Privacy Policy

Driehaus Capital Management LLC

Driehaus Capital Management (USVI) LLC

Driehaus Mutual Funds

Our Privacy Policy

In providing financial services and products to you, we or our service providers will collect certain nonpublic personal information about you. Our policy is to keep this information confidential and strictly safeguarded, and to use or disclose it only as needed to provide services to you, or as permitted by law. Protecting your privacy is important to us.

Information We Collect

The nonpublic personal information we have about you comes from sources such as account applications and forms, from other written, electronic or verbal correspondence, from other financial advisers or consultants, among others, and includes what you provide when you open an account, buy shares of one of our mutual funds or otherwise communicate with us or with a third-party who has obtained your consent to share such information with us. This information may include, but is not limited to your name, address, social security number, date of birth, investment objectives and experience, financial circumstances, employment and your account and account transactions, e-mail address, driver’s license number or passport number age, marital status, income level, occupation, information relating to your specific financial condition, We may also collect information through your use of our website, including device identifiers and IP addresses.

Information We Disclose

We disclose nonpublic personal information about you only to our affiliates, to third parties we hire to help us provide products and services to you, as specifically authorized by you, or as otherwise allowed or required by law. We do not sell your personal information to anyone.

How We Safeguard Your Information

We have physical, electronic and procedural safeguards in place that are designed to protect the security and confidentiality of your information. These include confidentiality agreements with companies we hire to help us provide services to you, password-protected user access to our computer files and strict confidentiality policies that apply to all Driehaus personnel.

Our privacy policy applies equally to our former customers, clients and Fund shareholders. If you would like more information, please call us at 1-800-688-8819.

Questions & Answers

Who is giving me this Notice?

This Privacy Notice is from the Driehaus Mutual Funds, Driehaus Capital Management LLC and Driehaus Capital Management (USVI) LLC.

Why Am I Receiving This Notice?

We are sending to you or posting this Privacy Notice on our website to let you know how we treat personal nonpublic information about you, as a present or former Driehaus Mutual Fund shareholder or as a client of one of the Driehaus companies named above.

What Types of Information About Me Do You Collect?

We gather various types of information about you when you inquire about our products or services, during the account opening process and throughout your on-going relationship with us. See the section above entitled “Information We Collect” for a list of this information. We also have records of your account transactions, including the dollar amounts you have invested or withdrawn, your account balances and our communications with you. We may receive additional information about you from custodian banks, prime brokers, or others that service your account.

How is information about me used?

We use information about you to provide our financial products and services to you, such as managing your investment account or servicing your Driehaus Mutual Fund account. We share this information among the Driehaus Mutual Funds and companies. We also may disclose it, as permitted by law, to third parties that we use to provide our services to you, including outside broker-dealers, custodian, administrators, transfer agents, accountants or attorneys. From time to time, we must give information about our business to regulatory authorities. This may include personal information about you.

We do not sell personal non-public information about our clients, investors, Fund shareholders, employees or third persons to marketers.

For California Residents Only

In addition to our Privacy Policy, the below notice is provided to California residents who are clients or employees of or have a business relationship with us.

The California Consumer Privacy Act (“CCPA”) gives you the right to know what personal information we intend to or have collected about you and why. For clients and investors of DCM and Driehaus Mutual Funds, this information was explained in our Privacy Notice.

For employees, including former and prospective employees and business relationships, in addition to the personal information noted in our Privacy Policy, we may also collect employee number and photographic/video imagery, criminal history, political views and activity, personal trading account information, industry memberships, gender/gender identification, education level, housing type, number of children and other familial relationships, financial condition including credit scores, bank/credit/debit accounts, assets, debts, biometric data including physiological, biological and behavioral characteristics, health information, information such as personal preferences, attitudes, characteristics, tendencies and behaviors, internet or other electronic network activity such as browsing history, search history, login credentials and information regarding interactions with an internet web site, application or advertisement. We may also collect information on your charitable involvement and giving, geolocation, professional affiliations, licenses and disciplinary events, employment history, experience, performance and compensation, information on any legal proceedings, convictions judgments and garnishments, information relating to any business activities, property purchases, business contact information.

We collect this Personal Information directly and indirectly from you or through electronic technologies through which you interact with us, such as our internet and intranet sites, internal computer and communications networks, email and voice mail messages and systems, text and instant message systems and third-party services such as LinkedIn and Facebook. We also collect information via other electronic means such as physical access control technologies, reception logs, closed circuit TV. In addition to the reasons we collect personal data as explained in our Privacy Policy, we also collect and use personal information in connection with operating our business and for employee personnel matters such as hiring, management and other human resource functions, benefit administration, facilities management and operations.

We do not sell any personal information we collect. Personal information is only shared for legitimate business or employee related purposes.

The CCPA also provides you the right to request access to specific pieces of information we have collected from you. You also have the right to request that we delete personal information about you, however we may not be able to delete personal information if we are required to retain this information for legal or ongoing business purposes. You can contact us at 1-800-688-8819 or by submitting a request through our website at www.driehaus.com/contact.

If we do not delete certain items of Personal Information because we have a legal right or obligation to retain that information, we shall notify you of that. Further, if we do not delete certain items of Personal Information because we have a legal right or obligation to retain that data, we shall delete that information at such later time that we no longer have a legal right or obligation to retain that information.

We are not required under CCPA to provide information to you about our collection of your Personal Information or our sale and disclosure of Personal Information about you more than twice within a 12-month period. Additionally, we may refuse to honor unfounded or excessive repetitive requests to us or charge a reasonable administrative fee for honoring those requests, and in either case, will notify you of our decision.