Privacy Policy

Online Privacy Statement

(last updated: April 2007)

Emerald Asset Management (Emerald) is committed to protecting your privacy and maintaining the confidentiality, integrity and security of your personal information. Please read the Online Privacy Statement below and also any supplemental information for additional details. This Emerald Online Privacy Statement applies to data collected by Emerald through its Web site and services, as well as, its offline product support services. It does not apply to partner sites, services and products that do not display or link to this statement or that have their own privacy statements.

Please note that certain details of this policy may depend on whether you deal with Emerald through an investment professional or directly as an individual investor. If you are a shareholder in one or more of the Emerald family of mutual funds, please also review the related privacy policy of the Funds. If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current and new customers.

Collection of Your Personal Information

In order to access some Emerald services and information, you will be asked to sign in with an e-mail address and password which we will provide to you upon verification of a valid email address. We ask you to provide personal information, such as your e-mail address, name, home or work address or telephone number and may also collect demographic information such as your ZIP code, job title, company and the name of your Emerald contact.

Emerald considers the protection of sensitive information to be a foundation of customer trust and a sound business practice. We employ extensive physical, electronic and procedural controls and we regularly adapt these controls to respond to changing requirements and advances in technology. When you receive newsletters or promotional e-mail from Emerald, we may use web beacons, customized links or similar technologies to determine whether the e-mail has been opened and which links you click in order to provide you more focused e-mail communications or other information.

In order to offer you a more consistent and personalized experience in your interactions with Emerald, information collected through one Emerald service may be combined with information obtained through other Emerald services. We may also supplement the information we collect with information obtained from other companies. For example, we may use services from other companies that enable us to derive a general geographic area based on your IP address in order to customize certain services to your geographic area.

Use of Your Personal Information

Emerald collects and uses your personal information to operate and improve its sites and deliver the services or carry out the transactions you have requested. These uses may include providing you with more effective customer service; making the sites or services easier to use by eliminating the need for you to repeatedly enter the same information; performing research and analysis aimed at improving our products, services and technologies; and displaying content and advertising that are customized to your interests and preferences.

We also use your personal information to communicate with you. We may send certain mandatory service communications such as welcome letters, information on technical service issues and event announcements. Some Emerald servicess may send periodic member letters that are considered part of the service. We may also occasionally send you product surveys or promotional mailings to inform you of other products or services available from Emerald and its affiliates.

Sharing of Your Personal Information

Except as described in this statement, we will not disclose your personal information outside of Emerald and its controlled subsidiaries and affiliates without your consent. Some Emerald services may be co-branded and offered in conjunction with another company. If you register for or use such services, both Emerald and the other company may receive information collected in conjunction with the co-branded services.

We occasionally hire other companies to provide limited services on our behalf such as handling the processing and delivery of mailings, providing customer support, hosting websites, processing transactions or performing statistical analysis of our services. Those companies will be permitted to obtain only the personal information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose. We may access and/or disclose your personal information if we believe such action is necessary to: (a) comply with the law or legal process served on Emerald; (b) protect and defend the rights or property of Emerald (including the enforcement of our agreements); or (c) act in urgent circumstances to protect the personal safety of users of Emerald services or members of the public.

Security of Your Personal Information

Emerald is committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. To help us accomplish this, we take the following steps:

• We employ internal access controls to ensure that the only people who see your information are those with a need to do so to perform their official duties;
• We train relevant personnel on our privacy and security measures;
• We physically secure the areas where we hold hard copies of the information we collect online;
• We regularly back up the information we collect online to insure against loss;
• We use technical controls to secure the information we collect online as appropriate including but not limited to: Secure Socket Layer (SSL), encryption, firewalls and password protections.

If you are sharing a computer with anyone you should always choose to log out before leaving a site or service to protect access to your information from subsequent users.

Use of Cookies, Web Beacons and other technologies to collect information

Emerald Web sites use "cookies" to enable you to sign in to our services and to help personalize your online experience. A cookie is a small text file that is placed on your hard disk by a Web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Cookies cannot be used to run programs or deliver viruses to your computer.

Emerald Web sites use cookies to store your preferences and other information on your computer in order to save you time by eliminating the need to repeatedly enter the same information and to display your personalized content and appropriate advertising on your later visits to these sites. No personally identifiable information is stored in these cookies.

Our Web site may also use other technologies to track which pages on our Web sites our visitors view. This non-identifiable click-stream data helps us understand how visitors use our Web site. You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to sign in or use other interactive features of Emerald sites and services that depend on cookies.

Emerald Web pages may contain electronic images known as Web beacons - sometimes called single-pixel gifs - that may be used to assist in delivering cookies on our sites and allow us to count users who have visited those pages and to deliver co-branded services. We may include Web beacons in promotional e-mail messages or our newsletters in order to determine whether messages have been opened and acted upon.

Emerald may also employ Web beacons from third parties in order to help us compile aggregated statistics and determine the effectiveness of our promotional campaigns. We prohibit Web beacons on our sites from being used by third parties to collect or access your personal information.

Emerald will not sell, lease or rent its e-mail subscriber lists to third parties. While Emerald continues to actively review and implement new technology, such as expanded filtering features, there is no currently available technology that will totally prevent the sending and receiving of unsolicited e-mail. Using tools and being cautious about the sharing of your e-mail address while online will help reduce the amount of unsolicited e-mail you receive.

The Emerald Privacy Policy is provided on behalf of: Emerald Investment Advisory Services including Emerald Asset Management, Emerald Advisers, LLC.

Changes to This Privacy Statement

We will occasionally update this privacy statement to reflect changes in our services and customer feedback. When we post changes to this Statement, we will revise the "last updated" date at the top of this statement. If there are material changes to this statement or in how Emerald will use your personal information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification. We encourage you to periodically review this statement to be informed of how Emerald is protecting your information.

Contacting Us

Emerald welcomes your comments regarding this privacy statement. If you have questions about this statement or believe that we have not adhered to it, please contact us by sending an email to [email protected] or in writing to Emerald, 3175 Oregon Pike, Leola, Pennsylvania 17540.