Privacy Notice

I.          Introduction

This Privacy Notice applies to the collection of personal information about visitors to this website (“you”) by Ruane Cunniff LP and Sequoia Fund, Inc. (“we” or “us”) through your interaction with this website. By accessing, visiting or using the website, you acknowledge your understanding of this Privacy Notice. If you do not agree with the contents of this Privacy Notice, you should not access, visit and/or use the website.

This Privacy Notice may be modified at any time without prior notice to you. Your continued access, visitation and/or use of the website will constitute your acceptance of any changes or revisions to this Privacy Notice.

II.         Collection of Your Personal Information

We may collect personal information about you (such as your name, address, social security number, assets and income) when you contact us using the website or using the contact information provided on the website. We may collect personal information from our discussions with you, from documents that you may deliver to us and in the course of providing advisory services to you. We may use this information to open an account for you, to process a transaction for your account or otherwise in furtherance of our business.

III.        Sharing of Your Personal Information

We may share your personal information with others, including the following categories of third parties:

Service Providers. We may share your personal information with Service Providers that perform services for us, such as a broker, but only for the purpose of and to the extent necessary to perform those services.

Affiliates. We may share your personal information with our parent, subsidiaries, affiliates and other related entities, and our advisors, including lawyers, consultants, accountants, auditors and others.

Marketing Communications. We may use your personal information to communicate with you about services offered by us.

Health, Safety, and Legal Requests. We may share your personal information for purposes of health, safety and other matters in the public interest. We may also share your personal information to cooperate with official investigations or legal proceedings brought by or otherwise involving governmental and/or law enforcement officials, as well as private parties, including, for example, in response to subpoenas, search warrants, court orders, or other legal process. We may also use personal information to protect our rights and property and those of our agents, clients, and others including to enforce our agreements, policies, and terms of use.

Transfer or Sale of Our Business. If we, or our parent, subsidiaries, affiliates or other related entities, are involved in a business transaction, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving us or our parent, subsidiaries, affiliates or other related entities, we may share your personal information in connection with such transaction. We may also share your personal information to legal, financial, insurance, or other advisors in connection with such business transaction or management of all or part of our business or operations.

IV.       Protection of Your Personal Information

Security Measures. We restrict access to your personal information to our employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your personal information.

No Liability for Breach. Because no security system is impenetrable, we cannot guarantee the security of your personal information. By using the website, you agree to assume all risk in connection with your personal information. We are not responsible for any loss of such personal information or the consequences thereof.

Breach Notification. If we believe the security of your personal information in our possession or control may have been compromised, we may seek to notify you subject to applicable laws and regulations governing such notifications.

V.        Cookies and Related Technologies

Cookies. We do not place and/or store code or other types of information and/or software on your Device or within your browser, such as cookies, locally shared objects, and HTML5.

Do Not Track. California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how a website operator responds to “Do Not Track” (“DNT”) browser settings. DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third-party ad networks, social networks and analytic companies. We do not currently take actions to respond to DNT signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a DNT standard once one is created. For information about DNT, visit All About DNT.

Shine the Light. California’s “Shine the Light” law, Cal. Civil Code §1798.83, gives California customers the right to prevent our disclosure of their personal information to third parties for those third parties’ direct marketing purposes and requires certain businesses to respond to requests from California customers asking about the business’s practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place.