PRIVACY POLICY

This policy is provided by Junto Capital Management LP ("Junto") on behalf of its funds, and sets forth Junto's policies with respect to the collection, sharing and protection of non-public personal information you provide to Junto.  These policies apply to individuals and individual retirement accounts only and may be changed at any time, provided a notice of such change is given to you.  Please read this Privacy Notice carefully to understand what we do.

We collect personal information, such as your address, social security number, assets, transaction and/or income information, for example, when you: (i) provide it to us in the Subscription Agreement and related documents; (ii) provide it to us in correspondence and conversations with Junto's representatives; or (iii) make transactions with Junto, such as when you purchase securities from us, tell us where to send money or make a wire transfer.  We also may collect your personal information from other sources, such as affiliates.

We may disclose information about our investors, prospective investors or former investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non-affiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process your transactions, maintain your account(s), respond to court orders and legal investigations or to host this website.  Thus, it may be necessary, under anti-money laundering and similar laws, to disclose information about our investors in order to accept subscriptions from them.  We will also release information about you if you direct us to do so.  We do not share your information with non-affiliates for them to market to you.  We may disclose your information for our own marketing purposes, such as to offer our products and services to you.  We may also disclose information about your transactions and experiences with us to our affiliates for their everyday business purposes.  You cannot limit these types of sharing.

This web site may use "cookies," which may automatically collect certain information and data.  "Cookies" are small pieces of data sent to your computer browser from Junto's web server and stored on your computer's hard drive.  The data identifies you as a unique user and facilitates your ongoing access to and use of this web site.  Cookies also help Junto diagnose problems with Junto's server.

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law.  These measures include computer safeguards and secured files and buildings.

If you have any questions about Junto's Privacy Policy, please feel free to contact Junto at compliance@juntocap.com.