Privacy Policy

Data Privacy and Protection of Nonpublic Information

Regulation S-P requires certain SEC-regulated entities, including the Funds, to adopt a policy and procedures to protect various records and information of the Funds' customers. The regulation is designed to prevent financial institutions from disclosing various types of non-public information gathered from individual clients to unaffiliated entities.

Under Regulation S-P, the Funds are generally prohibited from providing non-public information about a customer to an unaffiliated third-party unless they provide the customer with an initial and annual "privacy notice" giving the customer the option of withholding consent to the sharing of the information. If a customer decides to "opt out," the Funds must comply, i.e., cease sharing the information with unaffiliated entities, as soon as reasonably practicable.

Fund officers are responsible for ensuring that the following policies and procedures are implemented:

1. The Company is committed to protecting the confidentiality and security of the information it collects and will handle personal customer and consumer information only in accordance with Regulation S-P and any other applicable laws, rules and regulations. The Company will undertake to ensure: (a) the security and confidentiality of customer records and information; (b) that customer records and information are protected from any anticipated threats and hazards; (c) that customer records and information are protected from unauthorized access or use and (d) that customer records and information are disposed of in a manner reasonably designed to maintain such security and confidentiality.

2. The Company conducts its business affairs through its trustees, officers and third parties that provide services pursuant to agreements with the Company. The Company does not have any employees. It is anticipated that the trustees and officers of a Trust who are not employees of service providers will not have access to customer records and information in the performance of their normal responsibilities for the Company.

3. The Company may share customer information with its affiliates, subject to the customers' right to prohibit such sharing.

4. The Company may share customer information with unaffiliated third parties only in accordance with the requirements of Regulation S-P. Pursuant to this policy, the Company will not share customer information with unaffiliated third parties other than as permitted by law, unless authorized to do so by the customer.

Consistent with these policies, the Company adopts the following procedures:

1. The Company will determine that the policies and procedures of its affiliates and service providers are reasonably designed to safeguard customer information and only permit appropriate and authorized access to and use of customer information through the application of appropriate administrative, technical and physical protections.

2. The Company will direct each of its service providers to adhere to the privacy policy of the Company and to their respective privacy policies with respect to all customer information of the Company and to take all actions reasonably necessary so that the Company is in compliance with the provisions of Regulation S-P, including, as applicable, the development and delivery of privacy notices, the maintenance of appropriate and adequate records, and appropriate destruction of such records.

3. The Company requires its service providers to provide periodic reports to the Company’s Board of Trustees outlining its privacy policies and the implementation of such policies. Each service provider is required to promptly report to the Company’s Board any material changes to its privacy policy before, or promptly after, the adoption of such changes.