Privacy Policy

We recognize and appreciate the importance of respecting the privacy of our clients.  We are committed to safeguarding client information against unnecessary or unauthorized disclosure or access, including personal identifying information of Massachusetts residents held by us.  This Privacy Statement sets forth our current policies and practices with respect to non-public personal information of our clients and former clients.  Please be aware that we may change this policy periodically.  If we do, we will notify you.

We limit the collection, retention and use of individual client information to the minimum amount required to properly serve you and to meet regulatory requirements.  For our clients that are residents of Massachusetts, this means protecting your information in compliance with Massachusetts Law 201 CMR 17.00.  We may collect directly and from subscription documents, questionnaires or other forms non-public personal information about clients such as name, address, social security number, financial information and transactions with us and investment funds managed by us.

The law permits us to share and we will share your information described above with unaffiliated third parties that provide processing and support services on your behalf.  Otherwise, unless we have your consent, we will not share your personal information, except as provided by law.  For example, your information may be disclosed for audit purposes, to attorneys or other professionals, or to law enforcement or regulatory agencies.

We have taken physical, electronic, and managerial measures to safeguard the information we collect.  We emphasize to our employees the confidential nature of client information and the high level of importance we place on maintaining confidentiality.  We restrict access to non-public personal information about you to those employees who need to know that information to provide products or services to you.  To the extent we outsource processing functions and support services to unaffiliated third parties, we limit the information available to them to information necessary or appropriate to offer such processing and support services.  We require that these third parties hold the information we provide in confidence subject to our security standards and only for approved purposes.

In addition to protecting your privacy, we are committed to keeping your non-public personal information, such as your name and address, secure.  To protect the non-public personal information of our clients, we maintain physical, electronic and procedural safeguards that comply with federal regulations and Massachusetts law.  Our service providers also maintain physical, electronic, and procedural safeguards that comply with federal regulations and Massachusetts law to guard your non-public personal information.

We strive to maintain complete and accurate information about you.  If you ever believe our records contain inaccurate or incomplete information, please let us know immediately.  We will correct any inaccuracies as quickly as possible.

You may have additional rights under other applicable domestic or foreign laws.