Tortoise Capital Series Trust (the “Trust”) on behalf of each of its series (each a “Fund,” collectively the “Funds”) is committed to acting with integrity and to adhering to the highest standards of business practice. The Trust will work hard to maintain your privacy; however, the nature of our business requires that we collect and, in some instances share, certain information about you with other organizations or companies. Therefore, we want you to be aware of how your personal information will be treated. This Privacy Policy explains how the Trust handles your personal information and the procedures that we will follow to ensure your privacy.
What type of personal information will the Trust collect or receive?
Generally, the Trust does not collect any non-public personal information about you, although certain non-public personal information about you may become available to the Trust from various sources, including:
- Information we may receive from you, such as your name, address and phone number, your social security number and your assets, income, other household information and any other information you may provide to the Trust;
- Information about your transactions with the Trust, our affiliates, or others, such as your account balances, account holdings, transaction history, and claims you make; and
- Information from visitors to our website provided through online forms, site visitorship data, and online information collecting devices known as “cookies.”
How will the Trust use this information?
The Trust does not sell lists of client information or share information between affiliates for marketing purposes. No personal information, regardless of the source, regarding any customer or consumer, may be disclosed except as follows:
- To the employees of the Fund’s investment adviser and administrator in connection with Trust’s business;
- To an affiliate, but the affiliate may disclose the information only to the same extent as the Trust; or
- To nonaffiliated third parties with whom the Trust has a contractual agreement to jointly offer, endorse, market or sponsor a financial product or service; and/or to service and maintain customer accounts including effectuating a transaction.
If you access the Trust’s products or services through another financial intermediary, your intermediary’s policy will govern how it uses your personal information.
Your right to opt out
The Trust does not sell or distribute non-public financial information to third parties; however, if, in the future, the Trust’s policies were to change, you would be notified and provided an opportunity to opt out of the Trust’s disclosure of that information.
How we keep your information secure and confidential
The Trust restricts your personal and account information to those individuals who need to know that information to service your account. The Trust also maintains physical, electronic and procedural safeguards to protect your information.
Disposal of your information derived from a consumer report
In the unlikely event the Trust obtains non-public consumer report information (as that term is defined in Regulation S-P) about you and the Trust no longer needs such information, the Trust will dispose of such information as follows: If such information is in paper form, the Trust will shred any papers containing such information so that such information may not be practicably read or reconstructed. If such information is in electronic form, the Trust will permanently erase such information from the electronic device holding such information such that it can no longer be practicably read or reconstructed.
With respect to each ETF in the Trust (each, an “ETF”), issues and redemptions of its shares at net asset value (“NAV”) occurs only in large aggregations of a specified number of shares (e.g., 50,000) called “Creation Units.” Only Authorized Participants (“APs”) may acquire shares directly from an ETF, and only APs may tender their ETF shares for redemption directly to the ETF, at NAV. APs must be (i) a broker-dealer or other participant in the clearing process through the Continuous Net Settlement System of the NSCC, a clearing agency that is registered with the SEC; or (ii) a DTC participant. In addition, each AP must execute a Participant Agreement that has been agreed to by the Fund’s distributor, and that has been accepted by the Fund’s transfer agent, with respect to purchases and redemptions of Creation Units.
Because of this structure, the Trust does not have any information regarding any “consumers” as defined in Rule 3 of Regulation S-P with respect to any ETFs, and consequently is not required by Regulation S-P to deliver a notice of the Trust’s privacy policy to any ETF shareholders.