Brookshire Privacy Policy

Our Commitment to Privacy

Brookshire is committed to maintaining the confidentiality, integrity and security of personal information about our current and prospective customers. You do not have to contact us to benefit from Brookshire's privacy protections; they apply automatically to all of our clients.

How and Why We Obtain Personal Information

Brookshire takes great care to protect your personal information and when we use it, we do so with respect for your privacy. We may use personal information about you to service and maintain your investment in our Funds; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; or to fulfill legal and regulatory requirements. Brookshire may collect public and non-public personal information about you from any of the following sources:

• Information provided by you or your representative on applications or other forms furnished to a Fund or through other interactions that you or your representative have with the Fund (for example, name, address, Social Security number, birth date, assets and income)
• Information arising from your investments in or accounts with a Fund;
• You or your employer or plan sponsor if Brookshire provides them with recordkeeping services (for example, payroll, human resource, or benefits information)
• Transactional activity in your account (for example, trading history and balances)
• Other interactions with Brookshire (for example, discussions with our customer service staff or information you enter into our Website)
• Information services and consumer reporting agencies (for example, to verify your identity, to assess your credit-worthiness or to better understand your product and service needs)
• Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into a Brookshire managed fund)

Brookshire employs physical, electronic, and procedural controls to safeguard your information. For example, we Funds authorize access to your personal and account information only for personnel who need that information in order to provide products or services to you.  Brookshire does not disclose any non-public personal information about you, except as permitted by law.

If you are a former customer, these policies continue to apply to you; we treat your information with the same care as we do information about current customers.  If you decide to sell your investment in a Fund, Brookshire will continue to adhere to the privacy policies and practices as described in this notice.

How We Protect Your Information

Brookshire considers the protection of sensitive information to be a foundation of customer trust and a sound business practice. We employ physical, electronic and procedural controls to respond to changing requirements and advances in technology.

Within Brookshire and among our service providers, we restrict access to personal information to those who require it to provide products and services to you. We may share the personal information that we collect with the following entities:

• Brookshire corporate affiliates, including internal service providers;
•  Unaffiliated service providers (for example, printing and mailing companies, securities clearinghouses, and other entities who may provide services at Brookshire's direction);
•  Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions);
• Other organizations, with your consent or as directed by your representative or as permitted or required by law (for example, for fraud prevention) .

Brookshire does not share personal information about our customers with unaffiliated third parties for use in marketing their products and services.

Privacy Online

Privacy, security and service in our online operations are just as critical as in the rest of our business. Brookshire employs all of the safeguards described previously, along with the following Internet-specific practices:

• We use firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect Brookshire accounts and systems from unauthorized access;
• We may also place cookies and similar files on your hard drive for purposes such as security, to facilitate site navigation, and to personalize your experience on our site. Our cookies do not identify you by name as an individual or by account number;
• When you visit our Website, we may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on the Website. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our Web design and functionality;
• We may use third party service providers to help us analyze certain online activities. For example, these service providers may help us measure the performance of our online advertising campaigns or analyze visitor activity on our Web sites. We may permit these service providers to use cookies and other technologies, such as Web beacons or pixel tags, to perform these services for Brookshire. We do not share personally identifiable information about our customers with these third party service providers, and these service providers do not collect such information on our behalf.

Your Connection to Brookshire

You may interact with us in various ways, and when you do, we may exchange information with other parties in addition to those described above. For example, if you conduct business with Brookshire through your employer or investment professional, we may exchange the information we collect with them or with others at their direction. If we provide services to you on behalf of your employer, we may also collect and exchange information such as human resource, payroll, banking and insurance data, in addition to the information listed above. Information collected from investment professionals' customers is not shared with Brookshire affiliates for marketing purposes, except with the consent of the investment professional or the customer.