Privacy Policy

I. Purpose

Federal law (Regulations adopted by the Securities and Exchange Commission) requires the following:

• Hanover may only in limited instances disclose nonpublic personal information about a consumer to nonaffiliated third parties;
• Hanover must disclose to all consumers the Companies’ privacy policies and practices with respect to information sharing with nonaffiliated third parties;
• Hanover must provide a method for customers to request that their nonpublic information not be disclosed to nonaffiliated third parties except as allowed by applicable law; and
• Hanover must establish procedures to safeguard the confidentiality and security of customer information.

To ensure that privacy disclosure laws are not violated, Hanover has adopted the policies and procedures set forth in these Privacy Policies and Procedures. These Policies and Procedures are intended to describe Hanover’s policies, educate Employees about related issues and the policies, establish procedures for complying with these policies, monitor compliance with these policies and procedures, and ensure, to the extent feasible, that Hanover satisfies its obligations in this area.

II. Privacy Policy

A. Definitions

1. Consumer: individual or an individual’s legal representative who obtains or has obtained a financial product or service to be used primarily for personal, family or household purposes. A person is a consumer even if the application is withdrawn or denied.

2. Customer: a consumer that has an ongoing relationship with the Companies, whereby the Companies are providing one or more financial products or services to the consumer (e.g., a brokerage client or Fund shareholder).

3. Nonpublic Personal Information includes:

• All personally identifiable financial information; and
• Any list, description, or other grouping of consumers (and publicly available information pertinent to them) that is derived using any personally identifiable financial information that is not publicly available information.

B. Policy Statement Regarding Use and Treatment of Confidential Information

No nonpublic personal information, whatever the source, regarding any customer or consumer, may be disclosed except as follows:

• To other Employees in connection with Hanover’s business.
• To an affiliate, but the affiliate may disclose the information only to the same extent as Hanover.
• To nonaffiliated third parties with whom Hanover has a contractual agreement to jointly offer, endorse or sponsor a financial product or service; and/or to service and maintain customer accounts including effectuating a transaction.

Note: All contracts with non-affiliated third parties creating a joint marketing or servicing agreement with Hanover must contain language prohibiting the disclosure of all nonpublic personal information by the nonaffiliated third party except as necessary to carry out the purpose of the agreement.

C. Procedures Regarding Use and Treatment of Nonpublic Personal Information

Hanover encourages Employees to be aware of and sensitive to the treatment of nonpublic personal information. Hanover prohibits Employees from discussing that information unless necessary as part of their duties and responsibilities to Hanover Furthermore, the Hanover requires that each Employee take precautions to avoid storing nonpublic personal information in plain view in public areas of the Companies’ facilities, and requires that each Employee remove nonpublic personal information from conference rooms, reception areas and other areas where it may be seen by third parties. Particular care should be exercised when nonpublic personal information must be discussed in public places, such as restaurants, elevators, taxicabs, trains or airplanes, where that information may be overheard. Under no circumstances may nonpublic personal information be shared with any person, including any spouse or other family member, who is not an Employee of Hanover and who does not have a reason relating to such Employee’s responsibilities within Hanover to know that information.

D. Procedures

• Nonpublic personal information may not be disclosed to any nonaffiliated third parties unless customers have been previously informed of the disclosure and been given a right to opt-out of that disclosure, as required by law.
• Nonpublic personal information may be disclosed to the extent specifically permitted or required by law.
• Hanover must send a Privacy Notice once during each calendar year to each customer.
• Hanover will examine all new technologies and agreements to ensure that their implementation will not negatively affect the safety of customer/consumer information.
• Hard copy customer/consumer information will be shredded when legally able to be discarded. Computer information will be deleted, and the “trash” also deleted. Old computers’ hard drives will be destroyed before discarding the equipment.

E. Penalties for Violation of Procedures

Any violation of the procedures set forth in these Privacy Policies and Procedures will subject the violating Employee to disciplinary action, including possible termination.

III. Summary

A. Importance of Adherence to Procedures

It is very important that all Employees adhere strictly to these Privacy Policies and Procedures. Any violations of such policies and procedures may result in serious sanctions, including dismissal from employment.

B. Annual Internal Circulation/Certification

These Privacy Policies and Procedures shall be circulated by email or hardcopy at least annually to all Employees, and at least annually each Employee shall be asked to certify in writing that he or she has followed the Privacy Policies and Procedures.

C. Questions

Any questions regarding these policies and procedures should be directed to the Compliance Department at 901-261-5950.