Client Information Security. Pursuant to the ▇▇▇▇▇-▇▇▇▇▇-▇▇▇▇▇▇ Act, to the extent that the services provided by the Sub-Adviser under this Sub-Advisory Agreement require that the Sub-Adviser have possession or control of any Shareholder Information (as defined below) and the Sub-Adviser actually has possession or control of any such Shareholder Information, the Sub-Adviser 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 after the Sub-Adviser becomes aware of any security breach or acquisition of Shareholder Information in Sub-Adviser’s possession or control by an unauthorized person.
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Client Information Security. Pursuant to the ▇▇▇▇▇-▇▇▇▇▇-- ▇▇▇▇▇▇ Act, to the extent that the services provided by the Sub-Adviser under this Sub-Advisory Agreement require that the Sub-Adviser have possession or control of any Shareholder Information (as defined below) and the Sub-Adviser actually has possession or control of any such Shareholder Information, the Sub-Adviser 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 after the Sub-Adviser becomes aware of any security breach or acquisition of Shareholder Information in Sub-Adviser’s possession or control by an unauthorized person.
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