Privacy
Policy

Last Revised April 2022

PRIVACY NOTICE STATEMENT

Your privacy is important to us. We understand and respect the privacy of the non-public personal information we receive from our clients. The purpose of this Privacy Notice is to explain the practices of Fund Evaluation Group, LLC, its affiliated entities, and our website www.feg.com (together “FEG” or “we”) with respect to the collection, use, disclosure, and safeguarding of your personal information. Instances of “you” or “your” in this notice refer to individuals whose personal information is processed by FEG, including clients with direct or indirect relationships (such as through an intermediary); potential clients; employees, officers, and agents (together “Representatives”); and beneficial owners of an organization or entity in connection with:

• Services provided by FEG
• Transactions to which we are a party (including those which we effect on behalf of clients)
• Services provided to us by third-party vendors

This Privacy Notice sets out the purposes for which we collect, use, and disclose (collectively “process”) personal information and how we protect that information. It also sets out individuals’ rights in relation to the processing of their personal information. There may be additional terms, conditions, and commitments that also govern how we collect, use, and disclose your personal information which should be read in conjunction with this Privacy Notice.

INFORMATION WE COLLECT

In order to conduct business with you, FEG sometimes needs to collect your personal, non-public information, from a variety of sources.

Personal information is any information relating to an individual which can be used either alone or with other sources of information to identify that individual. Personal information does not include information where the identity of the individual or the specific detail of the information has been removed and is therefore anonymous. The nature of the information that we collect depends on the services we provide and our relationship with you. We grouped the personal information that we may possess into the following categories (note, however, that the examples provided within each category are not exhaustive):

• Identification data - Full name, title, gender, marital status, date of birth, passport number, driving license number, national identification number (e.g., social security number), and signature
• Contact data - Personal address, telephone number, and email address
• Electronic Monitoring data - To the extent permitted by law, we may record and monitor your electronic communications with us
• Financial data - Bank account number and routing number
• Marketing and Communications data - Marketing and communication preferences, as well as tracking data on the open and read rates of FEG’s marketing communications number, and email address
• Profile data - Username and password to access our online services, as well as your investments, the services you have requested, and any marketing communications or survey responses
• Services data - Payment details and details of services provided (both to you and from you)
• FEG Building Security data - Records of visits to our premises
• Technical data - Your use of and interaction with our online services and website, as well as your IP address, browser type and version, browser plug-in types and versions, and operating system

Sources of Information

We may collect personal information about you in a number of ways, including:

• When you provide it to us in connection with FEG’s services, such as through a completed investment advisory contract, subscription documents, etc.
• If you are a representative of an organization or entity that is a client or vendor of FEG, and that organization or entity provides us with your personal information
• Throughout the course of our relationship with you, including when you change your account details, provide additional personal information, or adjust your request for services
• From public sources where you have manifestly chosen to make your personal information public, including public profiles on social media
• From third parties, such as credit reference agencies
• From visits to our website or through logging into any of our online services
• From third-party vendors that gather your data from publicly available sources, engaged by FEG for the purpose of sourcing and improving business relationships
• From communications from FEG staff

We may also create or derive personal information such as creating records of your interactions with us, subject to applicable law.

Unless indicated that the provision of specific personal information is optional, any personal information we specifically request is necessary for us to provide you or your organization or entity with the products and services requested. If you do not provide the personal information requested, we may not be able to provide those products and services.

Purpose of Personal information Processing

• To evaluate opening an account or entering into a relationship at your request, including performing anti-money laundering, anti-terrorism, sanction screening, fraud, and other due diligence checks
• To deliver the services you have requested, including liaising with third parties (e.g., brokers for the purposes of executing transactions, third-party administrators) and to provide access to our client web portals
• To manage payments, fees and charges, and transfer funds, and to collect and recover any outstanding debt
• To manage our relationship with you, which includes notifying you about changes to our terms of business or this Privacy Notice
• To interact with governmental or regulatory bodies or other competent national authorities
• To detect or prevent fraud and/or other criminal activity and to protect our employees and assets
• To manage and protect our business, including improving data security; troubleshooting data and systems, system maintenance, and testing; data hosting; and managing our offices and other facilities
• To invite you to take part in market insight or other events, client surveys, or client seminars (or similar events) and to manage event participation
• To send you marketing communications, regulatory disclosures, and service updates via paper and electronic channels

