Ativo is committed to protecting the confidentiality and security of your private investment records and personal information. Our policies and procedures are designed to safeguard your information and to permit only appropriate and authorized access to and use of this information.

In order to carry out the functions necessary to service your investment account, we collect certain nonpublic personal information from you from the following sources:

• Information we receive from you over the telephone, electronic mail and on investment management contracts or other forms (e.g., your name, Social Security number and address); and
• Information about your portfolio transactions.

We restrict access to your personal and account information to those Ativo employees and service providers and their employees who need to know that information to service your account. We, along with our service providers, maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

You can be assured that Ativo considers your data to be private and confidential, and we will not disclose any nonpublic personal information about you to any unaffiliated third parties, except as permitted or require by law. If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.

If you have any questions or comments about our privacy practice, please call us at 312-263-7600 and ask to speak with our Compliance Officer.