Privacy Policy

May 2013

We consider customer privacy and confidentiality to be a fundamental aspect of our relationship with clients. We are committed to maintaining the confidentiality, integrity, and security of our current, prospective and former clients’ personal information. To achieve this, we have developed policies that are designed to aid in the protection of this confidentiality, while at the same time allowing client needs to be served.
In the course of providing clients with different products and services, we and maybe some of our service providers may obtain non-public personal information.. This information may come from sources such as account applications and other forms, from other written, electronic or verbal correspondence, from transactions, from brokerages or financial advisory firms, financial advisers or consultants, and/or from information captured on our internet websites.

It is our general policy not to disclose any personal or account information provided or gathered by us to non-affiliated third parties, except as required or permitted by law or in the exercise of everyday business purposes, such as to process transactions or service accounts. Non-affiliated companies may be retained for the provision of certain services, such as preparing and mailing prospectuses, reports, newsletters, account statements and other information, conducting research on client satisfaction, and gathering shareholder proxies. Equally, non-affiliated financial service providers may be engaged, such as brokers, agency-dealers, and introducers, to market our products, and we may possibly enter into joint marketing arrangements. . These companies may have access to personal and account information, but are permitted to use the information solely to provide the specific service or as otherwise permitted by law. We may also provide personal and account information to indicated/connected brokerages or financial advisory firms and/or to own personal financial advisers or consultants.

We reserve the right to disclose personal information to non-affiliated third parties in limited circumstances where we believe in good faith that such disclosure is required under law, to cooperate with regulators (local or international) or law enforcement authorities, to protect our rights or property, or upon reasonable request by any of the funds in which there is an interest. Additionally, via direct request or with written consent, personal or account information may be disclosed to a non-affiliated third party.

Client information may be shared with our other affiliates in connection with servicing of the account, and subject to applicable law, may provide information about products and services that we or our affiliates believe may be of interest. The information that may be shared could include, for example, information about the account’s funds’ experiences and transactions, the participation in such funds or other investment programs, the ownership of certain types of accounts (such as IRAs), information captured on our internet websites, or other data about the accounts, subject to applicable law. Our affiliates, in turn, are not permitted to share this information with non-affiliated entities, except as required or permitted by law.

Naturally, we take seriously the obligation to safeguard all non-public personal information. In addition to this policy, procedures are in place, designed to restrict access to non-public personal information to our personnel who need to know that information to perform their jobs, such as servicing the account or the notification of new products and services.  Physical, electronic, and procedural safeguards are also in place to guard non-public personal information.

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