Personal Information Disclosures

In connection with one or more of the purposes outlined above, FEG may disclose your personal information to:

• Other staff members of FEG
• Professional advisors, third parties, agents, or independent contractors that provide services to FEG (such as IT systems providers, platform providers, brokers, consultants, attorneys, and accountants)
• Competent authorities, including national regulatory or enforcement bodies, agencies, courts, or tax authorities and/or their agents where FEG is required or allowed to do so under applicable laws or regulations
• A potential buyer, transferee, merger partner, or seller and their advisers in connection with an actual or potential transfer or merger of FEG’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it
• Organizations that help us conduct anti-money laundering and anti-terrorist financing checks and detect fraud and other potential criminal activity. Any person to whom disclosure is allowed or required by local or foreign laws, regulations, or any other applicable instrument

Website & Cookies

FEG’s website and/or its service providers may use a variety of technologies to collect information to help FEG and its service providers understand how the website is used. Information collected from your web browser (including small files stored on your device that are commonly referred to as “cookies”) allows the website to recognize your web browser and helps to personalize and improve your user experience and enhance navigation of the website. This information also allows FEG to recognize, measure, track, and analyze usage. You can change your cookie preferences by changing the setting on your web browser to delete or reject cookies. Note, however, that if you delete or reject cookies, some website pages may not function properly.

Third-Party Website Links

FEG’s website may contain links that are maintained or controlled by third parties, each of which has privacy policies which may differ (in some cases significantly) from the privacy policies described in this notice. Please read the privacy policies of such third parties and understand that accessing their website is at your own risk. This Privacy Notice is not applicable to third-party websites that we do not own or control or to any third-party websites where FEG advertisements are displayed.

Notice Related to the California Consumer Privacy Act (CCPA) and to “Natural Persons” Residing in the State of California

California residents should be aware that this section does not apply to personal information covered by certain sector-specific privacy laws, including the Gramm-Leach-Bliley Act (GLBA) or other information subject to a California Consumer Privacy Act (CCPA) exception.

Your rights under the CCPA (only for natural persons residing in the State of California) include the right to:

• Request information about the personal information that we collect about you and the manner in which we process and disclose that information
• Obtain the specific personal information that we have collected about you in the 12 months preceding your request
• Request that we delete certain personal information that we have collected about you
• Opt-out of disclosures of your personal information to third parties under certain circumstances
• Not be discriminated against as a result of exercising any of the aforementioned rights

You may discuss or exercise your rights by contacting us directly at 888-268-0333 (toll free) or dataprivacy@feg.com

Although you have the right to request that your personal information be deleted at any time, applicable laws or regulatory requirements may prohibit us from doing so. In addition, if you invest in an FEG fund through a financial intermediary, FEG may not have access to your personal information.

In some cases, FEG may need to request specific information from you to help us confirm your identity and ensure your right to access the personal information requested, or to exercise any of your other rights. This is to ensure that personal information is not disclosed to anyone who does not have authority to receive it. We may also require further information to help us to locate the personal information processed in relation to you, including, for example, the nature and location of your relationship with us.

FEG aims to respond to all legitimate requests within 45 calendar days. If we think it may take us longer than 45 calendar days (such as in cases where the request is particularly complex or you have made a number of requests), we will notify you and keep you updated of our progress.

California law requires that FEG describe certain disclosures of personal information where we receive valuable consideration. California law treats such disclosures as “sales,” even if no money is exchanged. We do not sell information to third parties as defined under California law.

Maintenance of Information

FEG has internal procedures designed to maintain accurate records concerning your personal information. Should you ever believe that our records contain inaccurate, incomplete, or out-of-date information about you, please notify us. We will respond to requests to correct information in a timely manner.

Information Security

FEG restricts access to non-public personal information to those employees who need to know that said information in order to provide our products and services to you. We maintain physical, electronic, and procedural safeguards to protect your non-public personal information.

In the event that you end your relationship with us, we will continue to adhere to the policies and practices described in this policy statement.

We reserve the right to amend this Privacy Notice as needed. The revised Privacy Notice will be posted on our website and/or otherwise provided to you.