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Notice of Privacy Policy

At First Manhattan Co., we recognize the importance of protecting your privacy. To that end, we have adopted policies and procedures designed to maintain the confidentiality and security of your personal and financial information. These policies and procedures are reviewed on a regular basis and revised as deemed necessary and appropriate. This notice is designed to help you understand what information we collect from or about you, how we use that information, and how that information is protected.

For your convenience, you may access and if necessary, correct your account information in a number of ways. You can review your information using your account statements mailed to you by Pershing LLC, a subsidiary of the Bank of New York Mellon Corporation, First Manhattan’s clearing firm. You may also email, write, or call your First Manhattan Money Manager with (i) your request for information or (ii) any changes that you may have concerning your account information. If you have any changes to your account information, please advise your Money Manager.

Categories of Information We Collect

First Manhattan collects nonpublic personal information about you from applications, subscription agreements, and other forms we may ask you to complete. Such information may include name, address, tax identification number, telephone numbers, bank and financial information, etc. In addition, we collect and maintain information about financial transactions you may enter into with us. Finally, in the course of establishing a relationship with us, we may utilize the services of a third party for anti-money laundering purposes or to obtain and/or confirm financial, credit, employment, and related information.

Disclosure of Information

First Manhattan does not disclose information about you or our former clients to service providers (other than information we may disclose in connection with services rendered to First Manhattan related to clearing, accounting, portfolio management, and business operations purposes) or other third parties, except as may be (i) authorized in writing by you, (ii) required by or necessary in accordance with applicable law or regulation, including anti-money laundering or anti-terrorist laws and regulations, or (iii) necessary in order to perform tasks on our behalf in furtherance of providing services to you. In the event that we do disclose client information to service providers, we require such service providers to have processes and policies in place in order to protect the privacy of such information.

Confidentiality and Security

First Manhattan restricts access to non-public personal information about you to those employees and agents who need access to that information in order to provide services to you. We maintain physical, electronic, and procedural safeguards to protect your non-public personal information.

Disposal of Clients’ Consumer Reports

As part of its account opening process, First Manhattan obtains consumer reports concerning its clients. In order to safeguard such consumer reports and information derived from such reports (collectively “Consumer Information”). First Manhattan takes reasonable steps to ensure that such Consumer Information is properly disposed of in accordance with all applicable laws and regulations.