Boston Equity Advisors, LLC
Customer Privacy Statement
Guiding Principles
The relationship between Boston Equity Advisors, LLC and our customers is the most important asset of our firm. We strive to maintain your trust and confidence in our firm, an essential aspect of which is our commitment to protect your personal information to the best of our ability. We believe that all of our customers value their privacy, so we will not disclose your personal information to anyone unless it is required by law, at your direction, or is necessary to provide you with financial services. We have not and will not sell your personal information to anyone.
Personal Information That We Collect, Maintain, and Communicate
Boston Equity Advisors, LLC collects and maintains your personal information so we effect securities transactions on your behalf in compliance with federal and state securities laws. The types and categories of information we collect and maintain about you includes:
· Information we receive from you to initiate a customer relationship or to effect securities transactions on your behalf (such as your name, home address, telephone number, marital status, social security number, name and social security numbers of beneficiaries, occupation and employment information, and tax bracket and other financial information, and investment history, including any information contained in subscription documents or investor questionnaires);
· Information that we generate to effectuate any subscriptions of equity securities for you; and
· Information that we may receive from third parties with respect to you (such as information which we may receive from your investment advisors, attorneys, accountants or other financial advisors).
In order for us to provide these services to you, we do disclose your personal information in very limited instances, which include:
· Disclosures to companies – subject to strict confidentiality agreements – that perform services on our behalf (such as our technology consultants who assist us in maintaining our computer systems); and
· Disclosures to companies as permitted by law, including those necessary to service you (such as providing personal information to outside legal counsel, to other broker-dealers with whom you maintain an account or to bank/escrow agents established in connection with a private placement of securities).
· Disclosures to regulatory agencies as permitted or required by law, including the Securities and Exchange Commission, state securities commissions and the Financial Industry Regulatory Authority, Inc. (“FINRA”). These agencies may make official requests from time to time regarding customer accounts and trading activity, to which we are obligated to respond.
How We Protect Your Personal Information
To fulfill our privacy commitment at Boston Equity Advisors, LLC, we have instituted firm-wide practices to safeguard the information that we maintain about you. These include:
· Adopting policies and procedures that put in place physical, electronic, and other safeguards to keep your personal information safe.
· Limiting access to personal information to those employees who need it to perform their job duties.
· Requiring third parties that perform services for us to agree by contract to keep your information strictly confidential.
· Protecting information of our former customers to the same extent as our current customers.
If you any questions regarding our privacy commitment, please contact Mark C. Butts at Boston Equity Advisors, LLC at (781) 821-4114.