Client Information Security. It is generally expected that the Sub-Adviser shall not be provided with Shareholder Information (as defined below); however, in the event that the Sub-Adviser agrees to receive this information, then pursuant to the ▇▇▇▇▇-▇▇▇▇▇-▇▇▇▇▇▇ Act, the Sub-Adviser will implement reasonable measures that are designed to: 1) Ensure the security and confidentiality of any of the Fund’s shareholder personal information (“Shareholder Information”) in Sub-Adviser’s possession or control; 2) Protect against any anticipated threat or hazards to the security or integrity of Shareholder Information; 3) Protect against unauthorized access to or use of Shareholder Information that could result in substantial harm or inconvenience to any Fund shareholder; and 4) Ensure the proper disposal of Shareholder Information. The Sub-Adviser also agrees to notify Adviser as soon as possible of any security breach or acquisition of Shareholder Information by an unauthorized person.
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Client Information Security. It is generally expected that The Adviser shall not share or have shared on its behalf Shareholder Information with the Sub-Advisor. Notwithstanding the foregoing, in the event the Sub-Adviser shall not be provided with receives Shareholder Information (as defined below); howeverInformation, in the event that the Sub-Adviser agrees to receive this information, then pursuant to the ▇▇▇▇▇-▇▇▇▇▇-▇▇▇▇▇▇ Act, the Sub-Adviser will agrees to implement reasonable measures that are designed to:
1) Ensure the security and confidentiality of any of the Fund’s shareholder personal information (“Shareholder Information”) in Sub-Adviser’s possession or control;
2) Protect against any anticipated threat or hazards to the security or integrity of Shareholder Information;
3) Protect against unauthorized access to or use of Shareholder Information that could result in substantial harm or inconvenience to any Fund shareholder; and
4) Ensure the proper disposal of Shareholder Information. The Sub-Adviser also agrees to notify Adviser as soon as possible of any security breach or acquisition of Shareholder Information by an unauthorized person.
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Client Information Security. It is generally expected that the Sub-Adviser shall not be provided with Shareholder Information (as defined below); however, in the event that the Sub-Adviser agrees to receive this information, then pursuant Pursuant to the ▇▇▇▇▇-▇▇▇▇▇-- ▇▇▇▇▇▇ Act, the Sub-Adviser will agrees to implement reasonable measures that are designed to:
1) Ensure the security and confidentiality of any of the Fund’s shareholder personal information (“Shareholder Information”) in Sub-Adviser’s possession or controlcontrol (it being acknowledged that it is not anticipated that the Subs-Advisor will possess or control such Shareholder Information during the duration of this Agreement);
2) Protect against any anticipated threat or hazards to the security or integrity of Shareholder Information;
3) Protect against unauthorized access to or use of Shareholder Information that could result in substantial harm or inconvenience to any Fund shareholder; and
4) Ensure the proper disposal of Shareholder Information. The Sub-Adviser also agrees to notify Adviser as soon as possible of any security breach or acquisition of Shareholder Information by an unauthorized person.
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