JONAR N. STEIN considers customer privacy to be a fundamental aspect of its relationship with clients. JONAR N. STEIN is committed to maintaining the confidentiality, integrity, and security of its current, prospective and former clients’ non-public personal information. JONAR N. STEIN has developed policies that are designed to protect this confidentiality, while allowing client needs to be served.
In the course of providing its clients with products and services, JONAR N. STEIN and certain of its service providers may obtain non-public personal information about its clients. This information may come from sources such as account applications and other forms, from other written, electronic or verbal correspondence, from client transactions, from client brokerage or financial advisory firm, financial adviser or consultant, and/or from information captured on applicable websites.
As a matter of policy, JONAR N. STEIN does not disclose any non-public personal information provided by its clients or gathered by JONAR N. STEIN to non-affiliated third parties, except as required or permitted by law or for JONAR N. STEIN’s everyday business purposes, such as to process transactions or service a client account. As is common in the industry, non-affiliated companies may from time to time be used to provide certain services, such as preparing and mailing prospectuses, reports, account statements and other information, conducting research on client satisfaction, and gathering shareholder proxies. JONAR N. STEIN (or its affiliates) may also retain non-affiliated companies to market its products, and may enter into joint marketing arrangements with them and other companies. These companies may have access to client personal and account information, but are permitted to use the information solely to provide the specific service or as otherwise permitted by law. JONAR N. STEIN may also provide client personal and account information to their brokerage or financial advisory firm and/or to their financial adviser or consultant.
JONAR N. STEIN reserves the right to disclose or report personal or account information to non-affiliated third parties in limited circumstances where JONAR N. STEIN believes in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities, to protect its rights or property, or upon reasonable request by any of its mutual funds in which clients have invested. In addition, JONAR N. STEIN may disclose information about a client or their accounts to a non-affiliated third party at their request or if the client consents in writing to the disclosure.
JONAR N. STEIN may share client information with its affiliates in connection with servicing a client account, and subject to applicable law may provide a client with information about products and services that JONAR N. STEIN or its affiliates believe may be of interest to the client. The information that JONAR N. STEIN may share may include, for example, information about JONAR N. STEIN’s or its mutual funds’ experiences and transactions with a client, their participation in its mutual funds or other investment programs, their ownership of certain types of accounts, information captured on applicable websites, or other data about their accounts, subject to applicable law. JONAR N. STEIN’s affiliates, in turn, are not permitted to share client information with non-affiliated entities, except as required or permitted by law.
JONAR N. STEIN takes seriously the obligation to safeguard a client’s non-public personal information. In addition to this policy, JONAR N. STEIN has implemented procedures that are designed to restrict access to a client’s non-public personal information to its personnel who need to know that information to perform their jobs, such as servicing a client’s account or notifying a client of new products and services. Physical, electronic, and procedural safeguards are in place to guard a client’s non-public personal information.