Privacy Policy

Background

Pursuant to the Gramm-Leach-Bliley Act, the SEC adopted Regulation S-P which requires certain entities, including the Trusts, to adopt measures to safeguard non-public personal information. Regulation S-P requires the Trusts to provide certain privacy notices to “customers” and, under certain circumstances, “consumers,” as those terms are defined under Regulation S-P.

Bennett Group Financial Services (“BGFS”) is not required to have a separate privacy policy because the Trusts are their sole investment advisory client.

Prevention

The Trusts have adopted policies and procedures to protect non-public personal information obtained by the Trusts about their consumers and customers, a copy of which is included in the Appendix. The policies and procedures include the following safeguards:

  • The Trusts' policy to limit disclosure of non-public personnel information in accordance with Regulation S-P.
  • The Trusts' Privacy Notice is provided to all new customers upon opening an account. Additionally, the Trusts provide the required privacy notice to their customers annually by mailing such notice to existing customers.
  • Extensive policies and procedures are in place to safeguard customers' records and information.
  • The information systems personnel perform ongoing evaluations of the systems containing information about the Trusts' customers to ensure proper security and make changes when appropriate.
  • Contracts with vendors/service providers contain confidentiality provisions with respect to the handling of customer information.

Detection

The Chief Compliance Officer of Bennett Group Financial Services (the “CCO”) monitors compliance with the internal policies and procedures regarding safeguarding non-public personal information, as well as those of the Service Providers, and ensures delivery of the required Privacy Notices.

Correction

In the event that the Trusts' privacy policy is not followed, the CCO has the authority to: (a) make any necessary changes to operational procedures; (b) require additional training; and/or (c) recommend disciplinary actions to the Trusts' Boards or senior management of BGFS, as applicable.



Important Legal Information

Terms of Use

Bennett Group Financial Services, LLC along with its affiliates and service providers, including Bank of New York, (collectively referred to herein as “Bennett Group” “we” or “us”) provide the information on this website (the “website”) as a service to our customers and visitors to be used for informational purposes only. The websites are intended only for your personal, non-commercial use. Please read the Terms of Use and relevant sections of the Important Legal Information carefully and refer to it as often as necessary.

Acceptance of Terms: Read Before Continuing

By using the website you signify your agreement to all terms, conditions, disclosures, and notices contained or referenced in these Terms of Use (the “Terms”). These Terms are a binding agreement between you and us as well as any of our affiliates or assigns. By using or accessing the websites, you accept and agree to be bound by these Terms. Your use of the websites is governed by the Terms in effect on the date each website is accessed by you. We may modify these Terms at any time without prior notice to you. You should review the most current version of these Terms by clicking on the Important Legal Information hyperlink on the bottom of each page of the website. These Terms are in addition to any other agreements between you and Bennett Group, including any customer or account agreements, and any other agreements that govern your use of information, content, tools, products and services available on and through the website.

Mutual Funds

An investment into a mutual fund offered by Bennett Group (i) is not FDIC-insured, (ii) are not deposits or obligations of, or guaranteed by, any bank, and (iii) involve investment risks, including the risk of loss. Certain strategies will use leverage and investors do not retain trading authority over investments in the funds we may advise. An investor's account may not be liquid or transferable. Fees and expenses may offset trading profits. Before investing, consider the investment objectives, risks, charges and expenses of the fund sand its investment options. Contact Bennett Group for a prospectus containing this information and read it carefully.

Limitations On Investment Guidance and Professional Advice

The website is not intended to provide legal, tax, investment or insurance advice. Nothing on the website should be construed as an offer to sell, a solicitation of an offer to buy, or a recommendation for any security by Bennett Group or any third party. You are solely responsible for determining whether any investment, investment strategy, security or related transaction is appropriate for you based on your personal investment objectives, financial circumstances, and risk tolerance. You should consult your legal or tax professional regarding your specific situation.

Information for Foreign Investors

Nothing on the website shall be considered a solicitation to buy or an offer to sell a security, or any other product or service, to any person in any jurisdiction where such offer, solicitation, purchase or sale would be unlawful under the laws of such jurisdiction.

Third Party Sties and Content

The website may link you to other sites on the Internet. These sites may contain information or material that Bennett Group has no control over and has not been involved in the preparation, adoption, or editing of such content. These other sites are not under the control of Bennett Group, and you acknowledge that Bennett Group is not responsible for the accuracy, copyright compliance, legality, decency, or any other aspect of the content of such sites. The inclusion of such a link does not imply endorsement of the site by Bennett Group or any association with its operators.

The website may include general news and information, commentary, tools, quotes, research, and other data concerning the financial markets, or other subjects. Some of this content is supplied by companies that are not affiliated with any Bennett Group entity. Third Party Content is provided on an “as-is” basis. The third party content providers expressly disclaim all warranties of any kind, express or implied, including without limitation any warranty of merchantability, fitness for a particular purpose or non-infringement.

