The following comprises Boston Private's:

• Privacy Statement
• Security Statement
• Confidentiality of Commercial Client Data
• Privacy of Personal Information
  • Privacy Terms of Use for This Website
  • Privacy in the Use of Online and Mobile Banking Services
• European Privacy Disclosures
• Privacy Notice for California Residents

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.

Confidentiality of Commercial Client Data

Current privacy laws and regulations are focused on the protection of consumer data, while remaining largely silent on data that is owned by businesses and provided to financial institutions in order to open accounts, initiate transactions, and use other services such as online banking. At Boston Private, we afford the same confidentiality and security protections to all client data—including but not limited to commercial account and transactional data and the personal data of commercial account signers--regardless of its owner or source. Boston Private does not differentiate between consumer and commercial data in its information security protections or its data sharing practices. It does not sell data of any kind to anyone, and it does not share data with third parties for marketing purposes. Boston Private shares client data principally with third-party service providers who assist in the execution of transactions, and in every case subject to confidentiality restrictions that maintain the privacy of such data. These service providers are contractually bound to use the data to provide the service to Boston Private and its clients, and for no other purpose. They cannot sell the data or disclose it to other parties. Boston Private also shares the data of commercial clients as legally required, such as pursuant to court order. 

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.

Privacy Terms of Use of This Website

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. There is currently no standard that governs what, if anything, websites should do when they receive these signals. If and when a standard is established, we may revise our policy on responding to these signals.

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.

Privacy in the Use of Online and Mobile Banking Services

This section of our Privacy Practices page, in combination with other relevant privacy notices that we provide to you (e.g., pursuant to financial privacy laws), informs you of the policies and practices regarding the collection, use and disclosure of any personal information that we and our service providers collect from or about users in connection with Online Account Opening and the Online Banking Service and related mobile applications (the “Online and Mobile Banking Services” or “the Services”).

I. The Types of Information We Collect

Through your use of the Online and Mobile Banking Services, we may collect personal information from you in the following ways:

(a) Personal Information You Provide to Us.

• We may collect personal information from you, such as your first and last name, address, e-mail, telephone number, and social security number when you create a profile.
• We will collect the financial and transaction information necessary to provide you with the Services, including account numbers, payment card expiration date, payment card identification, verification numbers, and transaction and payment history.
• If you provide feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
• We also collect other types of personal information that you provide voluntarily, such as any information requested by us if you contact us via email regarding support for the Online and Mobile Banking Services.

(b) Personal Information Collected from Third Parties. We may collect certain information from identity verification services and consumer reporting agencies, including credit bureaus, in order to provide some of our Services.

(c) Personal Information Collected Via Technology. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our communications and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
• Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.
• Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
• Location Information. If you have enabled location services on your phone and agree to the collection of your location when prompted by the Services, we will collect your location information when you use the Services, for example, to provide our fraud detection services. If you do not want us to collect this information, you may decline the collection of your location when prompted or adjust the location services settings on your device.

II.         How We Use Your Information

(a) General Use. In general, we use your personal information collected through your use of the Services to respond to your requests as submitted through the Services, to provide you the Services you request, and to help serve you better. We use your personal information, in connection with the Services, to:

• facilitate the creation of, and secure and maintain your account;
• identify you as a legitimate user in our system;
• provide improved administration of the Services;
• provide the Services you request;
• improve the quality of experience when you interact with the Services;
• send you administrative e-mail notifications, such as security or support and maintenance advisories; and
• send surveys, offers, and other promotional materials related to the Services.

(b) Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern the Services; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

(c) Creation of Non-Identifiable Data. We may create de-identified information records from personal information by excluding certain information (such as your name) that makes the information personally identifiable to you. We may use this information in a form that does not personally identify you to analyze request patterns and usage patterns to enhance our products and services. We reserve the right to use and disclose non-identifiable information to third parties in our discretion.

III.        Disclosure of Your Personal Information

We disclose your personal information collected through your use of the Services as described below.

(a) In Accordance with Our Other Privacy Notices. Other than as described in this Privacy Policy in connection with your use of our Online and Mobile Banking Services, this Privacy Policy does not apply to the processing of your information by us or third parties with whom we share information. For more information about how we share your information when you use our services, see our Consumer Privacy Notice .

(b) Third Party Service Providers. We may share your personal information with third party or affiliated service providers that perform services for or on behalf of us in providing the Online and Mobile Banking Services systems, for the purposes described in this Privacy Policy, including: to provide you with the Online and Mobile Banking Services; to conduct quality assurance testing; to facilitate the creation of accounts; to optimize the performance of the Services; to provide technical support; and/or to provide other services to the Online and Mobile Banking Services systems.

 (c) Authorities and Others. Regardless of any choices you make regarding your personal information, we may disclose your personal information to law enforcement, government authorities, and private parties, for the compliance and protection services described above.

IV.       Links to Other Sites

The Online and Mobile Banking Services systems may contain links to third party websites. When you click on a link to any other website or location, you will leave our site and go to another site and another entity may collect personal and/or anonymous information from you. The site’s provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites. We encourage you to read the privacy policy of every website you visit.

V.        Your Choices Regarding Your Information

You have several choices regarding use of information on the Services.

 (a) How We Respond to Do Not Track Signals. Some web browsers transmit “do not track” signals to the websites and other online services with which your web browser communicates. There is currently no standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established, we may revise our policy on responding to these signals.

(b) Access, Update, or Correct Your Information.  You can access, update or correct your information by changing preferences in your account. For additional requests, please contact us. 

