This privacy notice is intended to inform you how Cramer Rosenthal McGlynn, LLC (“CRM,” “We,” “Our,” “Us”) collects, uses and shares information we collect about you when you interact with us.  This includes information pertaining to our policies relating to nonpublic information of clients, prospective clients and former clients. It is our goal to protect your privacy.

In the conduct of our business, we may collect nonpublic, personal information from you and other sources such as:

• Information reported by you in investment management agreements, subscription documents, purchase applications and any other related documents or forms you filled out and sent to us in connection with your account;
• Information about your transactions with us, our affiliates or others (such as purchases, sales, account balances and average costs);
• Information used to verify your identity, such as certain sensitive personal information, including: (i) social security, driver’s license, state ID card or passport numbers, (ii) phone number(s); (iii) email address; (iv) postal address; (v) date of birth; and (vi) other personally identifiable information;
• Information about any bank account you use for transfers between your bank account and your CRM accounts; and
• Information we receive about you or your accounts as a result of your inquiries by mail, e-mail or telephone.

CRM does not share or disclose any nonpublic, personal information about its current or former customers, except as permitted by law, in order to service your account. We will also release information about you if you direct us to do so, if we are compelled to do so by law, or in connection with a government request or investigation.

In addition, in order to comply with state and federal laws, including anti-money laundering requirements, any information you provide in connection with your account is subject to verification by CRM or a third-party vendor contracted by us for this purpose, or both.

Other Shared Information

So that we can complete transactions you authorize or request, as well as performing certain functions on your behalf, and so that we can provide you information about CRM products, services and funds, we may disclose information we collect about you to third party service providers, including but not limited to companies that provide services to us, such as transfer agents or printers and mailers that prepare and distribute materials to you. Those companies are authorized to use that information only to perform services for which CRM hired them and are not permitted to use or disclose that information for any other purpose. All of the information we collect may be shared among CRM and its affiliates or related persons, all of which are engaged in the financial services business.

Information Safeguarding

CRM will internally safeguard your nonpublic, personal information by restricting access to only those employees who provide products or services to you or those who need access to your information to service your account. In addition, we will maintain physical, electronic and procedural safeguards designed to comply with federal and/or state standards to guard your nonpublic, personal information, and we review and adjust these safeguards periodically in response to advances in technology and industry developments.

What You Can Do

For your protection, you should not provide your account information, user name, or password to anyone. If you become aware of any suspicious activity relating to your account, it is your responsibility to contact us immediately. If you have any questions relating to this privacy policy or concerns about the way in which we have handled information about you, please do not hesitate to send us an email at Legal@crmllc.com.

Use of Third-Party Service Providers

From time to time, we may obtain certain information from third-party internet Service Providers who may collect technical information, including but not limited to browser type, internet address, pages visited, IP address, or operating system, in an effort to assist us in evaluating our client’s online access to Firm information.

How Long We Keep Your Personal Information

We may keep certain personal information for as long as necessary or permitted for the purposes described in this notice or otherwise authorized by law. This generally means holding the information for as long as your personal information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information, or for as long as we are otherwise required or permitted to keep your personal information by applicable laws or regulations.

We Will Keep You Informed

As required by federal law, we will notify you of our privacy policy annually. We reserve the right to modify this policy at any time. Furthermore, in the event CRM becomes aware of any unauthorized access to or use of your personal information, CRM shall notify you as soon as practicable, and in all instances no later than thirty (30) days of becoming aware of such incident.

The Right to Delete (Opt Out) or Update and Correct Information

You have the right to request that we delete personal information we collected from you, subject to certain exceptions. This includes the right to request that we do not disclose your personal information with any non-affiliated third parties, as applicable. If you believe that personal information we maintain about you is inaccurate, you have the right to request that we update or correct that information.

Changes to This Notice

We reserve the right to amend this notice at our discretion and at any time without prior notice to reflect changes in our information practices and applicable law. We suggest that you periodically review this notice for any amendments.

All clients will be provided with a copy of CRM’s current notice upon account inception (the “Initial Notice”) and shall receive a copy of the then-current notice annually thereafter (the “Annual Notice”).

Contact Information

If you have any questions relating to this notice or how we handle your personal information, including making any requests as described above, please email us at Legal@crmllc.com. You may also contact us by phone at 212-326-5300.

This Privacy Notice relates to the following entities:

Cramer Rosenthal McGlynn, LLC

CRM Mutual Fund Trust