Common use of Non-Public Personal Information Clause in Contracts

Non-Public Personal Information. To the extent prohibited by Regulation S-P, the Adviser will not disclose any non-public personal information, as defined in Regulation S-P (“NPI”), received from the Trust regarding any shareholder of the Portfolios. The Adviser represents and warrants that, in accordance with applicable state privacy laws and Regulation S-P, it has implemented safeguards by adopting policies and procedures reasonably designed to insure the security and confidentiality of records and NPI of shareholders; protect against any anticipated threats or hazards to the security or integrity of shareholder records and NPI; and protect against unauthorized access to or use of such shareholder records or NPI that could result in substantial harm or inconvenience to any shareholder.

Non-Public Personal Information. To the extent prohibited by Regulation S-P, the Adviser will not disclose any non-public personal information, as defined in Regulation S-P (“NPIP(“NPI”), received from the Trust regarding any shareholder of the Portfolios. The Adviser represents and warrants that, in accordance with applicable state privacy laws and Regulation S-P, it has implemented safeguards by adopting policies and procedures reasonably designed to insure the security and confidentiality of records and NPI of shareholders; protect against any anticipated threats or hazards to the security or integrity of shareholder records and NPI; and protect against unauthorized access to or use of such shareholder records or NPI that could result in substantial harm or inconvenience to any shareholder.