Privacy Notice

This notice informs you of the privacy practices of Gurtin Fixed Income Management, LLC dba Gurtin Municipal Bond Management (“Gurtin”) and applies to all non-public personal information of current, prospective, and former clients (collectively, “Clients,” “You,” and “Your”). Our relationship with our clients is Gurtin’s most important asset. We understand that our clients have entrusted us with their private information, and we are committed to maintaining the confidentiality, integrity, and security of that information.

INFORMATION WE COLLECT 
Gurtin will obtain access to non-public personal information through each client’s account application, investment management agreement, and correspondence with Gurtin representatives and through transactions with Gurtin. This information may include:

• Name and address
• E-mail address
• Phone number
• Social security number
• Taxpayer identification number
• Assets
• Income
• Account balance
• Investment Activity
• Accounts at other institutions

In addition, we may collect non-public information from the following sources:

• Information we receive on Subscription Agreements, Mutual Fund account documents, Managed Account Agreements, and other Subscription and Account Opening Documents
• Information we receive in the course of establishing a customer relationship including, but not limited to, applications, forms, questionnaires, and data through our website
• Information about your transactions with us, our affiliates, or others
• Shared Personal Information

HOW WE SAFEGUARD YOUR INFORMATION 

We take our responsibility to protect the privacy and confidentiality of your information very seriously. We maintain physical, electronic, and procedural safeguards to store and secure information about you from unauthorized access, alteration, and destruction, including by restricting access to non-public personal information to those employees responsible for the management and servicing of the Account or to whom access is necessary for another proper business purpose.  

HOW WE SHARE INFORMATION WE COLLECT 

We may disclose the information that we collect, as described above, in the following circumstances: Gurtin may disclose non-public personal information to affiliates and to non-affiliated third parties, such as brokers and custodians, as necessary, to facilitate the acceptance and management of our relationship. We may also disclose non-public personal information to companies Gurtin hires to help administer its business and to affiliates and other financial institutions with whom we have joint marketing 
arrangements. In addition, non-public personal information may be released to the appropriate client or to such client’s authorized agent or representative, if compelled to do so by law, or in connection with any government or self-regulatory organizational request or investigation, or as otherwise permitted by law. 

INFORMATION AUTOMATICALLY COLLECTED ON OUR WEBSITE 

Gurtin uses cookies and similar technology to collect and retain certain technical and navigational information about you and other visitors to Gurtin’s website, such as, for example, device type, browser type, internet protocol address, pages visited, and average time spent on Gurtin’s website (collectively, “Website Data”), unless you expressly opt out of allowing Gurtin to collect such Website Data. This collection is used: to provide a variety of financial services, including investment management and financial advice; to facilitate investment in a variety of investment products; and to engage in marketing and advertising in relation to such products and services. You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you delete or reject cookies, some website pages may not function properly. Gurtin does not look for web browser “do not track” requests.

CHANGES TO THE PRIVACY POLICY 

From time to time, Gurtin may update or revise this privacy policy. If there are changes to the terms of this privacy policy, documents containing the revised policy on the relevant website will be updated.