Privacy

Privacy Notice

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

Personal information we collect.

We may collect personal information about you for the purpose of processing your requests and transactions, maintaining your account and providing high-quality customer service. This information may include your name, home address, telephone number, date of birth, social security number, and other information such as ACH/wire transfer instructions.

How we collect this information.

We may collect this information through a number of means. For example:

• we receive information from you to open an account;
• we generate information to service your account, such as account statements;
• we may receive information from our affiliates or other nonaffiliated third parties with respect to your account, such as trade confirmations with brokerage firms; and
• we may use cookies, relating to your access and use of any of our websites.

How we use this information.

All financial companies need to share customers’ personal information to run their everyday business and we use the personal information we collect from you for our everyday business purposes. These purposes may include opening an account, processing a transaction for your account, and responding to court orders and legal investigations.

Disclosure to others.

We may disclose your personal information to our affiliates and to nonaffiliated third parties that assist us in servicing your account and have a need for such information, as permitted or required by law, or with your authorization. We require nonaffiliated third-party service providers, via written agreement, to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. These sharing practices are consistent with Federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. We note that the Federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in.

How we protect your personal information.

We do not sell personal information to anyone. Our internal policies prohibit employees who have access to our customers’ personal information from using or disclosing the information except for business use. All employees are required to sign a confidentiality agreement that requires them to protect your personal information.

Updating Your Personal Information.

If you need to correct or update your personal information, please call us at 800.279.0279. One of our investor service representatives will be able to review, correct, or update your personal information.

Supplemental Privacy Notice for California Residents

This privacy notice for California residents (notice) supplements the information contained in the Privacy Notice of Davis Selected Advisers, L.P. and its affiliates (collectively, Davis or us), and applies solely to residents of the State of California (you). We provide this notice to comply with the California Consumer Privacy Act, as modified by the California Privacy Rights Act of 2020 (CCPA) and the regulations issued under it; accordingly, this notice addresses the specific requirements of the CCPA and should be read together with the other Davis privacy notices that apply based on your relationships with us. Any terms defined in the CCPA have the same meaning when used in this notice; that may differ from what those terms mean when we use them in other policies or disclosures.

1. Summary

The CCPA provides specific privacy rights to California residents, including the right to receive a privacy notice and certain rights you may choose to exercise relating to your personal information. Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household. Personal information does not include aggregate or deidentified information or publicly available information.
This notice does not apply to all personal information we may collect about you. The CA Privacy Laws include certain exemptions that may apply to our collection and processing of your personal information. Therefore, it is possible that not all personal information we collect from or about you is fully covered by the CA Privacy Laws. Accordingly, the CA Privacy Laws privacy rights set out herein may not apply to you or to all of your personal information. For example, the following personal information is not covered by the CA Privacy Laws:

•  Personal information that is collected, processed, shared, sold or disclosed pursuant to the federal Gramm Leach Bliley Act (“GLBA”) and implementing regulations is not covered by the CA Privacy Laws. To understand how we collect, use and share your nonpublic personal information in accordance with the GLBA, please read our U.S. Funds Privacy Notice, which is available at the back of your most recently received annual or semi-annual shareholder report or Form ADV, as applicable. 
• Publicly available information, de-identified data and aggregate California resident information (as those terms are used in the CA Privacy Laws) are not personal information for purposes of the CA Privacy Laws.

2. How we collect and disclose personal information

The table below explains the categories of personal information we collect from California residents generally, the sources of that information, the purposes for which we use the information, and the categories of unaffiliated parties to whom we disclose the information for business or commercial purposes. In the chart, we use the term everyday business purposes to encompass the business purposes defined in the CCPA, as well as the following related purposes for which Davis may use personal information:

• To provide the information, product, or service you request or as you may reasonably expect given the context in which we collect the personal information (such as providing client service, personalization, and preference management; providing updated product and service information; and dispute resolution);
• For identity and credential management, including identity verification and authentication and system and technology administration;
• To protect the security and integrity of our systems, networks, applications, and data, including detecting, analyzing, and resolving security threats, and collaborating with cybersecurity centers, consortia, and law enforcement about imminent threats;
• For fraud detection and prevention;
• For legal and regulatory compliance, including all uses and disclosures of personal information required by law or reasonably needed for compliance with our policies and procedures, such as: anti-money laundering programs, security and incident response programs, intellectual property protection programs, and corporate ethics and compliance hotlines;
• For corporate audit, analysis, and reporting;
• To enforce our contracts and to protect against injury, theft, legal liability, fraud, or abuse, and to protect people or property, including physical security programs;
• To deidentify personal information or create aggregated datasets, such as for consolidating reporting, research, or analytics;
• To make back-up copies for business continuity and disaster recovery purposes; and
• For corporate governance, including mergers, acquisitions, and divestitures. 

The personal information we collect includes the following categories of sensitive personal information. Note that the sensitive personal information we collect may vary depending on the nature of your interactions with us and may not include all of the examples listed below. We do not use or disclose sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.

Category	Examples	Collected
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data	Physical location or movements.	YES
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

We obtain the categories of personal information listed above from the following categories of sources: 

• Directly from consumers or their agents. For example, from documents that our clients provide to us related to the services for which they hire us. 
• Indirectly from consumers or their agents. For example, through information we collect from our clients in the course of providing services to them.
• Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically. 
• From third-parties that interact with us in connection with the services we perform. For example, from custodians or broker-dealers who provide financial services to our clients.

