Privacy Statement and Business Continuity Plan
CLIENT PRIVACY STATEMENT
We are Committed to Protecting Your Privacy.
We respect every individual’s right to privacy. We understand the importance you place on the privacy and security of information that personally identifies you or your account information.
Why and How We Collect Personal Information.
We collect personal information about you for the purpose of providing investment advisory services to you, evaluating your financial needs, processing your requests and transactions and providing customer service. The personal information we collect about you may include:
- Information we receive from you to open an account or provide investment advice to you, such as your home address, telephone number and financial information;
- Information that we generate to service your account, such as account statements; and
- Information that we may receive from third parties with respect to your account, such as trade confirmations with brokerage firms.
- Identifiable information, stored in the form of cookies in your computer, relating to your access and use of any of our websites.
We Protect the Confidentiality of Your Personal Information in the Following Manner:
We do not sell personal information to anyone.
We disclose personal information only as required by law or with your permission.
We disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities, or to protect our rights or property.
We use personal information in ways that are compatible with the purposes for which we originally requested it. For example, we will use the information you give us to process your requests and transactions, to provide you with additional information about products and services, or to evaluate your financial needs. To do so, we may share personal information with an agent or affiliate.
We limit the collection and use of personal information to what is necessary to administer our business and to deliver services to you. This may include advising you about our products or services.
When We Share Your Personal Information With Our Affiliates.
In order for us to provide investment advisory services to you, we may disclose your personal information in very limited instances which include:
- Disclosures to companies as permitted by law, including those necessary to service your account, such as providing account information to brokers and custodians;
- Disclosures to companies that perform services on our behalf, such as mailing your account statement to you.
How We Protect Your Personal Information That We Share With Our Affiliates.
When we share personal information with an agent or affiliate, we protect that personal information with a strict confidentiality agreement. Companies that we hire to provide support services or act as our agent must conform to our privacy standards.
Our internal policies prohibit employees who have access to our customer’s personal information from using or disclosing the information except for business use. All employees are required to sign a confidentiality agreement that requires them to protect your personal information.
On occasion we may request that a company that is not affiliated with the Clipper Fund distribute your account statement, a newsletter or other marketing materials. In all cases your personal information is protected by a strict confidentiality agreement. We do not allow any non-affiliated companies to retain your personal information longer than necessary to provide the product, service or information.
Updating Your Personal Information.
We will give you reasonable access to the information we have about
you. Most of this information is contained in account statements that
you receive and applications that you submit to obtain our products and
services. The accuracy of your personal information is important. If you
need to correct or update your personal information, please call us at
800.432.2504. One of our customer service representatives will be happy
to review, correct or update your personal information.
BUSINESS CONTINUITY STATEMENT
Davis Distributors, LLC
Davis Distributors, LLC ("Davis") is the principal underwriter of the fund for which it serves as adviser. Davis has adopted certain Business Continuity Policies and Procedures (the "Plan") which are designed to respond to a Significant Business Disruption (SBD). The Plan will be updated as necessary and will be reviewed annually.
The Plan addresses how Davis will handle disruptive events of varying scope (e.g., an internal business disruption, an external business disruption, an Event during business hours, and an Event during non-business hours). The Plan includes backup systems for critical data and operations, as well as for critical employees. The Plan is designed to continue business operations if an SBD should occur.
Davis Selected Advisers, L.P., the parent company of Davis, has offices in a number of U.S. cities. In the event of a disruption to a single building, a single city, or a region, we may move our staff and operations from the affected office(s) to the closest unaffected office or we may also allow remote access via a secure electronic portal.
In the event of an internal or external SBD, if telephone service is available, our registered persons will take customer orders or instructions and contact our transfer agent on their behalf, and if our Web access is available, our firm will post on the fund site that customers may access their funds and securities by contacting us at one of our office locations.
In the event of a firm-wide disruption or a disruption affecting the securities industry, we will contact our critical counter-parties, such as our transfer agent, custodian and other broker-dealers, to make alternative arrangements to complete those transactions as soon as possible. In addition, Davis maintains daily backup for critical systems and data.
While it is Davis' objective that our recovery time for business resumption is four (4) hours, the recovery objective may be negatively affected by the unavailability of external resources and circumstances beyond our control. While Davis has taken many steps to develop an effective Plan, we cannot guarantee that the systems will always be available or operable after an SBD.
Davis will mail a copy of this Business Continuity Statement upon request to its customers as well as maintain a copy on the fund website. Please contact your fund representative if you have any further questions regarding our Plan or for the most current copy of Davis' Business Continuity Statement.
For more information about the Clipper Fund, including sales charges and expenses, see the prospectus(es). Please read the prospectus(es) carefully before you invest. Davis Distributors, LLC, is the distributor of the Clipper Fund.