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APPLIED FUNDAMENTAL RESEARCH, LLC
PRIVACY POLICY

While information is the cornerstone of our ability to provide superior service, our most important asset is our client’s trust. Keeping information secure, and using it only as our clients would want us to, is a top priority for Applied Fundamental Research, LLC.

Here, then, is our promise to our clients:

  • We will safeguard, according to strict standards of security and confidentiality, any confidential information our clients share with us.
  • We will limit the collection and use of client information to that information we require to deliver superior service to our clients, which includes advising our clients about our products, services and other opportunities, and to administer our business.
  • We will permit only authorized employees, who are trained in the proper handling of client information, to have access to that information. Employees who violate our Privacy Policy will be subject to our normal disciplinary process.
  • We will not reveal client information to any external organization, except as necessary to effect or administer a transaction in connection with a client’s trading account unless we have previously informed the client in disclosures or agreements, have been authorized by the client, or are required by law or government regulators.
  • We will tell clients in plain language, initially and at least once annually, our practices and their rights relating to privacy.
  • Whenever we hire organizations to provide support services in the future, we will require them to maintain privacy standards substantially similar to those herein.

We will attempt to keep client files complete, up to date and accurate. We will tell our clients how to request access to their account information (except when we’re prohibited to do so by law) and how to notify us about errors which we will promptly correct.


FORM OF PRIVACY NOTICE

Keeping client information secure is a top priority for Applied Fundamental Research, LLC (“AFR”). We are sending you this privacy notice to help you understand how we handle the personal information about you that we collect and may disclose. This notice tells you how you can limit our disclosing personal information about you. The provisions of this notice will apply to former clients as well as current clients unless we state otherwise.

Our Policies and Practices to Protect your Personal Information

We protect personal information we collect about you by maintaining physical, electronic, and procedural safeguards. We would demand that third parties who have access to personal information about our clients agree to follow appropriate standards of security and confidentiality that meet or exceed applicable law. We have severe limits put upon us by law which limit our sharing this information with third parties.

Categories of Personal Information We Collect and May Disclose

The personal information we collect about you comes from the following sources:

  • Information we receive from you on applications or other forms, such as your name, address, and telephone number.
  • Information about your transactions with us, our affiliates, or nonaffiliated third parties, such as your equity interests, account balances, and account activity.
  • Information we receive from your communications, such as your wiring details and bank account information.

We may disclose any of the above information that we collect to affiliates and nonaffiliated third parties as described below.

Categories of Nonaffiliated Third Parties To Whom We May Disclose Personal Information

We may disclose personal information about a client to the following types of nonaffiliated third parties:

  • Brokerage companies for the purpose of executing trades or administering your fund account.
  • Service companies such as administrators or custodians of the funds, the funds’ accountants or lawyers.
  • Regulatory authorities or law enforcement as may be requested or required by law

At present, AFR shares only that personal information necessary to effect or administer a transaction in connection with your account. While AFR does not foresee any need to make additional disclosures at the present time, we reserve the right to make such disclosures subject to applicable law and your further approval.