Bahl & Gaynor, Inc.
Privacy Statement

The relationship between Bahl & Gaynor and our clients is the most important asset of our firm. We strive to maintain your trust and confidence in us, an essential aspect of which is our commitment to protecting your personal information. We believe that all of our clients value their privacy, so we will not collect or use your personal information or communicate or disclose your personal information to anyone unless it is permitted by law, is at your direction or with your consent, or is necessary to provide you with our services. We require our employees to uphold our privacy standards.

Bahl & Gaynor requires all persons associated with Bahl & Gaynor to preserve the confidentiality of information that they may obtain in the course of our business and to use such information properly and not in any way adverse to our clients’ interests, nor to obtain an advantage for themselves or for another person, subject to the legality of such information.

Bahl & Gaynor collects and maintains your personal information so we can provide investment management services to you. The types of information we collect and maintain about you name, email address, phone number, mailing address, account number, social security number, social insurance number, etc. Such information may come from sources such as account applications, investment policy statements, from your transactions and other forms of written, electronic or verbal correspondence from you, your broker, custodian, attorney, accountant or other advisors you may employ.

In order for us to provide investment services to you, we may disclose personal information in very limited instances to outside third party organizations that is essential in administrating our operations. In particular, we disclose name, email address, phone number, mailing address, account number, social security number, social insurance number, etc. to banks, brokers, regulatory entities, etc. to facilitate transactions. We reserve the right to disclose or report personal information where we believe in good faith that disclosure is required or permitted under law, to cooperate with regulators or law enforcement authorities. There are circumstances where Bahl & Gaynor may decide to buy, sell, or reorganize its business. Under these circumstances, it may be necessary to disclose or receive personal information with prospective or actual purchasers, acquisition targets, partners, or affiliates. In such circumstances, Bahl & Gaynor will ensure your information is used in accordance with this Notice.

We have not and will not sell or exchange your personal information to anyone.

We do not knowingly collect or use information from individuals under the age of eighteen (18) without parental or guardian consent. We do not target our services to minors, and would not expect them to be engaging with our services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly. If we are aware of any personal information that we have collected about minors under the age of 18 without authorization or consent, we will take steps to securely remove it from our systems.

To fulfill our privacy commitment to you we maintain physical, electronic and other safeguards to protect your personal information. We maintain password protected systems, updated anti-virus and anti-spyware software, and encrypted hardware and software firewalls. However, no entity can ever promise 100% security. You have a responsibility, as well, to safeguard your personal information and not provide to Bahl & Gaynor unnecessary sensitive information unless specifically requested.

Depending on where you are located, you may have the right to request to access your personal information, verify the accuracy of such information, update or rectify your information, request deletion, request a portable copy of the personal information, or to withdraw consent to collection, use and/or disclosure of your personal information, subject to certain limitations and restrictions as well as appropriate proof of identity. Such requests may be submitted to our Compliance Officer at 255 East Fifth Street, Suite 2700, Cincinnati, OH 45202. Please advise Bahl & Gaynor promptly of any changes to your information, or any suspected inaccuracy or misuse of your information.

For clients in Canada, your personal information may be transferred to, and processed in, countries outside of Canada. Bahl & Gaynor, our affiliates and third-party service providers and partners operate in the United States. This means that when we collect your personal information, such information may be processed in any of these countries, and accordingly, may be accessible to courts, law enforcement and national security authorities of those countries. If you have any questions or wish to obtain further written information about our policies and practices with respect to the collection, use, disclosure or storage of your personal information by service providers or affiliates outside of Canada, you may contact our Compliance Officer at 255 East Fifth Street, Suite 2700, Cincinnati, OH 45202.

Occasionally, Bahl & Gaynor is asked to share a list of representative clients. Only with client consent, Bahl & Gaynor may share the names of clients on such list. Bahl & Gaynor will not disclose contact information, asset size or imply any endorsement for Bahl & Gaynor. Additionally, the Representative Client List also includes the following disclosure: “It is not known whether these representative clients approve or disapprove of Bahl & Gaynor’s investment services. These representative clients were not selected for their performance record or assets under management.”