's computer moved to different ads on the site. Unless the user voluntarily provides personally identifying information, for instance, by requesting that he or she be sent specifications on a particular product or service, the personal identity of the user should remain unknown to the advertiser.

How Is This Cookie Information Used?


As a general rule, the tracking information from each user is bundled with that of other users to create an overall usage summary for the ad(s) in question. This summary allows the advertiser to better evaluate the reach and effectiveness of its ads, both from a content and placement perspective; for instance, by analyzing how many "hits" a particular ad receives. However, please note that, in certain instances, the advertiser may also use the unbundled or individual results of this tracking to target specific products or service offerings to particular users based on their individual usage patterns.

How to Stop the Ad Serving Companies from Collecting Your Cookie User Information


If you want to stop the tracking process with respect to a particular ad service company, you may do so by blocking its cookies from being stored on your computer. Listed below are links to a number of the more well-known ad services companies. To block the cookies of the companies on this list, click on the below links and follow the relevant instructions. Please note that the privacy policies for each of these companies are also available through these links and that you may review them for additional information.

http://www.networkadvertising.org/optout_nonppii.asp http://www.advertising.com/privacy_policy.php http://www.revenuescience.com/site/privacy.asp http://mediaplex.com/MOJO_Privacy_Statement.shtml



---

LINKS TO OTHER SITES


To provide you with a more complete resource for investment information and services, Morningstar.com may contain links to other sites. In some instances, we will share demographic information on our users with sites that link to Morningstar.com, but again, this information is shared on an aggregate basis only. Please note that you may be required to register with a site that links to Morningstar.com in order to take advantage of that site's services (for example, ordering a book through Amazon.com that was recommended on Morningstar.com).

We cannot be responsible for the privacy practices of these sites; you should refer to these sites' privacy policies for details.

---

CHANGES TO THE PRIVACY POLICY


If we change the Privacy Policy, we will post that information on this Privacy Policy page, which can be found at the bottom of the Morningstar.com home page as well as at the bottom of most Morningstar Web pages. We invite you to come back from time to time to review the policy.

If you have any questions about Morningstar.com's privacy practices or this Privacy Policy, please e-mail us at joe@morningstar.com.