We at Rampart Investment Management Company, Inc. ("Rampart") are committed to preserving the confidentiality of the non-public personal information provided to us by our current, prospective and former clients, including investors in funds that we advise. As part of this commitment, Rampart has adopted the following privacy policies concerning the collection, maintenance, disclosure and disposal of our clients’ nonpublic personal information.

(Note: "We", "us" and "our" refer to Rampart and "you" and "your" refer to our current, former and prospective clients.)

Information We Collect
As the Rampart team works together to achieve your investment goals, you will often share with us non-public personal information, such as your name, address, telephone number, social security number, e-mail address, employment, income and other such personal information about you, your family members and household. You also may share with us certain non-public personal financial information, such as your investment goals, the net asset values of your investments and your banking arrangements, as well as information from/about your financial advisor, investment consultant or other financial institution with whom you have relationships and/or have authorized to provide information to us. We collect and maintain this personal information in order to properly serve your account. We consider protecting it a vital part of our job.

How We Protect Your Information
All of our personnel are trained to comply with our strict policies for protecting your personal and financial information. If we determine that any of our personnel have failed to adhere to our policies, he or she will be subject to disciplinary action.

Disclosure of Information
We do not disclose your non-public personal information except as may be required or permitted by law or otherwise described in this policy.

We may disclose your non-public personal and financial information to our affiliates to, for example, provide you with investment services, improve our service to you, make our procedures more efficient, implement security measures and fight fraud.

We also may disclose information about you to the following types of third parties:

• If you have asked us to work with another investment adviser, securities broker or financial institution, we may disclose your non-public personal and financial information to any of them, as well as to their service providers, legal representatives.


• We also may disclose your non-public personal and financial information to any person acting in a fiduciary or representative capacity on your behalf (such as a trustee of a grantor trust or IRA custodian.)


• We also use custodians, mailing houses and other third-party businesses to manage your account and provide services to you. We may disclose your personal and financial information to these other businesses in order to better serve you.


• We also may disclose your non-public personal information to non-affiliated third parties as permitted or required by law. For example, we may disclose to law enforcement agencies or computer security consultants for the purpose of protecting against fraud and unauthorized transactions or in order to maintain the confidentiality of our records. We may also disclose your non-public personal information to our attorneys and accountants.


• On occasion, we may be required to provide information about you and your transactions to governmental agencies, self-regulatory organizations, industry associations and similar bodies in order to fulfill legal and regulatory requirements. In addition, federal and state laws give people involved in lawsuits and other legal proceedings the right under certain circumstances to obtain information from us, including your personal and financial information. We will comply with these laws to the extent that we are required to do so.

On all occasions when it is necessary for Rampart to share your personal information with non-affiliated companies, Rampart will require that such information only be used for the limited purpose for which it is shared and will advise these companies not to further share such information with others except to fulfill that limited purpose.

We will not sell your personal and financial information to any outside third party. In particular, we do not sell or otherwise disclose our customer lists to unrelated businesses that may try to sell you products and/or services.

Rampart takes its responsibility to protect the privacy and confidentiality of clients’ information very seriously. Rampart maintains appropriate physical, electronic and procedural safeguards to protect your non-public personal information. If we change our policies to permit Rampart or our affiliates to share additional information that we collect and/or maintain about you, or to permit disclosures to additional types of parties, you will be notified in advance, and, if required by law, will be given the opportunity to opt out of such additional disclosure and to direct Rampart not to share such information with such parties.

Please direct your questions about this Privacy Notice to: