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Sit Investment Associates, Inc., its subsidiaries and the Sit Mutual Funds (“Sit”) take their clients’ personal privacy seriously.  In order to provide financial products and services, Sit may collect nonpublic personal information about its clients from the following sources:

• information we receive from account documentation, including applications, contracts, and other forms which may include (but is not limited to) information such as a client’s name, address, tax identification number or social security number, assets and income;
• information about client transactions and communications with Sit, its affiliates, agents or others which may include (but is not limited to) account numbers, balances, and transaction requests made through transfer agents, custodians or third party intermediaries.

Sit does not disclose any nonpublic personal information about its clients or former clients to anyone outside Sit’s organization except as necessary in order to provide services to its clients as permitted by law.  For example, we may disclose nonpublic personal information about a client to a non-affiliated company assisting Sit in servicing client accounts such as providing a portfolio management system and transfer agent services.  To safeguard its client’s personal information, Sit insists that its service providers limit access to personal information to authorized employees and agents and maintain appropriate safeguards.

Sit restricts access to its clients’ nonpublic personal information to those employees who need to know that information to provide products or services to its clients.  Sit maintains physical, electronic and procedural safeguards that comply with federal standards to guard its clients’ nonpublic personal information.

This privacy policy does not apply to a client’s relationship with other financial service providers, such as broker dealers, custodians or other third party intermediaries.