The Third Party content providers and their parents, subsidiaries, affiliates, service providers, licensors, officers, directors or employees, shall not be liable for any direct, indirect, incidental, special or consequential damages arising out of or relating to the use or the inability to use the third party content, including but not limited to damages for loss of profits, use, data or other intangible damages, even if such party has been advised of the possibility of such damages.

Disclaimer of Warranties

ALL MATERIALS, INFORMATION, SOFTWARE, PRODUCTS, AND SERVICES INCLUDED IN OR AVAILABLE THROUGH THE WEBSITE (THE “CONTENT”) ARE PROVIDED “AS IS” AND “AS AVAILABLE” FOR YOUR USE. THE CONTENT IS PROVIDED WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT. BENNETT GROUP AND ITS LICENSORS DO NOT WARRANT THAT THE CONTENT IS ACCURATE, RELIABLE OR CORRECT; THAT THE WEBSITE WILL BE AVAILABLE AT ANY PARTICULAR TIME OR LOCATION; THAT ANY DEFECTS OR ERRORS WILL BE CORRECTED; THAT UNAUTHORIZED ACCESS TO OR MISAPPROPRIATION OF THE CONTENT WILL NOT OCCUR; OR THAT THE CONTENT IS FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. YOUR USE OF THE WEBSITE IS SOLELY AT YOUR RISK. BECAUSE SOME JURISDICTIONS DO NOT PERMIT THE EXCLUSION OF CERTAIN WARRANTIES, THESE EXCLUSIONS MAY NOT APPLY TO YOU.

Disclaimer of Liability

UNDER NO CIRCUMSTANCES WILL BENNETT GROUP, ITS SUBSIDIARIES OR AFFILIATES, OR ITS LICENSORS BE LIABLE FOR ANY DIRECT, INDIRECT, PUNITIVE, INCIDENTAL, SPECIAL, OR CONSEQUENTIAL DAMAGES THAT RESULT FROM THE USE OF, OR INABILITY TO USE, THE WEBSITE, OR THE UNAUTHORIZED ACCESS TO OR THE MISAPPROPRIATION OF ANY CONTENT MADE AVAILABLE ON OR THROUGH THE WEBSITE. THIS LIMITATION APPLIES WHETHER THE ALLEGED LIABILITY IS BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR ANY OTHER BASIS, EVEN IF BENNETT GROUP HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGE. BECAUSE SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, BENNETT GROUP'S LIABILITY IN SUCH JURISDICTIONS WILL BE LIMITED TO THE EXTENT PERMITTED BY LAW.

Indemnification

As a condition of your use of these sites, you agree to indemnify and hold Bennett Group harmless from and against any and all claims, losses, liability, costs, and expenses (including but not limited to attorneys' fees) arising from your use of the sites or from your violation of these Terms.

Governing Law

Unless otherwise agreed, these Terms and their enforcement are governed by the laws of the District of Columbia, without regard to conflict of law, and shall inure to the benefit of Bennett Group's successors and assigns, whether by merger, consolidation, or otherwise.

Severability

If a court of competent jurisdiction deems any provision unenforceable, that provision will be enforced to the maximum extent permissible, and the remaining provisions will remain in full force and effect.



Bennett Group Financial Services' Business Continuity Planning

Bennett Group Financial Services has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us — If after a significant business disruption you cannot contact us as you usually do at (202) 216-4880, you should call our alternative number (202) 834-9082, or go to our website at www.bennettgroupfinancial.com. If you cannot access us through either of those means, you should contact our clearing firms, JP Morgan Clearing Corp at (347) 643-4927 or Charles Schwab at (877) 738-6811 for instructions on how it may provide prompt access to funds and securities, enter orders and process other trade-related, cash and security transfer transactions for our customers.

Our Business Continuity Plan — We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm's books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our clearing firms, JP Morgan Clearing Corp at (347) 643-4927 and Charles Schwab at (877) 738-6811, back up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within 12 hours. Your orders and requests for funds and securities could be delayed during this period.

Our administrator and transfer agent, BNY Mellon, maintains a duplicate set of certain fund records and other important information which can assist us during a significant business interruption. BNY Mellon maintains their own Business Continuity/ Disaster Recovery Plan designed to respond to events that significantly disrupt their business. On a periodic basis, an agent of Bennett Group Financial Services will review certain policies and procedures of BNY Mellon including their Business Continuity/ Disaster Recovery plan and the results of any testing of such plan.

Varying Disruptions — Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within 3 hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within 12 hours. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our website www.bennettgroupfinancial.com on how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer's prompt access to their funds and securities. For more information — If you have questions about our business continuity planning, you can contact us at 202.216.4880.