It is the policy of The Needham Funds, Inc. (the "Fund") to keep personally identifiable financial information about you as an individual ("nonpublic personal information") confidential, and use or disclose it only as necessary to provide services to you or the Fund or as otherwise required or permitted by law. We may collect the following non-public personal information about you:
- 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
- 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.
We 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.
If you have any questions concerning the Fund's Privacy Policy, please call 1-800-625-7071. | 
May 11, 2008
