Privacy Policy

Commitment to Consumer Privacy

We are committed to handling investor information responsibly. We recognize and value your expectation that all personal data will be kept private. It is our belief that one of our fundamental obligations is to treat each shareholder account with the utmost confidentiality and safekeeping even after you have closed your account with the Fund.

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Collection of Consumer Information

The Fund collects and retains personal information only when it is allowed by law and when we reasonably believe it would be useful to better serve you.

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We collect nonpublic information from:

• Account applications and other forms that you submit to the Fund;
• Correspondence, written or electronic, and/or telephone contacts with us;
• The transaction history of your account(s) with the Fund;
• Information made available from a third party (i.e. IRA transfer applications).
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Disclosure of Consumer Information

We do not disclose your information to anyone, except regulatory agencies, companies that are or would be service providers and/or tax authorities as required by law.

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Security of Consumer Information

We restrict access of your records to those employees and service providers who are involved in administering these accounts. The Fund upholds policies and procedures designed to assure only authorized entrance to and use of investor information. We consistently maintain physical, electronic and procedural safeguards that comply with federal standards to protect the information that you have given to us. Also, we require our service providers to maintain policies, procedures and safeguards designed to secure our investors’ information as described above. Our privacy policy applies only to Fund investors who have a direct customer relationship with us. If you own Fund shares through a relationship with a third-party broker, bank, investment adviser, or other financial service provider, such third party’s privacy policies may apply to you while our privacy policies may not.