CinFin Capital Management Company Notice of Privacy Practices

Our Privacy Pledge

CinFin Capital Management believes that information personal to you should be respected and protected. For this reason, CinFin Capital Management is committed to protecting your personal information and using it only as appropriate to provide you with the best possible service. This privacy notice describes our information practices and policies. It applies to our relationship with you if you are an individual who inquires about or obtains products or services from us for personal, family or household purposes.

Gathering and Maintaining Information

In order to provide our products and services, it is often necessary to collect and maintain certain types of customer information. We may collect or retain nonpublic information about you from the following sources:

• Information that comes from you during the application process or other forms that you provide to us, such as your name, address, Social Security number, assets, income and investment objectives
• Information about you from your transactions with CinFin Capital Management or any of its affiliates, such as account balances, trading history and usage
• Information about your transactions with affiliated third parties, such as agents, brokers or other investment providers

Sharing Financial Information

CinFin Capital Management does not disclose nonpublic personal information about its customers or former customers to nonaffiliated third parties, except as permitted by law. Customer information may be shared in certain situations. These include, but are not limited to, sharing information necessary to:

• Process or service a financial product or service that you request or authorize
• Provide information to assist us in processing your application or managing your account(s)
• Protect the integrity and security of your records, including prevention of fraud and unauthorized transactions
• Maintain or service your account with CinFin Capital Management
• Comply with federal, state or local laws, rules and other applicable legal requirements (such as a subpoena)
• Effect, administer or enforce a transaction that includes, but is not limited to:
  • Information that is required or is one of the lawful or appropriate methods to enforce your rights or the rights of other persons engaged in carrying out the financial transaction or providing the product or service
  • Information that is required or is a usual, appropriate, or acceptable method in carrying out the transaction or the product or service of which the transaction is a part, to record, service, or maintain your account in the ordinary course of providing the financial service or financial product
  • Information that you consent or direct be disclosed, provided that you have not revoked the consent or direction
  • Information disclosed to persons acting in a fiduciary or representative capacity on your behalf

CinFin Capital Management Company does not sell your personal information to anyone. We do not disclose your personal information to third parties – people or companies or other entities that are not affiliated with us – for their own marketing purposes. For this reason, no “opt-out” is required.  If we share some personal information about you with third parties without your specific authorization, it is to provide you with products and services that you request or expect from us, and otherwise permitted by law. To whom we make such disclosures depends on the product or service requested or expected and may include a broker/dealer other than the broker/dealer where your account is maintained.

Accurate Information

Maintaining accurate information is essential to protecting the integrity of our customers’ records. CinFin Capital Management takes all precautions, in accordance with reasonable industry standards, to ensure information is current and complete. If you become aware of any inaccurate information, please help us correct it by contacting us promptly.

Security Practices

To further safeguard your information, we limit the availability of your information to CinFin Capital Management personnel. CinFin Capital Management personnel may access your information only for legitimate business purposes and are trained to respect your privacy concerns and to safeguard your personal information. CinFin Capital Management Company also maintains physical, electronic and procedural safeguards to protect your personal information.

A Special Word

You have the right to access the personal information that we collect about you in connection with your relationship with us. If you believe that any of that information is in error, you have the right to request that we correct it. Send your written request to:

CinFin Capital Management Company
ATTN: Chief Compliance Officer
6200 S. Gilmore Road
Fairfield, OH 45014-5141

We will provide a notice of our privacy policy annually, as long as you have a continuing customer relationship with us. This policy may change from time to time. You may also request a copy of our privacy policies and procedures by sending a written request to the above address.

This privacy statement is provided to you pursuant to the Investment Adviser Act of 1940 (15 U.S.C. § 80b-1 et. seq.). Specifically, this privacy statement is provided pursuant to 15 U.S.C. §§ 80b-4, 80b-4(a), & 80b-11. This information also is provided to you pursuant to Regulation S-P: Privacy of Consumer Financial Information – 17 C.F.R. Pt. 248.

Adv. 563 (3/08)