We consider protecting your privacy to be fundamental to our relationship with you and are committed to preserving the confidentiality, integrity and security of your personal nonpublic information. We maintain strict standards of security and confidentiality to safeguard the nonpublic personal information you share with us and will remain vigilant in protecting the privacy of that information.

What information do we collect from you and about you?

We collect nonpublic personal information about you from the following sources:

• Information you provide to us in the Subscription Agreement and related documents and in correspondence or conversations with our representatives, such as your name, address, social security number, telephone number, employment, asset, income and other household information;
• Information about your transactions with us, such as amount of investments bought and sold, checking transactions and wire transfers; and
• Information that is generated to service your account, such as account statements.

What information do we disclose to affiliates and nonaffiliated third parties about you?

In order to process your transactions and provide services to you, we may share some or all of the information we collect, as described above, with financial service providers which include, as applicable, the Funds’ administrator, distributors and our corporate affiliates. We may also share this information with certain nonaffiliated third parties, such as attorneys, accountants, compliance consultants, brokers or custodians who perform services on our behalf or who assist us in providing services to you, or with other financial institutions with which we have joint marketing agreements. We do not disclose any nonpublic personal information about you to anyone except as permitted by law. You cannot limit the information we share for everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. It may also be necessary, under anti-money laundering and similar laws, to disclose Information about you in order for the Funds to accept subscriptions from you. You can limit use of your Information to prevent us from sharing it with non-affiliates who may use it to market to you.

We will continue to adhere to these policies and practices even after you no longer have an investment with us.

How do we protect the confidentiality and security of your information?

We restrict access to your personal and financial data to those employees and nonaffiliated third parties who need that information to provide you with our services. We maintain, and where applicable, require third parties who perform services on our behalf to maintain, physical, electronic and procedural safeguards that comply with regulatory standards to guard your nonpublic personal information. We enter into contractual agreements with all third parties to whom we provide your nonpublic personal information which prohibit them from disclosing or using the information for the purposes other than which we disclosed the information to them.