Keeping your Information secure is one of our most important responsibilities. We maintain physical, electronic and procedural safeguards to protect Customer Information. Appropriate employees are authorized to access Customer Information for business purposes only. Our employees are bound by a code of ethics that requires confidential treatment of Customer Information and are subject to disciplinary action if they fail to follow this code.

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

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. Personal information may be collected if the visitor chooses to send The Boston Company an e-mail message. 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 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.

Information Collected from Representatives of Institutional Clients

If you work for one of our institutional (business) clients, we may obtain from you or your firm your business contact information, such as your name, title, office address, business phone number and email address. We may use this information for the purpose of conducting business with your firm, managing our relationship with your firm, and advising your firm of products and services that we believe might be of interest. We may (i) share this information with affiliated companies within the BNY Mellon corporate enterprise, (ii) disclose it to service providers that we use to process the information and that have agreed to confidentiality restrictions, and (iii) export this information to the United States and other jurisdictions where we, or our service providers, do business. We may also disclose this information as required by law.

Use of Cookies and Similar Technologies

We use cookies, web beacons and similar technologies (called "Cookies" in this policy) to store information, enhance your browsing experience and improve the functionality of our websites and web-based applications (called "Websites" in this policy).

You should be aware that disabling Cookies may affect the appearance of our Websites on your device and limit your browsing experience (including preventing access to any secure areas of our Websites where relevant).

What is a Cookie?

A Cookie is a small file placed on your device when you visit certain websites.

"Session" Cookies are temporary and will expire at the end of a browser session; that is, when you leave a website. Session Cookies allow a website to recognize you and carry information as you navigate between pages during a single browser session and allow you to use the website most efficiently.

"Persistent Cookies", in contrast, remain in the Cookie file of your browser even after you leave a website and after the browser is closed. They enable a website to recognize you on your return, remember your preferences and provide tailored services to you.

For more information about Cookies, how they work, why they are so useful and how to disable them, please visit www.allaboutcookies.org

How The Boston Company Uses Cookies

The Boston Company uses both session and persistent Cookies in the following ways:

  • Remembering your preferences, including your preferred language and country, or products and services of interest to you.
  • Enabling us to provide the services you requested on our Websites, including (where relevant to secure areas of our Websites) by identifying and authenticating you.
  • Where relevant to secure areas of our Websites, remembering your user ID so that you do not have to input it every time you visit our Websites.
  • Measuring your use of our Websites so that we can improve them, enhancing your overall experience.
  • Measuring the effectiveness of our newsletters and advertising campaigns (we may use Cookies from third parties to help us do this) and determining whether newsletters have been opened and acted upon.
  • To allow you to share certain information on our Websites via social media bookmarking buttons (Cookies from third parties may be used to do this).

Some of our Cookies may collect and store your personal information. We are committed to respecting and protecting your privacy and will ensure that all personal information collected by us is kept and treated in accordance with our privacy policy.

Managing Cookies

Most browsers are initially set to accept Cookies. However, you have the ability to change your internet browser settings. It may also be possible to configure your browser settings to enable acceptance of specific Cookies or to notify you each time a new Cookie is about to be stored on your device enabling you to decide whether to accept or reject the Cookie. You can also disable Cookies by configuring your browser setting to reject Cookies. Please refer to the help section of your browser for instructions on disabling Cookies.

If you do not wish to accept Cookies from this Website please either disable them or refrain from using this Website. If Cookies are disabled, it may mean that you experience reduced functionality or will be prevented from using some or all of this Website.

Third Party Sites

Our Websites may contain links to third party sites (including social media bookmarking buttons which enable you to share certain content on our Websites). Please review the Cookie and privacy policies of these sites to understand how they may use Cookies and your information.

Third Party Advertising

We may use third party advertising companies to serve ads on our behalf across the Internet. In order to measure and track the effectiveness of such ads, these companies will use Cookie technology so a Cookie may be set when you click on one of our ads or visit a webpage associated with our campaigns. These companies may also use and measure information about your visits to our Website as part of this same process.

When accessing any third-party/external sites that may be linked above, you will leave The Boston Company's website. These sites are not controlled or endorsed by The Boston Company, and The Boston Company is not responsible for the contents, operation or security of these sites.