We collect and retain nonpublic personal information about you that may include:

• Information we receive on your account applications or other forms such as your name, address, financial information and/or NIC number;
• Information we receive about your mutual fund transactions, such as purchases, redemptions, exchanges and account balances and
• Information we collect through the use of Internet “cookies” when you access our website. Cookies are software files we use to track which of our sites you visit.

We do not sell any of your nonpublic personal information to third parties. We may share the information we collect with affiliates or with non-affiliated third parties only when those third parties are acting on our behalf in servicing your account, or as required by law. These third parties may include:

• Administrative service providers (Trustee and Transfer Agent) who, for example, process transactions for your account, print checks or prepare account statements;
• Companies that provide services for us to help market our products to you and
• Governmental or other legal agencies, as required by law

When information is shared with third parties, they are legally obligated to maintain the confidentiality of the information and to limit their use of it to servicing your account, except as permitted or required by law.

We restrict access to your nonpublic personal information to authorized employees who need to access such information in order to provide services or products to you. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.

As previously mentioned, we may collect information through the use of Internet “cookies” on our website. In addition, in order to provide you with access to your account via the web, it is necessary for us to collect certain nonpublic personal information such as your name, NIC number and account information. Special measures such as data encryption and authentication apply to all nonpublic personal information and communications on our web site.

Our privacy policies apply only to those individual investors who have a direct customer relationship with us. Investors purchasing or owning units of any of the Funds through their bank, broker, or other financial institution should also consult that financial institution’s privacy policies.