Commitment to Privacy
At The Boston Company Asset Management, LLC ("The Boston Company"), we take the issue of privacy very seriously. We want to assure visitors to our Web site of the security, privacy and confidentially that they expect from a premier financial services institution.
Information Collected
The Boston Company does not collect any personal information from anyone who is merely visiting or browsing our Web site. Personal information may be collected if the visitor chooses to send The Boston Company an e-mail message.
E-Mail and Product Inquiry
Visitors of our Web site are encouraged to send e-mail messages to us so that we may respond to inquiries regarding The Boston Company and our products or services. The Boston Company retains copies of these e-mail messages. The information provided by a visitor will only be used to respond to the visitor’s inquiry and to provide better customer service.
Important Notice for The Boston Company Clients
Please be advised that The Boston Company will never contact you by e-mail to request or confirm personal account information or any other type of sensitive information. If you do receive an e-mail that asks you to provide or confirm sensitive information (such as passwords or sign-on IDs) or personal information (such as social security numbers, credit card numbers or personal bank account numbers), please assume that the request is fraudulent. Some e-mails, links or websites may even include The Boston Company logo or resemble existing The Boston Company internet sign-on pages. Despite the graphics, you should continue to assume that the request is fraudulent because The Boston Company will never contact you by e-mail to request or confirm personal or sensitive account information. If you receive e-mail requests to visit a website or to submit personal information, consider them fraudulent and notify The Boston Company immediately. We strongly recommend that you do not visit the site, submit your personal information via the site or e-mail, or respond in any way.
Use of Information Collected
The Boston Company uses the information collected from visitors to our Web site to address the specific needs of those visitors and to provide better customer service, including the provision of the latest information regarding financial products and services offered. The information collected also is used to provide a record of communications between The Boston Company and our Web site visitors and to comply with any applicable legal and/or regulatory requirements.
Access to Information Collected
Employees. Certain of the employees of The Boston Company will be provided with a visitor’s information in order to respond to that visitor’s needs and provide the visitor with information regarding specific products or services in which the visitor may have an interest. The Boston Company employees are instructed to use care in handling the personal, confidential information of The Boston Company customers, and the guidelines regarding the handling of such information are discussed in our Code of Conduct. The Boston Company employees who do not conform to The Boston Company’s confidentiality rules are subject to disciplinary sanctions that include dismissal.
The Boston Company Affiliates. The Boston Company is a wholly owned subsidiary of Bank of New York Mellon Corporation ("BNY Mellon") and a member of its Bank of New York Mellon Asset Management ("BNY MAM") group. BNY Mellon and its subsidiaries, such as the other members of the Bank of New York Mellon Asset Management ("BNY MAM") group, along with nonrelated service providers that assist The Boston Company in meeting the needs of its customers, may receive personal information collected from a Web site visitor. Such information will be disclosed only in an effort to respond to the visitor’s needs and provide information to the visitor about other financial products and services offered. The personal information is treated with the same standards of confidentiality that The Boston Company itself uses, as the employees of The Boston Company’s affiliates are subject to Bank of New York Mellon Corporation’s Code of Conduct, and The Boston Company’s non related service providers are legally bound to employ strict standards of confidentiality.
Third Parties. The Boston Company does not transmit any personal information collected through its Web site to any third-parties. Personal information may be transmitted, however, if there is a specific need to complete a transaction requested by the visitor. The Boston Company offers the opportunity to its Web site visitors to link to the Web pages of third parties who provide products and services not offered by The Boston Company. Once the visitor leaves the The Boston Company site, The Boston Company does not receive any information from the visitor.
The Bank of New York Mellon Corporation Policy on the Protection of Social Security Numbers
"We" refers to the family of companies owned by The Bank of New York Mellon Corporation.
Like all financial services companies, we collect a variety of information about individuals, including but not limited to our customers and employees. In many cases that information includes individuals' Social Security numbers. We use records of Social Security numbers for many purposes, especially to comply with federal and state laws such as tax laws and anti-money-laundering laws.
Our policy is (i) to comply with all laws restricting the use and disclosure of Social Security numbers, (ii) to protect the confidentiality of Social Security numbers, (iii) to prohibit the unlawful disclosure of Social Security numbers, and (iv) to limit access to Social Security numbers to our employees, and in certain cases to nonaffiliated parties that provide services to us, based on their responsibilities. To safeguard Social Security numbers, we maintain physical, electronic, and procedural safeguards that are designed to comply with applicable legal standards. Our employees are prohibited from disclosing Social Security numbers for unauthorized purposes.
We may share Social Security numbers among our affiliated companies or with nonaffiliated parties for administrative purposes, such as to process transactions, verify identities, and service accounts. We disclose Social Security numbers as required or permitted by law, such as to the Internal Revenue Service or to credit bureaus. When necessary, we disclose Social Security numbers to regulatory agencies, law enforcement agencies, courts, and parties to lawsuits.
We may share Social Security numbers among our affiliated companies for marketing purposes, but only in compliance with legal restrictions, including required opportunities to opt out of such sharing. We do not, without consent of the individual involved, share Social Security numbers with parties not affiliated with us to enable them to market their own products or services.