LAST UPDATED: 11/17/20
- Information we receive from you on applications, subscription agreements or other forms;
- Information about your transactions with us or others;
- Information we receive from third parties such as broker/dealers, transfer agents, financial advisors and custodians.
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual and includes nonpublic information about you that we obtain in connection with providing a financial product or service to you (“nonpublic personal information”). Personal Information we collect includes:
- Postal address
- Telephone number
- Email address
- Social Security number, tax identification number, passport number, or any similar number or other government-issued ID
- Date of birth
- Online account information, such as username and password
- Employment information, such as employer, dates of employment, title and role
- Financial and investment information, including information and choices concerning your current investments, account balances, transactional history, assets, income, beneficiary information, personal bank account information, tax-related information, and your broker/dealer, financial advisor and custodian
- Information to request a repurchase under exigent circumstances, such as physical or mental condition, impairment or illness; death certificate; government documentation of disability; physician certification; spouse name, employment information and income; dependents’ names and ages; and expenses.
Confidentiality and Security
We maintain physical, electronic and procedural safeguards designed to protect Personal Information within our organization. We also endeavor to restrict access to your personal and financial data to authorized associates who have a need for these records. Please do not send such information to us in non-secure e-mails.
Social Security Numbers
We may request that you provide us with your Social Security number in order to provide you with our services and facilitate any of your requests with respect to our investment programs and products. We only use and disclose such information to facilitate your requests, prevent fraud or other harm, and to comply with legal, audit, insurance and other similar requirements, and otherwise in accordance with applicable law. We take the confidentiality of this information very seriously (see also Confidentiality and Security above) and have policies in place to limit access to such information on a need-to know basis. We also have policies, processes and agreements in place to require that our employees and service providers treat such information accordingly.
Children’s Online Privacy
We do not knowingly request or solicit any Personal Information from anyone under the age of 13 on or through the Website. If you are a minor child, please do not provide us with any personal information. If you are the parent or legal guardian of a child that you believe has provided us with such Personal Information online, please contact us immediately to have such information deleted from our system.
Do Not Track
At this time, our Website does not honor Do Not Track signals from internet web browsers because there are not universal standards for doing so.