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Privacy Policy

This is our policy as of October 2005. This privacy policy applies to individuals, and we reserve the right to change any or all of the principles, along with related provisions, at any time.

You trust us with your financial and other personal information; we in turn are committed to respect your privacy and safeguard that information.

By adhering to the practices described below, we affirm our continuing commitment to protecting your privacy.

Collection and Use of Shareholder Information

Wintergreen Fund and the IRA custodian collect only relevant information about the Fund's shareholders that the law allows or requires us to have in order to conduct our business and properly service you. We collect financial and other personal information about you from the following sources: information you provide on applications or other forms (for example, your name, address, social security number and birthdate); information derived from your transactions with us (for example, transaction amount, account balance and account number); information you provide to us if you access account information or conduct account transactions online (for example, password, account number, e-mail address, alternate telephone number).

Keeping Information Secure

We maintain physical, electronic and procedural safeguards to protect your financial and other personal information, and we continually assess new technology with the aim of adding new safeguards to those we have in place.

Limiting employee access to information

We limit access to personally identifiable information to only those employees with a business reason to know such information.

Use of Personal and Financial Information by Us and Third Parties

We do not sell non-public personal information about current or former customers or their accounts to any third parties, and do not disclose such information to third parties unless necessary to process a transaction, service an account, or as otherwise permitted by law.

Those who may receive this information include the companies that provide transfer agent, technology and administrative services, as well as the investment adviser who is an affiliate of the Fund.

Accuracy of Information

We strive to keep our records of your information accurate, and we take immediate steps to correct errors. If there are any inaccuracies in your statements or in any other communications from us, please contact us or contact your investment professional.

Online Privacy Guidelines

We are firmly committed to protecting our shareholders' personal and financial information online. The following guidelines are designed to help you understand how we gather, use and protect that personal and financial information.



Information Collection, Use and Disclosure

We may provide the following online services for your account - account opening, account inquiry, or account trading - that would permit you to log on to the secure account information areas of our Web site.

We do not collect any personal information about you if you do not log on to the secure account information areas of the Web site. When you do log on to these areas, we collect your password and user identification number. We also give you the option to provide us with an additional telephone number and e-mail address. This information helps us assist you.

Whenever we ask for personal information on our Web site, we use Secure Socket Layer (SSL technology) for transferring data. This technology encrypts, or scrambles, your account information so it is virtually impossible for anyone other than us to read it.

We do not give out your personal information unless we are authorized or permitted to do so. We do not sell your personal information to any third parties.

When Information is Collected and Not Collected

Some areas of our Web site require you to give information, such as your password and user identification number, before you can perform certain tasks (for example, review your accounts or correspond with us). In these cases, the information we request is necessary for us to interact with you. If you choose not to interact with us, you may browse our Web site anonymously, and we will not collect personal information such as your e-mail address. In order to evaluate the usefulness of our site, we also gather and analyze data regarding usage of the site, such as domain name, number of hits, pages visited and length of user session.

Our Use of Cookies

What is a cookie? A cookie is a small piece of information placed on your computer by the Web site you are visiting. It allows the Web site to "remember"or "recognize" your computer during subsequent visits. Although different Web sites use cookies for different purposes, one important function is to allow a site to personalize your experience. For example, a cookie can be used to designate start pages within a site, or to indicate an area of interest to you on a Web site.

Web sites may use two types of cookies.

  • Temporary - cookies that are stored on your computer only during your browsing session, and are automatically deleted from your computer when you close your browser.
  • Permanent - cookies that are stored on your computer and are not deleted when you close your browser. Permanent cookies retain your preferences for a particular Web site, allowing those preferences to remain for future browsing sessions.

How we use cookies. We use temporary cookies on all secure pages. These cookies store a session ID that is not personally identifiable to you, allowing you to move from page to page without having to log in repeatedly. Once you close your browser, the temporary cookie we placed on your computer is deleted from your computer. We do not collect any information from your computer with this type of cookie, and it does not leave any retrievable information on your hard drive.

