The following comprises Boston Private's:

• Privacy Statement
• Security Statement
• Privacy Notice and Online Privacy

 

Privacy Statement

Boston Private values your privacy and recognizes the sensitivity of your personal information and complies with federal and state laws that protect your personal information. Using the buttons on this page, you can review the practices that govern our handling of your personal information. First, you can review the Consumer Privacy Notice, which explains the information we collect from clients, how we use that information, and how you may control the sharing of that information. On the Manage Privacy Preferences page, you can exercise your right to opt out of certain kinds of information sharing with our affiliates, as more fully described in the Privacy Notice. Finally, please take a few moments to review the Security Statement below, which describes the technologies used to protect your data, and the Online Privacy Statement below, which sets forth the privacy practices used on this website. You may also obtain a written copy for review by contacting your relationship manager.

Security Statement

Boston Private Financial Holdings, Inc. and its subsidiaries, including Boston Private Bank & Trust Company and Boston Private Wealth, LLC (collectively, "Boston Private") provide a suite of Online Services that bring together a combination of industry-approved security technologies to protect data for the Boston Private and for you, our customer. It features password-controlled system entry, a VeriSign-issued Digital ID, Secure Sockets Layer (SSL) protocol for data encryption, and a router loaded with a firewall to regulate the inflow and outflow of server traffic. Using these technologies, your Online Banking transactions are secure.

A. Secure Access and Verifying User Authenticity

To begin a session, the user must key in a Login ID and a password. It is recommended that you do not use as your password your Social Security Number, birth dates, names or other personal data that would be easy for another to guess. No Boston Private employee will ever ask you for your password, and you should not provide it to anyone you do not want to access your accounts. It is the user’s responsibility to keep this password safe.

B.Secure Data Transfer

Once the server session is established, the user and the server communicate in a secured manner. The server has a Digital Certificate issued by VeriSign that confirms the identity of the server to the user. Data traveling between the user and the server is encrypted with 128-bit SSL. With SSL, data that travels between the Boston Private and customer is secure and can only be decrypted with the relevant public and private key pair. In short, the Boston Private issues a public key to the end user's browser and creates a temporary private key. These two keys are the only combination possible for that session. When the session is complete, the keys expire and the whole process starts over when a new end user makes a server session.

C. Firewall

Industry-standard firewall technologies are in use to restrict access to the Online Banking servers.

Privacy Notice and Online Privacy

A. Privacy of Personal Information

We value your privacy and recognize the sensitivity of your personal information. Our employees share the same concerns. Together, we work toward protecting your privacy. We have carefully crafted our privacy practices to address privacy concerns, and to assure you that your personal information, including your financial and account information, will be treated carefully and appropriately. Nonpublic Personal Information (“Personal Information”) includes your name, address, social security number, assets, and income, as well as your account balance, payment history, the identity of parties to your transactions, credit card usage, creditworthiness, and other information. Boston Private does not disclose information about its clients to anyone, except as permitted or required by law, or in accordance with its Consumer Privacy Notice.

For example, if you are a client that uses Boston Private’s Online Banking service, Boston Private may provide your Personal Information to unaffiliated third parties with which we have confidentiality agreements, as necessary to process transactions and maintain and service your accounts and/or applications; in the normal course of our business, such as with consumer reporting agencies and government agencies when legally required or permitted in connection with fraud investigation and litigation; in connection with acquisitions and sales; at the request or with the permission of the client; or as otherwise permitted by applicable law.

View our Consumer Privacy notice.

B. Online Privacy

These terms and conditions tell you how we collect information from you and how we use it on this website. Boston Private follows core principles of privacy protection in the operation of its website:

• Notice/Awareness of Boston Private’s information practices before information is collected;
• Choice/Consent to provide information – giving you options to control how data is used;
• Access/Participation to/in your own data – your ability to view collected data and verify its accuracy;
• Integrity/Security of the data collected – ensuring that the data collected is accurate and secure;
• Enforcement/Redress through self-regulation by Boston Private

By using this website or interacting with a Boston Private advertisement or page or account on a third party website, you consent to these Terms & Conditions, including your consent to our use and disclosure of information about you in the manner described in these Terms & Conditions. 

i. Collection of Information. Visitors to the Boston Private website (“site”) can learn about Boston Private’s products and services without providing any personal information. Boston

