Privacy Policy

EMPOWERED FUNDS is strongly committed to preserving and safeguarding our clients’ personal financial information. Confidentiality is extremely important to both us and our clients, and we therefore take strict measures to protect the confidentiality and security of our clients’ personal information.

Personal Information

To provide financial planning and investment services, we collect nonpublic personal information from our clients. The categories of nonpublic personal information collected from a client depend upon the scope of the client engagement. It may include information about the client’s personal finances, information about transactions between the client and third parties, information from custodians, banks, or other financial institutions, information from the client’s other advisors, and information collected from written or verbal communications with the client. We do not disclose any of our clients’ personal information to anyone except as permitted or required by law. We do not disclose any of our clients’ personal information to affiliated or nonaffiliated third parties (such as our clients’ other professional and/or service providers) without our clients’ authorization and consent and only for the purpose of providing services on our clients’ behalf. Federal law allows you the right to limit the sharing of your NPI by “opting-out” of the following: sharing for affiliates’ everyday business purposes – information about your creditworthiness or sharing with non-affiliates to market to you. State laws and individual companies may give you additional rights to limit sharing. Please notify us immediately at our address or telephone number if you choose to opt out of these types of sharing.

Security

EMPOWERED FUNDS has instituted certain technical, administrative and physical safeguards through which EMPOWERED FUNDS seeks to protect personal information about current and former clients from unauthorized use and access. First, technical procedures are used in order to limit the accessibility and exposure of client information contained in electronic form. Second, administrative procedures are used in order to control the number and type of employees, affiliated and nonaffiliated persons, to whom customer information is accessible. Third, physical safeguards have been established to prevent access to client information contained in hard-copy form. As these procedures illustrate, EMPOWERED FUNDS realizes the importance of information confidentiality and security, and emphasizes practices which are aimed at achieving those goals.

Questions

EMPOWERED FUNDS welcomes questions and comments about our Privacy Policy. Please call us at +1.215.882.9983.

Privacy Policy Notification

EMPOWERED FUNDS will provide clients with a privacy notice (the “Privacy Notice”) when the client engages EMPOWERED FUNDS for advisory or other services. EMPOWERED FUNDS shall distribute an updated Privacy Notice to all of its clients on or before March 31 of each year, even if the policy has not changed since the previous year. Privacy Notices shall be sent by electronic mail unless otherwise requested by the client, and may be included in a quarterly report, newsletter or other client mailing. The Privacy Notice will also be available via our website. The Compliance Officer is responsible for evaluating EMPOWERED FUNDS’s compliance with this privacy policy. Compliance deficiencies must be addressed by the Compliance Officer and brought to the immediate attention of EMPOWERED FUNDS’s management.