Privacy

TimesSquare Capital Management, LLC. (TimesSquare) is committed to protecting the privacy and confidentiality of non-public personal customer or visitor information within the sites of the TSCMLLC.com domain. Personal information is any data that identifies customers or their accounts. Any update or change in our policy statement will be prominently noted on the TSCMLLC.com Home pages.

Information Collection

In order to effectively manage our web site and provide the functions required, we may collect personal information in two ways:

1) Submission of account documentation and contact information on forms completed by the customer that include the customer’s name, email and postal addresses and phone number as well as information relative to account set up and subsequent contribution and transaction activity. This information may be submitted in response to an interactive communication or by a secure email.

Customers with established accounts are able to access their investment information in ClientDirect, our online password-protected web site, provided they have proper authorization. Users must set their browsers to accept “cookies”, which are electronic tickets issued by ClientDirect that allow users to access and navigate the site securely. Without the proper “cookie” setting, error messages and warning notifications will occur repeatedly. The terms and conditions for online access to customers’ accounts and any personal information obtained are contained in our customer agreements.

2) Collection of information from visitors who are navigating the public part of our site. The information gathered includes IP address, software used, and domain reported by the browser. We do not use this information to market directly to or solicit business from visitors to TSCMLLC.com.

Information Use

It is our policy not to disclose non-public information about our customers among our affiliated companies, unless there is a legitimate business need, or to any other parties except where required by law or authorized by the customer or customers’ representative. From time to time, TimesSquare may disclose personal information collected from customers to third-party service providers that facilitate the operation of some areas of the site. We require these providers to adhere to our privacy policies for customers and site visitors.

Safeguards

TimesSquare uses the following measures to protect the privacy of clients and visitors. All personal information in our computers is protected from unauthorized access by a secure firewall and database architecture. Access to the information by personnel within TimesSquare is restricted to only those individuals with legitimate business reasons to do so. In instances where personal information is exchanged via the Internet, electronic and procedural methods to safeguard this exchange are used.

The TSCMLLC.com site may contain links to other sites. We are not responsible for the privacy practices or the content of such sites.

The continual use of TSCMLLC.com by customers and visitors within the European Union (EU) is tantamount to their consenting to having personal information they willingly provided processed outside the EU in accordance with the protections described in this statement.

We encourage communication and have provided a number of places on the site for customers and visitors to contact us. Please remember that unless the specific access location says otherwise, any Internet user can access all messages sent to or from this site. To protect privacy, please do not use email to communicate confidential information.

Correction And Removal Of Information

Any personal information provided to us may be corrected or removed from our records by sending a secure email to the appropriate TimesSquare division contact or by requesting an alternative secure way to communicate with us.