June 30, 2023

Privacy Principles

Your privacy is important to us. Boston Financial Investment Management, LP (“BFIM,” “we,” or “us”) wants you to be familiar with how we collect, use, disclose and protect your information.  This Privacy Policy describes our practices in connection with information that we collect through:

• Websites operated by us from which you are accessing this Privacy Policy (the “Websites”);
• Software applications made available by us for use on or through computers and mobile devices (the “Apps”);
• Our social media pages that we control from which you are accessing this Privacy Policy (collectively, our “Social Media Pages”);  
• HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and
• Offline business interactions you have with us.  

Collectively, we refer to the Websites, Apps, Social Media Pages, emails, and offline business interactions as the “Services.”

If you are a California resident, please see our CALIFORNIA PRIVACY NOTICE for further details on how we handle your information and how to exercise your rights.

Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.  The Services collect Personal Information, including:  

• personal details (e.g., name, occupation, date of birth, social security number);
• contact details (e.g., address, email address, position in company, company, landline and mobile numbers);
• IP address (we may also derive your approximate location from your IP address);
• wire transfer instructions or bank account information;
• other information about you which you may have provided to us during the course of our relationship with you, e.g., by filling out Website forms or commenting on the Social Media Pages (e.g., Social Media username); and
• sales and marketing information (e.g., offers you have received from us and how you reacted to them).

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including: 

• Through the Services. 
• We collect Personal Information through the Services, for example, when you sign up for a newsletter, register an account to access the Services, visit our offices, or attend one of our events.

• From Other Sources. 
• We receive your Personal Information from other sources, for example:
• publicly available databases;
• affiliated entities;
• third-party service providers.

We need to collect Personal Information in order to provide the requested Services to you.  If you do not provide the information requested, we may not be able to provide the Services.  If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy. 

Use of Personal Information

We and our service providers use Personal Information for the following purposes:

• Providing the functionality of the Services and fulfilling your requests.
• To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related benefits, or customer service.
• To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints via the Services.
• To complete your transactions, verify your information, and provide you with related benefits, or customer service.
• To send administrative information to you, such as changes to our terms, conditions, and policies.
• To allow you to send messages to another person through the Services if you choose to do so.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
• To send you marketing-related emails, with information about our Services, and other news about our company.
• To facilitate social sharing functionality that you choose to use.

We will engage in this activity with your consent or where we have a legitimate interest.

• Analyzing Personal Information for business reporting and providing personalized services.
• To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so that we can improve our Services.
• To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
• To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.

• Aggregating and/or anonymizing Personal Information.
• We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information.  We do so to generate other data for our use, which we may use and disclose for any purpose, since it no longer identifies you or any other individual.

• Accomplishing our business purposes.
• For data analysis, for example, to improve the efficiency of our Services;
• For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
• For risk management, fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
• For detecting and preventing misuse of the Services;
• For developing new products and services;
• For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
• For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
• For determining the effectiveness of our promotional campaigns, in order that we can adapt our campaigns to the needs and interests of our users; and
• For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users in order that we can focus our energies on meeting our users’ interests. 

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.

Disclosure of Personal Information 

We disclose Personal Information:

• To our affiliates for the purposes described in this Privacy Policy.
• You can consult the list and location of our affiliates here https://www.orix.com/offices/. 
• To our third-party service providers, to facilitate services they provide to us.
• These can include providers of services such as website hosting, data analysis, auditor, monitoring and, legal service providers, compliance service providers, administrators, third-party training providers, credit agencies, payment processing, fraud prevention, information technology and related infrastructure provision, benefits providers, collaboration tool, email delivery, background check provider, building security, and other services.  
• To third parties, including business partners, to carry out our respective business purposes, such as conducting transactions and to permit them to send you marketing communications, consistent with your choices. 

