Nicholas Company, Inc. and its affiliates Nicholas Fund, Inc., Nicholas II, Inc., Nicholas Limited Edition, Inc. and Nicholas Equity Income Fund, Inc. (together, “Nicholas Co.,” “we,” “us,” or “our”) respect your privacy. This GLBA Privacy Notice (the “Notice”) describes how we collect, use, and disclose your Nonpublic Personal Information (as defined below) when you apply for, access, and use our investment services (the “Services”).
For the purposes of this Notice, “Nonpublic Personal Information” or “NPI” means personally identifiable financial information that is not publicly available that you provide to us in connection with any transactions or services we perform for you, or that we otherwise obtain.
1. The NPI We Collect
We collect NPI about our separately managed account investors and mutual fund shareholders from some or all of the following sources:
- Information we receive from the completion of our account forms, fact-finding questionnaires and mutual fund applications;
- Investment transactions with us, our affiliates, and other arrangements for the provision of services to investors or shareholders;
- Consumer reporting agencies; and
- Custodian banks and broker/dealers.
For separately managed account investors, this NPI may include:
- Your name, address, phone number, tax identification number, date of birth, and investment selection,
- Your custodian bank or brokerage account number, account balances and transaction history, and
- Testamentary and other similar documents and information that you provide in connection with your account.
For mutual fund shareholders, this NPI may include
- Your name, address, phone number, tax identification number, date of birth, beneficiary information and investment selection,
- Your account number, account balances, transaction history and cost basis information,
- Your banking information, and
- Testamentary and other similar documents and information that you provide in connection with your account.
2. How We Use NPI
We may disclose NPI we collect from or about you to certain affiliated and nonaffiliated companies in order to more effectively and efficiently provide our services. We provide such NPI pursuant to written contracts which require the recipient to protect the privacy and security of any NPI which we disclose. Affiliated companies are defined as companies related by common ownership or control. Nonaffiliated companies are defined as companies not related by common ownership or control.
Affiliated and nonaffiliated companies with whom we disclose NPI include, but are not limited to:
- Nicholas Co. affiliated companies;
- Transfer agents, to allow for the servicing of mutual fund shareholder accounts;
- The broker-dealer through which we execute separately managed account securities transactions;
- Clearing agencies through which we clear and settle separately managed account securities transactions;
- Third-party investment advisory firms with whom we have relationships for the management of separately managed accounts; and
- Companies that provide services to us that assist with the maintenance of required books and records or to facilitate mailings on our behalf or to provide security for our IT systems and our data.
We do not disclose your NPI to nonaffiliated companies who intend to market their products to you.
3. Protection of NPI
We have established information security practices and procedures designed to prevent unauthorized access to, acquisition of or use of NPI. We only provide access to NPI to employees or service providers who process or service transactions and fulfill compliance, legal or audit functions. Our computer systems utilize protections designed to prevent access by unauthorized personnel, and we employ other physical, electronic and procedural safeguards to ensure the protection of NPI in accordance with federal and state data privacy and security laws and regulations.
4. Contact Us
If you have any questions about our Notice, or if you have any questions concerning your account, please contact us at 1-800-544-6547.
If you prefer, you may write to us at Nicholas Family of Funds c/o U.S. Bank Global Fund Services, P.O. Box 219301, Kansas City, Missouri 64121-9301.
We appreciate your business and look forward to serving your financial services needs.