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Privacy Policy as of 9/8/2007

Privacy Policy Notice

The Privacy Policy Notice discloses the privacy policies of the Columbia Funds, Columbia Acorn Funds, Columbia Variable Series, Excelsior Funds, Banc of America Funds and Wanger Advisory Trust ("Funds"), which are advised, distributed and/or serviced by financial service companies ("Companies") owned by Bank of America Corporation. The Companies and the Funds are referred to herein collectively as "we" or "us".

Protecting your privacy is a top priority

We realize that our ability to offer superior products and services depends on the personal and financial information we collect from you.  We value your business and are committed to maintaining your trust.  That is why we have made your privacy a top priority.

The information we have and where we get it

We collect information about you from a variety of sources, including:

  • Information we receive from you on applications or other forms, such as your name, address and phone number; your social security number; and your assets, income and other household information;
  • Information about your other transactions with us, our affiliates or others, such as your account balances and transactions history; and
  • Information from visitors to our Web sites provided through online forms, site visitorship data and online information-collecting devices known as "cookies."

    For more information about what we collect online, including our use of cookies, please visit our websites.

    We do not solicit personal or financial information from minors without written parental consent, nor do we knowingly market our products and services to minors.

    How we use this information

    We may share all of the information we collect with the Companies as part of the ordinary course of providing financial products and services to you, for the purpose of offering you new products and services to address your financial needs, for product development purposes and as otherwise required or permitted by law.

    To assist in our business dealings with you, we may also share this information with companies (other than the Companies) that perform services, including marketing services, on our behalf (such as vendors that package and mail our investor statements and marketing research firms that enhance our ability to market our products and services).  We do not share your information with mailing list or direct marketing companies.  Thus, the information you provide to us will not result in unwanted solicitations from third-party marketers.

    Finally, we may share this information with other entities outside of the Companies for the following purposes, including among others:

  • To respond to a subpoena or court order, judicial process or regulatory inquiry;
  • To report suspicious transactions to government agencies and law enforcement officials;
  • To protect against fraud;
  • To provide products and services with the consent or at the direction of a customer; or
  • In connection with the proposed or actual sale or merger of all or a portion of a business or operating unit.

    Except as described above, and except for information we provide to nonaffiliated third parties as otherwise required or permitted by law, we do not share information about you with nonaffiliated third parties.

    Security of personal financial information

    We restrict access to information about you to those employees we determine need to know that information to provide products and services to you.  We maintain physical, electronic and procedural safeguards to protect this information.

    If you provide information to us via our Web sites in order to view your account activity or conduct transactions, we use 128-bit SSL encryption security with passwords to ensure a safe transmission of data between you and us.  Information you provide is stored and transmitted in a secure environment, accessible only by a select group of people who are given a secure passcode to access the information.

    Teaming up against identity theft

    Identity theft is a serious concern to all of us. Safeguarding information to help protect you from identity theft is our priority. We take steps to protect you from identity theft by:

  • Utilizing client identification and authentication procedures before initiating transactions
  • Ensuring our employees are trained to safeguard personal information about you

    You can also help protect your identity and accounts. Here are a few steps to remember:

  • We will never request your account number, log-in password, or Social Security number in either a nonsecure or unsolicited e-mail communication.
  • Remember to shred documents that contain personal information.
  • Check your credit report regularly for unauthorized activity and protect your personal identification numbers (PINS) and personal data.

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

    Customer Privacy
    PO Box 73
    One Financial Center
    Boston, Massachusetts 02111

    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, as described in this Privacy Policy Notice, will continue to apply to you.

    We also will comply with more restrictive state laws to the extent they apply.

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

     

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    ©2008, Columbia Management Distributors, Inc.
    A Member of Columbia Management
    One Financial Center, Boston, Massachusetts 02111-2621

    NOT FDIC INSURED. May lose value. No bank guarantee.