The Needham Group, Inc. Privacy Policy

The Needham Group, Inc. is committed to safeguarding your privacy.  This Privacy Statement describes the types of non-public personal information The Needham Group, Inc. Needham & Company, LLC, Needham Capital Partners and Needham Funds collect about you, the ways we safeguard the confidentiality of this information and when this information may be shared with others. In addition, this Privacy Statement explains how your personal information may be shared among our affiliates to make you aware of valuable products and services, and the ways that you can let us know if you prefer that your non-public personal information not be shared.

The following policy applies to users of Needhamgrp.com, Needhamco.com, Needhamcapital.com and Neehamfunds.com, including clients who have a brokerage account with Needham & Company, LLC. By using these websites, you consent to the policies and practices described in this Privacy Statement.

1. Non-Public Personal Information We Collect

In order to provide you with superior products and services and to maintain our relationships with our clients, we may collect certain non-public personal information about you. We obtain this non-public personal information from varying sources, including the following:

(1) Applications forms and other communications. We collect information such as your name, address, telephone/fax numbers, assets, income and investment objectives through these documents. Also, we collect information such as name, address, telephone number, e-mail address through Needhamfunds.com’s “E-Delivery” and “Request Literature” functions.

(2) Consumer reporting agencies. We obtain information about your creditworthiness and credit history through these sources.

(3) Third-party vendors. We collect background information from various outside sources to verify representations you have made to those sources or us.

With respect to The Needham Funds, we may collect the following non-public personal information about you:

(1) Information we receive from you on or in applications or other forms, correspondence, or conversations, including, but not limited to, your name, address, phone number, social security number, assets, income and date of birth; and

(2) Information about your transactions with us, our affiliates, or others, including, but not limited to, your account number and balance, payments history, parties to transactions, cost basis information, other financial information and information about how you vote your shares.

Cookies. As with many websites, our sites use a technology called “cookies.” A cookie is a piece of information that is sent to your browser from a web server and stored on your computer’s hard drive. A cookie allows us to determine that a visit has occurred within our site, as well as which pages were viewed. Cookies are not used to identify you and will not collect personal information.  You can decide if and how your computer will accept cookies by configuring your preferences option within your web browser. If you choose to decline cookies, however, some of the functionality of the Site may be impaired.

2. Information Security

We maintain physical, electronic and procedural security measures to safeguard your non-public personal information. Access to such information is restricted to employees who are trained in the proper handling of personal information. Third parties that provide support or marketing services on our behalf may also have access to the non-public personal information we collect about you while carrying out these services, but are required not to share that information with any other third party. While we employ reasonable measures to protect personal information, we cannot guarantee that unauthorized third parties will not defeat those measures or use non-public personal information for improper purposes.

3. Information We May Disclose to Our Affiliates

In order to service and manage your account(s) effectively, and to provide you with offers for products and services that you may find useful, we may disclose the non-public personal information described above to our affiliates, including our asset management affiliate, Needham Investment Management, LLC.

Offers for products and services from our affiliates are developed under conditions designed to safeguard your privacy and we require these companies to adhere to our privacy standards when handling your non-public personal information. Please see Section 6 for instructions on how you can limit our ability to disclose non-public personal information about you.

4. Information We May Disclose to Third Parties

Needham considers the personal information contained in our business records to be confidential. We will not sell, rent, or share your personally identifiable information with unaffiliated third parties without your consent, except as described in this Privacy Statement.

To the extent permitted by law, we may disclose your personal information to government authorities or third parties pursuant to a legal request, subpoena, or other process that requires disclosure of information or other process that requires disclosure of information. We may also use or disclose your information to enforce compliance with our Terms of Use and as permitted by law to collect debts, fight fraud or protect the rights or property of Needham, our affiliates, our customers or third parties, or when we otherwise believe in good faith that the law requires it.

