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Privacy Notice for California Residents

We are dedicated to doing the right thing and to safeguarding personal information. This Privacy Notice for California Residents (“Notice”) applies to residents of the State of California who are Diamond Hill employees or other representatives of current or prospective investors or clients (“CA Residents”). This Notice describes how Diamond Hill handles the personal information of CA Residents in compliance with the California Consumer Privacy Act of 2018, as amended, by the California Privacy Rights Act of 2020 (together, the “CPRA”).

This Notice applies only to personal information not subject to the federal Gramm–Leach–Bliley Act. Certain personal information collected in connection with providing financial services is exempt from this Notice under GLBA. This Notice complements the notices and disclosures regarding your rights under GLBA and other federal laws and regulations, and we continue to protect such information consistent with those legal and regulatory obligations. For more information, please see Diamond Hill’s Privacy Policy.

Personal Information We Collect

We may collect the following categories of personal information from CA Residents:

  • Identifiers: Such as name, address, email address, telephone number, IP address, or other similar identifiers.
  • Sensitive personal information: Signature, Social Security number, financial information, or other identifiers necessary to open or maintain an account.
  • Protected classification characteristics under California state or federal law: Such as age, citizenship, national origin, or other characteristics protected under applicable anti-discrimination laws.
  • Commercial information : Account activity, investment holdings, or transaction history.
  • Internet or other electronic network activity : Browsing data, analytics, and interactions with our website.
  • Professional or employment-related information: Occupation, employer, or business affiliation.
  • Inferences: Preferences or characteristics drawn from personal information for servicing purposes.

We collect this information from you directly, from your interactions with our website, from third parties acting on your behalf, or from financial advisors, consumer reporting agencies, consultants, or custodians.

Use of Personal Information

We use personal information for the following purposes:

  • To provide our services: To evaluate and process investors’ applications, administer investments in accounts and funds we manage, make and receive payments, communicate with investors in connection with their investments, and verify the identity of investors or their representatives to prevent fraud, money-laundering, or other financial crime. We use sensitive personal information only as reasonably necessary to perform these services or meet legal obligations.
  • To administer accounts and managed funds: To perform audits, implement risk-management processes, uphold corporate governance standards, prepare tax documentation, maintain and monitor information-technology systems, and oversee third-party service providers.
  • For marketing: To communicate with you about Diamond Hill products or services that may be of interest, subject to applicable marketing laws and your contact preferences.
  • For compliance and protection: To enforce our agreements, comply with legal and regulatory obligations, defend against claims or disputes, protect the security and integrity of our services, and detect, investigate, and prevent fraudulent, unauthorized, or unlawful activities.

Disclosure of Personal Information

We do not sell, share, or rent your personal information. We may disclose personal information to:

  • Diamond Hill affiliates: For purposes consistent with this Privacy Notice
  • Service providers and third parties: That perform functions on our behalf or assist in operating our business, such as customer support, custodians, transfer agents, email delivery, marketing, identity verification, fraud prevention, and database administration.
  • Professional advisors: Including attorneys, bankers, accountants, auditors, and insurers, when necessary in the course of the professional services they provide to us.
  • Law enforcement, regulators, government authorities, or other third parties: As required to comply with applicable law, legal process, or to protect our rights, privacy, safety, or property.
  • Other parties: Where you or your authorized representatives direct or consent to such disclosure.

We may also disclose personal information in connection with any divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or bankruptcy or dissolution in relation to our business. Retention periods vary depending on the nature of the data and our regulatory obligations but generally align with our record-keeping requirements under federal securities laws.

Data Retention of Personal Information

We retain personal information for as long as reasonably necessary to fulfill the purposes described above or as required by applicable law, regulation, or record-retention policy. Retention periods vary depending on the nature of the data and our regulatory obligations but generally align with our record-keeping requirements under federal securities laws.

Personal Information Requests

You have the right to request the following with respect to your personal information:

  • Information: Including how we collect and use your personal information. We have made this information available to you without having to request it by including it in this notice.
  • Access: To the personal information that we maintain about you. Where applicable, we will provide this information in a portable, machine-readable, and readily usable format.
  • Correction: Of any personal information that is inaccurate or outdated.
  • Deletion: Of personal information that is no longer needed to provide our services or otherwise maintain for legitimate business or legal purposes.
  • Opt Out and Limit Use: Of personal information. Because we do not sell or share personal information, and do not use sensitive personal information for purposes other than those permitted by the CPRA, these rights do not currently apply. If that changes, we will update this Notice and provide a method to exercise such rights.

You may submit a privacy-related request by calling (614) 255-3333 or emailing info@diamond-hill.com. To protect your information, we may ask for details that help us verify your identity before we act on your request. You may also appoint an authorized agent to act for you. We will require documentation confirming the agent’s identity and authority, in accordance with applicable law.

Exercising your privacy rights will not result in any discriminatory treatment. In some cases, however, we may be unable to fulfill a request if it would interfere with our legal obligations, contractual duties, or the rights of other individuals. We may update this Notice occasionally and will post the date of the most recent revision at the top of this page. If you have concerns about how your request was handled, please contact us using the details above.

DIAMOND HILL® CAPITAL MANAGEMENT, INC. | DIAMOND-HILL.COM | 855.255.8955 | 325 JOHN H. MCCONNELL BLVD | SUITE 200 | COLUMBUS, OHIO 43215
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