Privacy Policy - Boston Private

The following comprises Boston Private's:

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 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.

European Privacy Disclosures

The following privacy disclosures (the “Disclosures”) provide information about the collection, use, processing and sharing of data about individuals located in the European Union, Iceland, Liechtenstein or Norway. In these 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.

These Disclosures apply only to the use of Personal Data in GDPR Processing Activities. Further, these Disclosures apply only to Boston Private Bank & Trust Company and its affiliated entities, Boston Private Financial Holdings, Inc., and Boston Private Wealth, LLC (collectively, “Boston Private Entities”). In these Disclosures the words “we” or “our” refer to each such Boston Private Entity. In some cases a Boston Private Entity may provide other information about its GDPR Processing Activities in its own supplemental or separate disclosures.

These Disclosures apply to GDPR Processing Activities by electronic means (such as websites and mobile applications).

A. How We Collect and Use Personal Data

We collect Personal Data in circumstances that involve GDPR Processing Activities, including data collected automatically (potentially including location data), and data we obtain from third party sources.

We use the Personal Data that we collect to carry on various institutional activities. As described in more detail below, we rely on your consent to lawfully process your Personal Data. The following sections of these Disclosures describe in more detail how we collect and use Personal Data in various circumstances that may involve GDPR Processing Activities. Please note that, depending on the situation, some of the processing of Personal Data we do in the various circumstances described below may not fall within the scope of the GDPR.

1. Personal Data We Obtain from You

We gather certain data automatically when you use our website or one of our mobile applications, such as your IP address, browser type and device type. Certain web-forms also collect Personal Data you provide, for example when you enter the data into form fields on a feedback page. If we also process data through our websites or mobile applications for one of the activities described further below, those sections will provide additional information about how data are collected and used. We and our third-party service providers collect Personal Data for the primary purposes of conducting analytics, responding to your requests and providing you with relevant information.

2. Personal Data We Obtain from Third Party Sources

As part of our GDPR Processing Activities, we may obtain certain Personal Data about you from third party sources, which we may use for the purposes and in the ways described in “How We Collect and Use Personal Data” above and in “Additional Uses of Personal Data” below. In some cases, we may obtain your consent for additional uses.

Partners and Service Providers

We use partners and service providers, such as analytics providers (for example, Blueconic), to perform services on our behalf.

Supplemental Personal Data

We may receive additional Personal Data from third-party sources, such as public or private databases (for example, compilations of email or postal addresses), or companies or institutions that may sponsor or facilitate your participation in one of our programs, which we may also append to existing Personal Data.

3. Additional Uses of Personal Data

In addition to the uses described above, we may use your Personal Data for the following purposes. These additional uses may under certain circumstances be based on your consent, may be necessary to fulfill our contractual commitments to you, may be necessary for legal compliance, or are necessary to serve our legitimate interest in the following operations:

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.

4. Legitimate Interests

We rely on several legitimate interests in using and sharing your Personal Data. These interests include:

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.

5. Data Retention

We will retain your Personal Data for as long as is necessary for the purposes set out in these Disclosures unless a longer period is required under applicable law, or is needed to resolve disputes or protect our legal rights or otherwise to comply with legal obligations.

Where we are processing Personal Data based on our legitimate interests, we generally will retain the data for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects.

Where we are processing Personal Data based on your consent, we generally will retain the information for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Data erased (see “Your Rights” below).

B. How We Share and Disclose Personal Data

We share your Personal Data with third parties in the ways described in these Disclosures. We may share your Personal Data with third parties as described above, as well as between Boston Private Entities. Additionally, we may share information as described below:

Service Providers

We share your Personal Data with third-party service providers that complete transactions or perform services on our behalf or for your benefit, such as:

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.

Third-Party Mobile App Providers

With your knowledge and consent, our services on your mobile device may gather and transfer your Personal Data, including location information, from and to other applications, functions and tools within your mobile device if you use our mobile applications.

Social Media Platforms

We may also use services provided by third parties (such as social media platforms) to serve targeted ads or sponsored content on third-party platforms. For more information regarding our use of cookies and similar technologies, see the “Cookies and Similar Technologies” section below.

Legal Process, Safety and Terms Enforcement

We may disclose your Personal Data to legal or government regulatory authorities as required by applicable law. We also disclose your Personal Data to third parties as required by applicable law in connection with claims, disputes or litigation, when otherwise required by applicable law, or if we determine its disclosure is necessary to protect the health, safety, rights or property of you, us or others, or to enforce our legal rights or contractual commitments that you have made.