We use permanent cookies on all secure pages to identify the user on subsequent sessions; we do this to enable us to customize the Web site's graphics to reflect your Fund's logo and look. We do not collect any information from your computer with this type of cookie, and it does not leave any retrievable information on your hard drive.

If you elect not to accept cookies from our system, you will not have access to the secured sections that contain information such as account balances, account applications and account transactions.

How We Handle E-Mail

We preserve the content of your e-mail, your e-mail address and our response so that we can more efficiently handle any follow-up questions you may have and to meet legal and regulatory requirements. It is important to understand that regular non-encrypted Internet e-mail is not secure. Some Fund-related Internet e-mail addresses are provided, but these are for information inquiries of a non-sensitive and non-confidential nature.

We strongly urge you not to send confidential information such as social security or account numbers to us via a non-secure e-mail address. For secure online transmissions of information to us, you should use the "contact us"selection on the section of this site that permits online trading and account balance inquiry. Inquiries sent through the sections of this site that permit online trading and account balance inquiry are secure and use Secure Socket Layer (SSL) encryption. (Secure e-mail is not available on the account opening section of this site.) Because our e-mail response back to you would not be secure, we will not include confidential account information in an e-mail response. You may also contact us by phone, fax or U.S. mail.

Security

We work hard to ensure that our systems are secure and that they meet industry standards. We employ the appropriate firewalls, encryption technology, user authentication systems (e.g., passwords) and access control mechanisms to control access to systems and data. The following are key aspects and procedures of our security program:

  • You will be required to change your temporary password for a permanent one when you logon for the first time. Keep a record of your permanent password in a safe place.
  • All transactions (including account inquiry, account trading and establishing an account) are secured by Secure Socket Layers (SSL) and encryption. SSL, which is used to establish a secure connection between your PC and our server, transmits information in an encrypted and scrambled format.
  • Because our security software is enhanced with RSA Public Key encryption, we can provide you with the highest security level available, with up to 128-bit encryption.
  • Encryption is achieved through an electronic scrambling technology that uses a "key" to code and then decode the data. Encryption acts like the cable converter box you may have on your television set. It scrambles data with a secret code so that no one can make sense of it while it is being transmitted. When the data reaches its destination, the same software unscrambles the data.
  • Our advanced security system lets you access your mutual fund accounts without having to buy special software. For maximum security for your transactions, access online trading from the most current public, non-beta release of Microsoft Internet Explorer browser.
  • An additional security feature protects your account from unauthorized use by automatically suspending use after five unsuccessful log on attempts.
  • For added security you should exit the secure area by closing your browser.

What You Can Do To Increase Security

  • For maximum security for your transactions, access online trading from the most current public, non-beta release of Microsoft Internet Explorer browser
  • We discourage using beta- or pre-released versions of Web browsers because of potential security lapses.
  • Keep your password in a secure place.
  • Change your password frequently, which you can do from this site.
  • If you leave your Internet access equipment unattended while signed on, your account is at risk. Remember to exit online transactions before leaving your Internet access equipment.
  • Take all possible precautions to keep your Internet access equipment clean and free from viruses that could be used to capture password keystrokes or affect your hard drive.
  • Stay informed about your account and make sure your records match ours. View and reconcile transactions in a timely manner. Be aware of the activity in your account and contact us immediately to report any discrepancies.
  • Do not access your account from public Internet terminals. These terminals may keep unencrypted copies of your data on their local hard drive.

Hyperlinks

This Web site may contain hyperlinks that enable you to visit other sites. Other sites may have hyperlinks to this site. You should be aware that Web sites linking to and from this site may have different privacy practices than ours. It is assumed that visitors to our site will read the privacy statements of this and other Web sites they visit. However, our privacy statement applies solely to information contained on this Web site. Because we cannot control information on other Internet sites, we are not responsible for the content of sites linked to or from this Web site nor for the privacy policies given on those sites.

You Can Count On Our Commitment to Your Privacy

You can count on us to keep you informed about the procedures and the technology we use to protect your privacy and limit the sharing of information you provide to us, whether in a mailed application, over the phone or through the Internet.

Issued by Wintergreen Fund
U.S. Bancorp Fund Services, LLC
IRA custodian

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