Private does not store or retain any information about visitors to Boston Private’s site unless the visitor (i) is a Boston Private client and a subscriber to Boston Private’s online banking service, which is the only area of Boston Private’s site in which transactions can be initiated and completed, (ii) completes and submits the privacy opt-out form, (iii) submits a request for information, or (iv) submits an inquiry or comment in the Contact Us section of the Sites. Boston Private also does not knowingly collect any personal information from minors through our site.

ii. Cookies. Like most websites, Boston Private’s site uses “cookies,” small text files that websites can use to recognize repeat users and facilitate their ongoing access to and use of the Sites. When you visit our website, a cookie may be transmitted to your computer.  A cookie is simply an electronically transmitted file that holds small pieces of information that personalize and enhance the performance of your experience with our website.  Furthermore, cookies enable us to determine which areas of our website are more popular than others and which of our advertisements on other sites have been visited, which enables us to make improvements to our site.  It is important for you to know that your privacy is never compromised when you accept a cookie from our website.  We track user activity on our website. We will not use cookies to collect or retain personally identifiable information, but only to collect information related to the characteristics of your computer, or when and how you reached the Sites. Generally, cookies work by assigning a unique number to the user that has no meaning outside the assigning site. Cookies do not pose a threat to a user’s system or files.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature. You can set your browser to notify you when you receive a cookie, allowing you to decide whether or not to accept it. Please note that cookies may be necessary to enable you to use certain features on the Sites.

 iii.  Google Analytics Cookies. Google Analytics Cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the Sites. The cookies collect information in an anonymous form, including the number of visitors to the Sites, where visitors have come to the Sites from and the pages they visited. Google Analytics has been enabled to collect data about the visitors via the DoubleClick cookie in addition to data collected through the standard Google Analytics implementation.

The following Google Analytics features have been implemented to support advertising:

• Remarketing 
  • Third-party vendors, including Google, may show our ads on websites across the Internet. 
  • Boston Private and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone's past visits to our website. 
• Google Display Network Impression Reporting
• Google Analytics Demographics and Interest Reporting – Boston Private uses data from Google's interest-based advertising or third-party audience data (such as age, gender, and interests) with Google Analytics to better profile the website traffic. All profile data is anonymous and does not violate any personally identifiable information compliance requirements. Using the Ads Settings, visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads. For more information, please see the Google Analytics Privacy Policy.          

Opting Out of Google Analytics Cookies -- To provide website visitors with more choice about how their data is collected by Google Analytics, Google developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the Sites visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services. For more information, please see the Google Analytics Opt-out Browser Add-on.  

iv.  Use of Collected Information. We use information submitted through the Sites to complete requested transactions and respond to inquiries, and we retain archival copies of the requests, transactions, and responses for audit and regulatory purposes. We use information gathered through cookies to allow you to move more quickly through the Sites, to assess the technical function of the Sites, to help diagnose problems with our server, to track user traffic patterns, and to administer the Sites.  By understanding how the Sites are accessed, we can continually improve the Sites to respond to users’ interests. We reserve the right to perform statistical analyses and profiling of user behavior and characteristics in order to measure interest in and use of the various areas of the Sites.

v. Sharing Information; Third Parties; How We Respond to Do Not Track Signals. We collect aggregated statistical data of user behavior and provide it to third parties; however, no personally identifiable information is collected or shared. We do not transmit any personally identifiable information to any third party as a result of user activity. However, Boston Private cannot control the use of cookies by advertisers or third parties hosting data for Boston Private, and we do not respond to web browser “do not track” signals or similar mechanisms, so when you use our website, third parties may collect information about your online activities. 

The Sites may provide you with links to the websites of third parties. In the event you choose to access such websites, we are not responsible for any actions or policies of such third parties. We recommend that you check the applicable privacy policy of such party before providing personally identifiable information to it, as its privacy policy may differ from ours. 

vi. Security—How We Protect Your Personal Financial Information. We maintain physical, electronic, and procedural safeguards that comply with federal and state standards to guard your Personal Information. Other than as set forth above, we restrict access to Personal Information about you to Bank employees who need to know that information to provide products or services to you. 

All information gathered on this website is stored within secure databases protected by multiple firewalls. As effective as current encryption technology is, however, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that information we gather will not be intercepted while being transmitted to us over the Internet.

vii. Changes in Our Online Privacy Statement. We may change this Online Privacy Statement at any time. Any changes to our Online Privacy Statement will be posted on this page so that you are always aware of our up-to-date Statement. Any changes to this Online Privacy Statement will become effective when they are posted on our site.