C. Cookies and Similar Technologies

We may collect Personal Data about you, or information that becomes Personal Data if combined with other information, when you visit or use our website and online services. This information may be collected through the use of cookies, which are small data files placed on your computer or mobile device that allow us to collect certain information whenever you visit or interact with our websites or online services. Some of these cookies are managed by us (first-party cookies), while others are managed by third parties that we do not control (third-party cookies). This information may also be collected through the use of other data collection technologies (such as web beacons, pixels or tags) that embed graphic files in our websites and online services. These graphic files contain a unique identifier that enables us to recognize when someone has visited our website or online services, or in the case of web beacons, opened an email that we have sent them.

These small data files or graphic files serve various functions:

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.

You can control the use of certain cookies and similar technologies by:

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).

If you choose to reject certain cookies and similar technologies, you may still use our website and online services through your access to some functionality and features may be restricted. If you have any questions regarding our use of cookies and other similar technologies, please contact us as set forth in the “Contact Us” section below.

D. Your Rights

We will provide you upon your reasonable, good faith request with information about whether we hold any of your Personal Data as part of our GDPR Processing Activities, to the extent required by and in accordance with applicable law. In certain cases, you may also have a right, with respect to your Personal Data collected and used in the GDPR Processing Activities, to:

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.

To submit a request, please visit https://www.bostonprivate.com/help/contact/feedback-complaints. Because we want to avoid taking action regarding your Personal Data at the direction of someone other than you, we will ask you for information verifying your identity. We will respond to your request within a reasonable timeframe.

You also have the right to withdraw your consent to our processing of your Personal Data as part of the GDPR Processing Activities, where our processing is solely based on your consent, subject to certain limitations at law. In some cases, you can do this by discontinuing use of the services involved in the GDPR Processing Activities. This would include by closing all of your online accounts with us and contacting us at https://www.bostonprivate.com/help/contact/feedback-complaints to request that your Personal Data be deleted. If you withdraw your consent to the use or sharing of your Personal Data for the purposes set out in these Disclosures or the other Boston Private privacy statements that link to or expressly adopt these Disclosures, you may not have access to all (or any) of the related services, and we might not be able to provide you all (or any) of the services. Please note that, in certain cases, we may continue to process your Personal Data after you have withdrawn consent and requested that we delete your Personal Data, if we have a legal basis to do so. For example, we may retain certain data if we need to do so to comply with an independent legal obligation, if we still need the data for the lawful purposes for which we obtained the data, or if it is necessary to do so to pursue our legitimate interest in keeping our services and operations safe and secure.

In individual cases, we process your personal data in order to conduct direct marketing. You have the right to object to the processing of your personal data for the purpose of this type of marketing at any time. This also applies to profiling, insofar as it is in direct connection with such direct marketing. If you object to processing for the purpose of direct marketing, we will no longer process your personal data for this purpose.

If you have any complaints regarding our privacy practices, you have the right to make a complaint with your national data protection supervisory authority.

E. Updates to the Disclosures

We may update these Disclosures from time to time without prior notice by posting revised Disclosures to this site. You can determine when these Disclosures were last revised by checking the Last Updated date in these Disclosures.

F. Contact Us

If you have any questions, comments, requests or concerns about these Disclosures or other privacy-related matters, please contact us here.

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:

Category of Information	Examples of Information	Collected?
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)	NO
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	YES
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data	NO
F. Internet or other similar network activity	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement	YES
G. Geolocation data	Physical location or movements	YES
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	NO
I. Professional or employment-related information	Current or past job history or performance evaluation	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records	NO
K. Inferences drawn from other personal information	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	YES

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:

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.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
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.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
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.

Sharing of Data for Marketing Purposes

California's “Shine the Light” law (Cal. Civil Code Section § 1798.83) permits users of our Website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Boston Private does NOT share your personal information with third parties for their direct marketing purposes.

Changes to This Privacy Notice

Boston Private reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Boston Private collects and uses your information described below and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Concierge Desk: (888) 322-2120, Monday – Friday, 8:00 am – 8:00 pm, Eastern Time

Email Feedback or Inquiries: Feedback web form

Postal Address:

Boston Private Bank & Trust Company
10 Post Office Square
Boston, MA 020109
Attn: Chief Compliance Officer

Boston Private Wealth, LLC
1 Federal Street, 30^th Floor
Boston, MA 02109
Attn: Chief Compliance and Risk Officer

Last Updated: December 2019

Our Privacy Practices

Our Thinking

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