Privacy Policy

We collect certain nonpublic information about you (“Client Information”). The essential purpose for collecting Client Information is to allow us to provide advisory services to you. Client Information we collect may include:

• Information that you provide on applications or other forms. This Client Information may include personal and household information such as income, spending habits, investment objectives, financial goals, statements of account, and other records concerning your financial condition and assets, together with information concerning employee benefits and retirement plan interests, wills, trusts, mortgages and tax returns.
• Identifying information such as your name, age, address, social security number, etc.
• Information about your transactions with us, or others (e.g., broker-dealers, clearing firms, or other chosen investment sponsors).
• Information we receive from consumer reporting agencies (e.g., credit bureaus), as well as other various materials we may use to provide an appropriate recommendation or to fill a service request.

We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information.

We do not disclose the nonpublic personal information we collect about our clients to anyone except: (i) in furtherance of our business relationship with them and then only to those persons necessary to effect the transactions and provide the authorized services (such as broker-dealers, custodians, independent managers etc.); (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, consultants, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law.

We are permitted by law to disclose the nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or share the information for any other purpose.

If you decide to close your account(s) or become an inactive client, we will adhere to our privacy policies, which may be amended from time to time.

In the event there were to be a material change to our privacy policy regarding how we use your confidential information, we will provide written notice to you. Where applicable, you would be given an opportunity to limit or opt-out of such disclosure arrangements.

If you have questions about this privacy notice or about the privacy of your client information call our main number 781-341-7250 and ask to speak to the Chief Compliance Officer, Luis Raposo.