We may disclose all of the information we collect, as described above to companies that perform marketing services on our behalf, to other financial institutions with which we have joint agreements or others who work on our behalf such as service providers, vendors, contractors and agents. When we share your non-public personal information with other parties that perform services for us, we require that such information only be used for the limited purpose for which it was shared and that those parties not share your information with others except to fulfill that limited purpose.

We do not make any disclosures of non-public personal information to other companies for the purpose of marketing their products or services to you. For example, we do not sell customer lists and we will not sell your name to a catalog company.

The Needham Funds may disclose nonpublic personal information about current and former shareholders to companies that provide necessary services to the Fund. These companies include the transfer agent, distributor, administrator and investment adviser as well as other affiliates of the Fund. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information and restrict access to this information to those persons who need it to provide services to you or the Fund or who are otherwise permitted by law to receive it. In the event that you hold any shares of our funds through a financial intermediary, including, but not limited to, a broker-dealer, bank, or trust company, the privacy policy of your financial intermediary governs how your nonpublic personal information is shared with nonaffiliated third parties.

5. Former Customers

Even if you are no longer a customer (or become a former customer at a future date), our Privacy Statement will continue to apply to the non-public personal information we collected about you.

6. How You Can Limit Our Ability to Disclose Non-Public Personal Information to Our Affiliates

For customers of Needham & Company, LLC and Needham Capital Partners who prefer that we do not share your non-public personal information (other than information about your transactions and experiences with us, your name, address, account number(s) or information necessary to process your authorized transactions) with our affiliates, you may direct us not to share such information ("opt out") by calling us toll free at (800) 903-3268 and asking for the Compliance Department or writing us at the following address:

Needham & Company, LLC
Attn: Compliance/ Privacy Policy
445 Park Ave, 3rd Floor
New York, NY 10022

Needham Capital Partners
Attn: Compliance/ Privacy Policy
445 Park Ave, 3rd Floor
New York, NY 10022

Your written request should state in detail the nature of your request, include your name, address, telephone number and account number(s) and should not be sent with any other correspondence. In order to process your request, we require that the request be provided by you directly and not through a third party.

7. How You Can Update Your Personal Information

You may update your personal information that you submitted to us by contacting us using the methods described above. For investors of The Needham Funds who have any questions concerning the Fund's Privacy Policy can call 1-800-625-7071.

8. Links to Other Websites

Hypertext links to third party websites or information do not constitute or imply an endorsement, sponsorship, or recommendation by Needham of the third party, the third-party website, or the information contained therein. You acknowledge and agree that Needham is not responsible for the availability of any such websites and that we do not endorse or warrant, and is not responsible or liable for any such website, or the content on such website, or the services offered by such website. Needham does not take responsibility for collection of personal information via other websites for which a link is provided on our websites. You should refer to the privacy statements for those websites.

9. Children

Our websites are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under the age of 13, please do not provide personally identifiable information of any kind whatsoever.

10. Non-U.S. Users

If you are located outside of the United States, please note that the information you provide to us will be transferred to the United States. By using these websites, you consent to this transfer. You also consent to the adjudication of any disputes arising in connection with our websites in the federal and state courts of, and in accordance with the laws of, the state of New York.

11. Corporate Change of Control

In the event of a corporate change in control resulting from, for example, a sale to, or merger with, another entity, Needham reserves the right to transfer your personal information to the new party in control. In addition, in the event Needham becomes the subject of a bankruptcy proceeding, whether voluntary or involuntary, we or our trustee in bankruptcy may sell, license or otherwise dispose of such information in a transaction approved by the bankruptcy court.

12. Changes to Privacy Statement

We reserve the right, in our sole discretion, to modify, alter or otherwise update this Privacy Statement at any time and you agree to be bound by such modifications, alterations or updates. We will notify you of material changes to this privacy policy by posting the revised policy with the date it was revised on this page. Your continued use of our websites constitutes your agreement to this privacy statement and any updates. We encourage you to periodically review this privacy statement to stay informed about how we are protecting the personal information we collect.

Effective Date: April 1, 2009

Privacy Policy