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, in particular, when we have a legal obligation or legitimate interest to do so:

• To comply with applicable laws and regulations.
• This may include laws outside your country of residence.
• To cooperate with public and government authorities.
• To respond to a request or to provide information we believe is necessary or appropriate.
• These can include authorities outside your country of residence.
• To cooperate with law enforcement.
• For example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons.
• To enforce our terms and conditions.
• To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction.
• We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

OTHER Information

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:

• Browser and device information;
• App usage data;
• Information collected through cookies, pixel tags and other technologies;
• Demographic information and other information provided by you that does not reveal your specific identity; and
• Information that has been aggregated in a manner such that it no longer reveals your specific identity.

 Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including: 

• Your browser or device. 
• Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using.  We use this information to ensure that the Services function properly. 
• Your use of the App. 
• When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
• Cookies. 
• Cookies are pieces of information stored directly on the computer that you are using.  Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data.  We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience.  We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them.  We do not currently respond to browser do-not-track signals.  Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services.  We may also use cookies or other technologies in online advertising to track responses to our ads.   If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.  You may also wish to refer to https://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.  You also may not receive advertising or other offers from us that are relevant to your interests and needs.
• Pixel tags and other similar technologies. 
• Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates. 
• Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  This service may also collect information regarding the use of other websites, apps and online resources.  You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• Hotjar. We also use Hotjar, which collects and analyzes information about your use of the Services. You can learn more about Hotjar’s practice by going to https://www.hotjar.com/privacy/, and exercise the opt-out provided by Hotjar by visiting https://www.hotjar.com/privacy/do-not-track.
• Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies.
• We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services.  If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel.  You can also go to the Global Storage Settings Panel and follow the instructions (which may explain, for example, how to delete existing Flash LSOs (referred to as “information”), how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time).  Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.  

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.  In some instances, we may combine Other Information with Personal Information.  If we do, we will treat the combined information as Personal Information as long as it is combined.

security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS 

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from: 

• Receiving marketing-related emails from us.  If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by following the unsubscribe instructions in each marketing email.
• Our sharing of your Personal Information with affiliates for their direct marketing purposes.  If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt out of this sharing by contacting us directly by phone at 646-569-2300 or email at dataprivacy@bfim.com.

We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

How you can access, change, or delete your Personal Information 

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below.  We will respond to your request consistent with applicable law.  If you are a California resident, please refer to our California Privacy Notice at the footer of  https://www.bfim.com/ for more information about the requests you may make under the CCPA. 

In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database.  For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable. 

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when entering into a transaction or promotion, you may not be able to change or delete the Personal Information provided until after the completion of such transaction or promotion).   

RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. 

The criteria used to determine our retention periods include: 

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations). 

THIRD-PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

THIRD-PARTY ADVERTISING 

We use third-party advertising companies to provide advertisements regarding services that may be of interest to you when you access and use the Services and other websites or online services.

• You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties.  These companies place or recognize a unique cookie on your browser (including through the use of pixel tags).  They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.  If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit https://optout.aboutads.info/#/ and https://optout.networkadvertising.org/#/. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps. 

use of Services by MINORS

The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16. 

Jurisdiction and CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

ADDITIONAL INFORMATION REGARDING THE EEA, UK and Cayman Islands: Some non-EEA countries are recognized by the European Commission (and the United Kingdom and the Cayman Islands) as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en. For transfers from the EEA, UK or the Cayman Islands to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services. 

CONTACTING US

The ORIX group company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy for the Services you interact with in your country or region is available at https://www.boston.financial.

If you have any questions about this Privacy Policy, please contact us by email at dataprivacy@bfim.com, or mail at BFIM, LP, 101 Arch Street, Boston, MA 02110, Attn: General Counsel.

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us. 

ADDITIONAL INFORMATION REGARDING THE EEA AND UK

You may also:

• Lodge a complaint with a data protection authority in the EU/EEA or UK for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs.  A list of data protection authorities is available at https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080. The UK Information Commissioner’s Office website is available at https://www.ico.org.uk/.