We are committed to maintaining your personal data in accordance with the requirements of data protection/data privacy legislation and attempts to ensure that your personal data is kept secure against unauthorized access or disclosure.

The personal data you supply will be processed by us, associated companies, employees, and/or agents to administer the service(s) that you request us to provide. This may involve the transfer of data by electronic media including the internet.

Unless indicated, the personal data you supply is necessary to enable us to provide the requested service. Failure to provide requested information may mean that we cannot provide the service you require. Your information will be held in confidence and not passed to any company or person, other than as already indicated, without your permission or unless required by law.

By adhering to the practices described below we affirm our continuing commitment to protecting your privacy.

Collection and use of client information:

Kothar Capital collects only relevant information about our clients that is either necessary or helpful in order to conduct our business and properly service our clients.

We collect financial and other personal information about you from the following sources:

Information you provide on applications or other forms (for example, your name, address, assets, social security number and birth date).

Information derived from your transactions with us (for example, transaction amount, account balance and account number).

Information you provide to us if you access account information or conduct account transactions (for example, password, account number, e-mail address, alternate telephone number, etc.).

Keeping information secure:

We maintain physical and procedural safeguards to protect your confidential financial and other personal information.

Limiting employee and agent access to information:

We limit access to personally identifiable information to those employees or third party agents/providers with a business reason to know such information.

Use of personal and financial information by us and third parties:

We do not sell non-public personal information about current or former customers or their accounts to any third parties, and do not disclose such information to third parties unless necessary to process a transaction, service an account, or as otherwise permitted by law. Those who may receive this information include the companies that provide transfer agent, custody, technology and administrative services, as well as any investment adviser or advisors handling your accounts or funds as necessary. Additionally, we have in place a business agreement with Stratis Business Centers, who provide us with administrative and secretarial services. Pursuant to this agreement, employees of Stratis may at times handle confidential client data. We have a confidentiality agreement in place with Stratis Business Centers to preserve the confidentiality of such data.

Accuracy of information:

We strive to keep our records of your information accurate. If there are any inaccuracies or changes in your information or in any other communications from us, please contact us or contact your investment professional.

Online privacy guidelines:

We are firmly committed to protecting our shareholders' personal and financial information online. The following guidelines are designed to help you understand how we gather, use and protect that personal and financial information.

Information collection, use, and disclosure:

We do not collect any personal information about you online. We do not give out your personal information unless we are authorized or permitted to do so. We do not sell your personal information to any third parties.

When information is collected and not collected:

You may browse our web site anonymously, and we will not collect personal information such as your e-mail address. In order to evaluate the usefulness of our site, we also gather and analyze data regarding usage of the site, such as domain name, number of hits, pages visited and length of user session.

Our use of browser cookies:

A cookie is a small piece of information placed on your computer by the Web site you are visiting. It allows the Web site to “remember” or “recognize” your computer during subsequent visits. Although different Web sites use cookies for different purposes, one important function is to allow a site to personalize your experience. For example, a cookie can be used to designate start pages within a site, or to indicate an area of interest to you on a Web site. How we use cookies: We do not use cookies on our Web site.

How we handle email:

We preserve the content of your e-mail, your e-mail address and our response so that we can more efficiently handle any follow-up questions you may have and to meet legal and regulatory requirements. It is important to understand that regular non-encrypted Internet e-mail is not secure. Our e-mail addresses are provided, but these are for information inquiries of a non-sensitive and non-confidential nature. We strongly urge you not to send confidential information such as social security or account numbers to us via a non-secure e-mail address. Because our e-mail response back to you would not be secure, we will not include confidential account information in an e-mail response. You may also contact us by phone, fax or U.S. mail.

This privacy policy applies to individuals, and we reserve the right to change any or all of these policies, along with related provisions, at any time.