We may disclose your personal information to a third party for a business purpose. When doing so, we enter into a contract with the third party describing the purpose of such disclosure and requiring that such personal information be kept confidential and not used for any purpose except to perform the services contracted or respond to bona fide regulatory or law enforcement requests.

In the preceding twelve (12) months, we have not sold any personal information.

3. How long we keep your personal information

We keep the categories of Personal Information described above for as long as necessary or permitted for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

• Your personal information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;  
• Your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected; 
• The personal information is reasonably necessary to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or 
• We are otherwise required or permitted to keep your personal information by applicable laws or regulations. 

Where personal information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact information on our page.

4. Your Rights

If you are a resident of California, you have the right to submit certain requests relating to your personal information as described below. In some circumstances, Davis may be a service provider to other businesses, and is not the proper party to respond directly to your privacy rights requests. If you are a retirement plan participant who would like to make a CCPA request, please submit your request directly to the Plan Sponsor using one of the methods it has designated for submitting such requests. Regardless of your relationship with us, Davis’s website and/or mobile app offer additional options for viewing, accessing, and updating your personal information.

5. The right to know.

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable request, we will disclose the following to you (unless an exception applies):

• The categories of personal information we collected about you, if applicable, including:
  1. The categories of sources for the personal information we collected about you.
  2. Our business or commercial purpose for collecting, selling, or sharing personal information.
  3. The categories of recipients to which we disclosed that personal information.
  4. The categories of personal information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of personal information.
  5. The categories of personal information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of personal information.
• The specific pieces of personal information we collected about you. 

6. The right to delete.

You have the right to request that we delete personal information we collected from you, subject to certain exceptions.

7. The right to correct.

If you believe that personal information we maintain about you is inaccurate, you have the right to request that we correct that information.

8. Non-discrimination

If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.

9. How to submit a CCPA rights request

If you are a California resident, you may exercise the rights described above by submitting a verifiable request to us by either:

Emailing us at one of the applicable email addresses listed below: 

• Davis Funds: [email protected] 
• Selected Fund: [email protected]
• Clipper Fund: [email protected]
• Davis ETFs: [email protected] 
• Davis Institutional: [email protected]
• Davis SMA: [email protected]

Calling us at one of the applicable phone numbers listed below::

• Davis Funds: 800.279.0279
• Selected Fund: 800.243.1575
• Clipper Fund: 800.432.2504
• Davis ETFs: 800.279.0279
• Davis Institutional: 212.891.5512
• Davis SMA: 800.717.3477

If you have an account with us, please have your account information available when you call or log in to our secure website to facilitate verification for requests to know, requests to correct, and requests to delete. If you do not have an account or are unable to log in, you will be asked to provide 2-3 pieces of personal information that we will match against our records to verify your identity.

10. Authorized agents

You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above.

11. Changes to this notice

We reserve the right to amend this notice at our discretion and at any time.

12. Contact information

If you have any questions relating to this notice or how we handle your personal information, please email us or call us at the information listed in Section 9 of this notice.

Business Continuity Statement

Davis Distributors, LLC

Davis Distributors, LLC (Davis), a registered broker-dealer, is a wholly owned subsidiary of Davis Selected Advisers, L.P. (“Davis Advisors”). Davis’ sole activity is to underwrite and distribute shares of registered investment companies and offshore funds that Davis Advisors advises. Davis Distributors, LLC provides underwriting services for Davis Funds, Selected Funds, and Clipper Fund.

Davis has adopted certain Business Continuity Policies and Procedures (the “Plan”) which are designed to respond to a Significant Business Disruption (“SBD”). The Plan will be updated as necessary and will be reviewed annually.

The Plan addresses how Davis will handle disruptive events of varying scope (e.g., an internal business disruption, an external business disruption, an event during business hours, and an event during non-business hours). The Plan includes backup systems for critical data and operations, as well as for critical employees. The Plan is designed to continue business operations if an SBD should occur.

Davis Selected Advisers, L.P., the parent company of Davis, has offices in multiple U.S. cities. In the event of a disruption to a single building, a single city, or a region, we may allow our Mission Critical staff to perform tasks utilizing remote access via a secure Internet portal or we may move certain staff and operations from the affected office(s) to the closest unaffected office.

In the event of an internal or external SBD, if telephone service is available, our registered persons will take customer orders or instructions and contact our transfer agent on their behalf, and if our Web access is available, our firm will post on the fund(s) website that customers may access their funds and securities by contacting us at one of our office locations.

In the event of a firm-wide disruption or a disruption affecting the securities industry, we will contact our critical counter-parties, such as our transfer agent, custodian and other broker-dealers, to make alternative arrangements to complete those transactions as soon as possible. In addition, Davis maintains daily backup for critical systems and data.

While it is Davis’ objective that our recovery time for business resumption is four (4) hours, the recovery objective may be negatively affected by the unavailability of external resources and circumstances beyond our control. While Davis has taken many steps to develop an effective Plan, we cannot guarantee that the systems will always be available or operable after an SBD.

Davis will mail a copy of this Business Continuity Statement upon request to its customers as well as maintain a copy on the fund(s) website. Please contact your fund representative if you have any further questions regarding our Plan or for the most current copy of Davis’ Business Continuity Statement.