PRIVACY POLICY

We are committed to protecting the privacy of our clients, ensuring that personal information is kept secure and confidential.


WHAT THE POLARIS CAPITAL PRIVACY POLICY EXPLAINS

  • How we handle and protect personal information
  • Protecting the confidentiality of our client information
  • The types of information that we have about our clients and where it comes from
  • How we use information about our clients and why
  • Maintaining client privacy
  • Relationship with Boston Investor Services, Inc.

PROTECTING THE CONFIDENTIALITY OF CLIENT INFORMATION

We consider the privacy and confidentiality of our client information of utmost importance. We do not provide information about current or former clients or their accounts to third parties. We limit access to client accounts to those employees who need to know the information to provide service to you. We provide our Polaris Capital Privacy Policy to our clients when they open a new account and then annually. If we materially change our Polaris Capital Privacy Policy, we will notify you.

INFORMATION WE HAVE ABOUT YOU

We receive information about you from:

  • Your Investment Management Contracts, such as your name and address, social
    security or taxpayer identification number, net worth or salary information
  • Your transactions with us, such as subscription and redemption amounts and bank wiring information
  • Bank or Brokerage Contacts, such as account information and transactions

HOW WE USE INFORMATION ABOUT YOU

We use the information we have about you strictly for account related transactions and management. We may share information for legal or marketing reasons. This information is disclosed with discretion and limited to:

  • We may share information with regulatory authorities and law enforcement officials who have jurisdiction over us or if we are required to do so by United States or other applicable law.
  • With client permission, we may mention client names as part of marketing
    information or as references.
  • If required by law, we may provide share positions in public companies.
  • We may provide performance information for groups of portfolios but will not
    disclose specific client names without your approval.
  • We may share client information with companies under contract to perform services for us on our behalf (such as vendors providing data processing, computer software maintenance and development, transaction processing and marketing services).

HONORING YOUR PRIVACY

We do not disclose to third parties any information that is personally identifiable to you as a client or former client, except as described in this Polaris Capital Privacy Policy. The accuracy and security of your personal information is a priority to us. If you believe that our records are incorrect or if you believe that we have shared your information inappropriately, please contact our compliance officer at (617) 951-0004.

SERVICE PROVIDERS

This policy also applies to the employees of Boston Investor Services, Inc., a service provider for Polaris Capital Management, LLC. Distributed annually to clients of Polaris Capital Management, LLC.

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