“Nonpublic personal information“ is nonpublic information about you that we obtain in connection with providing a financial product or service to you.

We collect nonpublic personal information about you from the following sources:

Information we receive from you on applications or other forms, and information about your transactions with us, our affiliates, or others.

We may share your name and address among affiliates for purposes of sending you information about products of ours that we believe may be of interest to you and inform you of our upcoming investors' conference.

We do not disclose any nonpublic personal information about our customers to anyone, except as permitted by law. Examples of permitted disclosures under the law include sharing with companies that work for us to provide you service, such as a transfer agent or mailing house. All such companies act on our behalf, are contractually obligated to keep the information that we provide to them confidential, and use the information only to provide the services that we have asked them to perform for you and us.

We restrict access to nonpublic information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards to guard your nonpublic personal information.

Regarding the information we collect

Some personal and demographic information about you may be collected through our website. In the account access area we may collect a shareholder's account number, social security number, tax identification number or password. The transaction area of the site is hosted and provided by DST, our transfer agent. BaronFunds.com does not control the personal information you provide to DST. We urge you to read DST's privacy policy before providing your personal information.

The e-delivery service, where shareholders and non-shareholders can consent to receiving documents electronically, is provided by Broadridge Financial Solutions, Inc. (formerly ICS, a division of ADP). Shareholders must provide their social security number and email address. Non-shareholders must provide their name, address and email address. For more information on Broadridge's privacy policy, please see their Privacy Notice when you enroll.

Cookies

A cookie is a small text file placed on your computer by a website. Cookies cannot read information from your hard drive. 

BaronFunds.com uses temporary session cookies on all secure pages to assign and store a sessionID to allow you to move uninterrupted between areas of our secure site. This sessionID is also used by us for internal reporting purposes. This sessionID is not personally identifiable to you and this type of cookie does not leave any retrievable information on your hard drive.

You may change your personal information, or request to no longer receive information regarding our products and services at any time by calling BaronFunds.com's toll free number 1-800-99BARON, or by sending us an email at info@BaronFunds.com.

 

PRIVACY NOTICE FOR EUROPEAN INVESTORS

We, Baron Capital Management, Inc., are based in the USA. This Privacy Notice summarizes our policies with respect to personal information of clients, principals, beneficial owners, beneficiaries and investors that we process. This Privacy Notice sets out the kinds of personal information we collect and how that personal information is used.  Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

Personal Information Collected

We receive personal information from Europe-based clients, principals, beneficial owners, beneficiaries and investors which includes:

  • Category 1 – Contact information such as name, title, address, business and/or personal telephone number, business and/or personal email addresses.
  • Category 2 - Verification information such as passport, driving license, utility bill, credit or bank card statement, and country of residence, country of origin/nationality, country of domicile/tax residency, tax reference number, date of birth, and occupation.
  • Category 3 - Business-related information such as the amount invested and details of the investment made, the name of the organization you work for and/or are a controlling person for.

Purposes for Processing Personal Information

We use the personal information held about Europe-based clients, principals, beneficial owners, beneficiaries and investors for the following purposes:

  • Category 1 – To carry out our obligations arising from any agreement entered into with us by or on behalf of clients, principals, beneficial owners, beneficiaries and investors, including contacting such individuals; to contact such individuals with information messages about the investment; and for administration purposes.
  • Category 2 – To complete anti-money laundering checks and other checks as are required by law, if these are not conducted then we will be unable to carry out our obligations arising under any agreement.
  • Category 3 – To tailor our advice and services to clients, principals, beneficial owners, beneficiaries and investors.

Lawful Basis for Processing Personal Information

The lawful basis/bases that we rely upon to process personal information held about Europe-based clients, principals, beneficial owners, beneficiaries and investors is as follows:

  • Category 1 – We use this personal information to carry out our obligations arising from the Subscription Agreement or any other agreement entered into by the clients, principals, beneficial owners, beneficiaries and investors, and to send informational messages to clients and investors to the extent allowed by applicable law.
  • Category 2 - We use this personal information to comply with our legal obligations.
  • Category 3 - We use this personal information to carry out our obligations arising from the Subscription Agreement or any other agreement entered into by or on behalf of the clients, principals, beneficial owners, beneficiaries and investors and where it is necessary for the purposes of the legitimate interests pursued by us.

Disclosure of Personal Information

We do not disclose any personal information about our Europe-based clients, principals, beneficial owners, beneficiaries and investors, to any third parties, except as reasonably necessary or appropriate in connection with the management of the funds, to processors who are only permitted to use it to perform services for is, or as required by law or any applicable regulatory authority, or to protect the rights, property, or safety of our company or its clients or others. In these cases we may share personal information with legal advisers, accountants, fund administrators, companies engaged to dispose of or store data including personal information, and adverse parties who have a legal right to receive such information and their counsel and experts and legal advisers.

We will take all steps reasonably necessary to ensure that where personal information is shared it is treated securely and in accordance with this notice and applicable laws.

Personal Information Retention

We will endeavor not to keep personal information in a form that allows a Europe-based client, principal, beneficial owner, beneficiary or investor to be identified for any longer than is reasonably necessary for achieving the permitted purposes. This means that personal information will be destroyed or erased from our systems or anonymized when it has reached the applicable retention period.

Storage of Personal Information

We may process personal information in and transfer personal information to countries that may not guarantee the same level of protection for personal information as the country in which you reside. 

Personal information will also be processed by staff operating outside the EEA who work for us. This includes staff engaged in, among other things, the provision of administration and support services. All such staff are subject to appropriate confidentiality and security obligations.

We restrict access to personal information about clients, principals, beneficial owners, beneficiaries or investors to those of our employees and agents who need to know the information to enable us to provide services. 

We maintain physical, electronic and procedural safeguards designed to protect your personal information, to prevent unlawful or unauthorized processing of personal information, and to prevent unauthorized disclosure of, or accidental loss of, or damage to, such information.

We will only transfer personal information to a third party service providers if they agree to comply with those procedures and policies, or if they put in place adequate measures themselves.

Rights in relation to Personal Information

You have certain rights in relation to your personal information. These include in certain cases the right to request access to the personal information we hold about you, the right to have inaccurate information amended or updated, the right to object to processing of personal information, the right to have personal information erased or to restrict processing in certain limited situations, the right to request porting of personal information to another organization, and the right to object to automated decision making. You should use the contact information below to get more information and/or to make a formal request.

Europe-based clients, principals, beneficial owners, beneficiaries and investors also have the right to lodge complaints with applicable data supervisory authorities.

We will endeavor to keep the personal information we store about Europe-based clients and investors reasonably accurate and up to date by enabling clients and investors to correct it by request. Clients, principals, beneficial owners, beneficiaries and investors should notify us if any of their personal information changes or if they become aware of any inaccuracies in the personal information we hold about them.

Changes to this Privacy Notice

We reserve the right to modify this Privacy Notice at any time and without prior notice.

Questions

If you have any questions in relation to this Privacy Notice, please contact ClientService@baronfunds.com