Todd Asset Management LLC Privacy Policy Disclosure

We Respect Your Privacy

Thank you for your decision to invest with us. Todd Asset Management LLC (TAM) has always placed a high value on the trust and confidence our clients place in us. We believe that confidence must be earned and validated through time. In today's world, when technology allows the sharing of information at light speeds, trust must be reinforced by our sincere pledge to take the steps necessary to ensure that the information you share with us is treated with respect and confidentiality.

Federal law gives consumers the right to limit some but not all sharing of personal information. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do. "Personal information" refers to the non-public financial information obtained by TAM in connection with carrying out our services.

Our Pledge to Our Clients

• We collect only the information we need to service your account and administer our business.
• We are committed to keeping your information confidential, and we place strict limits and controls on the use and sharing of your information.
• We make every effort to ensure the accuracy of your information.

We Collect the Following Nonpublic Personal Information About You

• Information we receive from you on or in investment agreements or other forms, correspondence, or conversations, including, but not limited to, your name, address, phone number, social security number, assets, income, and date of birth; and
• Information about your transactions with us, or others, including, but not limited to, your account number and balance, payment history, parties to transactions, cost basis information, and other financial information.

We May Provide Information to Service Your Account

All financial companies need to share customers' personal information to run their everyday business. Therefore, it is necessary to provide information about you to other companies in order to process transactions, maintain your account(s), and respond to court orders or legal investigations. These organizations have a legitimate business need to see some of your personal information in order for us to provide our service to you. We may disclose to these service providers the information that we collect as described above. We require that these companies strictly maintain the confidentiality of this information and abide by all applicable laws. We never sell our client information.

Categories of Information We Disclose and Parties to Whom We Disclose

We do not disclose any nonpublic personal information about our current or former clients to nonaffiliated third parties, except at your direction or as required or permitted by law. TAM does not have any affiliated companies.

We Place Strict Limits and Controls on the Use and Sharing of Your Information

To protect your personal information from unauthorized access and use, we use security measures that comply with federal low. These measures include computer safeguards and secured files and office space.