(c) Opting Out of Email or SMS Communications. If you have signed-up to receive our email marketing communications, you can unsubscribe any time by clicking the "unsubscribe" link included at the bottom of the email or other electronic communication. Alternatively, you can opt out of receiving marketing communications by contacting us at the contact information under "Contact Us" below. If you provide your phone number through the Services, we may send you notifications by SMS, such as provide a fraud alert. You may opt out of SMS communications by unlinking your mobile phone number through the Online and Mobile Banking Services.

(d) Opting Out of Location Tracking. If you initially consented to the collection of geo-location information through the Services, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. Please note, however, that if you withdraw consent to our collection of location information, you may no longer be able to use some features of the Online and Mobile Banking Services.

VI.       Safeguards and Retention

We implement reasonable administrative, technical and physical measures in an effort to safeguard the information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.

European Privacy Disclosures 
 

• “GDPR” means the European Union’s General Data Protection Regulation;  
• “Personal Data” means information that relates to an individual who is directly or indirectly identified or identifiable; and 
• “GDPR Processing Activities” means the collection, use, processing or sharing of Personal Data when those activities are within the scope of the GDPR. 

• Contacting you to respond to your requests or inquiries; 
• Providing you with newsletters, articles, service alerts or announcements, event invitations, and other information that we believe may be of interest to you; 
• Alerting you about a safety or security announcement; 
• Conducting research, surveys and similar inquiries to help us understand trends and needs of our clients and others using our websites or other services; 
• Performing marketing, promotions and advertising, either directly or through third-parties.  These activities may include interest-based advertising, targeted advertising and online behavioral advertising in order to increase the likelihood that the content would be of interest to you; 
• Preventing, investigating, taking action regarding or providing notice of fraud, unlawful or criminal activity, other misconduct, security or technical issues, or unauthorized access to or use of Personal Data, our website or data systems; or  
• Responding to subpoenas, court orders, or other legal process; enforcing our agreements; protecting the health, safety, rights or property of you, us or others; and meeting legal obligations. 

• Providing, improving and customizing our offerings; 
• Administration of our operations; 
• Furthering research and understanding of the ways our services are used; 
• Maintaining an ongoing relationship with clients and prospective clients; 
• Understanding how our online platforms are being used; 
• Exploring ways to develop and grow our operations;  
• Ensuring the safety and security of our clients;  
• Cybersecurity;  
• Enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and 
• Meeting our obligations and enforcing our legal rights. 

• Customer relationship management (CRM) services; 
• Marketing and analytics; 
• Event registration and coordination; 
• Providing platforms or tools that enable or enhance our offerings; 
• Research insights and analytics; and 
• System maintenance and security. 

• Strictly Necessary: Necessary to deliver our services; 
• Performance and Functionality: Enhance the performance and functionality of our services but are non-essential to their use; 
• Analytics and Customization: Allow us to understand the effectiveness of our services and marketing campaigns, as well as to customize our services based on this information; or 
• Advertising: Make advertising messages more relevant to you and your interests.  

• Opting out of targeted online advertising through advertising networks (please visit https://www.bostonprivate.com/privacy for more information); 
• Setting or amending your web browser controls to accept or refuse cookies (please visit your browser’s help menu for more information).  

• correct or update any of your Personal Data that is inaccurate;  
• restrict or limit the ways in which we use your Personal Data; 
• object to the processing of your Personal Data; 
• request the deletion of your Personal Data; and 
• obtain a copy of your Personal Data in an easily accessible format. 

-----------------

Privacy Notice for California Residents

This Privacy Notice for California Residents (“Notice”) supplements the information contained in Boston Private Bank & Trust Company’s (the “Bank”) and Boston Private Wealth, LLC’s (“BPW”) (together, “Boston Private”) Privacy Notices, and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

Our website (www.bostonprivate.com) (“Website”) collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). BOSTON PRIVATE DOES NOT SELL ANY OF YOUR PERSONAL INFORMATION TO ANY THIRD PARTY, WHETHER IT WAS PROVIDED TO BOSTON PRIVATE THROUGH OUR WEBSITE OR OTHERWISE.

For purposes of this Notice, personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, such as Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

In particular, the Website may have collected the following categories of personal information from its consumers within the last twelve (12) months:

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your transaction. We may also save your information to facilitate future activity.
• To provide, support, personalize, and further develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, transactions, and payments and implement and administer our fraud prevention program.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise permitted by the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Boston Private’s assets, in which personal information held by Boston Private about our Website users is among the assets transferred.

The Company will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without first updating this Notice, and where required, sending you an updated Consumer Privacy Notice.

Sharing Personal Information

The Company may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We may share your personal information with the following categories of third parties:

• Service providers.
• Data aggregators.
• Advertising networks (only to advertise Boston Private products and services to you).

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers

Category B: California Customer Records personal information categories

Category D: Commercial information

Category F: Internet or other similar network activity

Category G: Geolocation data

Category K: Inferences drawn from other personal information

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Boston Private disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.

If we disclosed your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that the Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete a transaction for which we collected the personal information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract(s) with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.  

You can make such a request to by either:

• Calling our Concierge Desk at (888) 322-2120, Monday – Friday, 8:00 am – 8:00 pm, Eastern Time
• Completing our Feedback web form by choosing “Privacy Related Request or Inquiry”

Your request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to confirm receipt of a verifiable consumer request and explain how we will process that request within ten (10) days of its receipt. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to the address associated with that account in our systems. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option, at the address you provide.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales

BOSTON PRIVATE DOES NOT SELL ANY OF YOUR PERSONAL INFORMATION TO ANY THIRD PARTY, WHETHER IT WAS PROVIDED TO BOSTON PRIVATE THROUGH OUR WEBSITE OR OTHERWISE. If in the future Boston Private were to sell your information to a third party, and you are 16 years of age or older, you would have the right to direct us to not sell your personal information at any time (the "right to opt-out"). The opt-out process and requirements would be described in this section of this Notice.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you products or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of products or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.