Last Updated July 2020
Bingham, Osborn & Scarborough, LLC, (“B|O|S” or “we”/“our”) an independent investment advisory firm, is committed to safeguarding the confidential information of its clients (“you”/“your”). B|O|S collects or uses nonpublic personal information about you, including information that we collect from you or from third parties and information that third parties may collect about you, in order to provide our services to you. We treat all such information with a high degree of care and hold it in strict confidence except as described in this notice.
The categories of nonpublic personal information that we collect about you depend upon the scope of our engagement with you. In general, such information will include information about your personal finances, including your assets and liabilities, information about your transactions or obligations between you and third parties, information about your income and tax liabilities, information about your health, your contact information, information about your insurance coverage, information about your estate plan, and information about your financial goals and objectives. We may collect your personal information from sources such as, but not limited to, account applications and related documents; other written, electronic or verbal correspondence; transactions; brokerage firms, custodians or other financial intermediaries; accountants, lawyers, or other professionals retained by you; and our third-party vendors or service providers.
We use your financial and health information to help you meet your personal financial goals while guarding against infringements of your privacy rights. We reserve the right to disclose all nonpublic personal information about you as described in this notice. Nonpublic personal information is used and disclosed for our everyday business purposes to provide services covered by our investment advisory agreements with our clients or as permitted by law. For example, to the extent necessary to service your account(s) or to execute transactions that you request or authorize, applicable law and regulations permit us to share information about you with (1) your brokerage firm, custodian or other financial intermediary and (2) accountants, lawyers, or other professionals retained by you, among others. We may also disclose your information to third parties with whom we have agreements to provide business or professional services and functions on our behalf, such as technology or other companies that host our data or that perform data processing, analysis services, or mailing automation services for us. In addition, other third parties with whom B|O|S has relationships, such as your custodian, may, at the direction of B|O|S or otherwise, disclose nonpublic personal information about you directly to our third-party service providers in order for such service providers to perform services on our behalf. We may also enter into agreements with third parties that help to market our services to potential clients, and we may share your information in order to prevent you from receiving marketing materials from such third parties. When you are no longer a B|O|S client, we may continue to share your personal information as described in this notice and to the extent reasonably necessary under the circumstances, such as to assist with terminating your relationship with B|O|S or as part of our archived data.
We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We have taken steps to secure our office and computer environment to ensure that your information is not placed at unreasonable risk. We do not provide your personally identifiable information to solicitors for any purpose. We do not disclose nonpublic personal information to nonaffiliated third parties, except as noted above or as permitted by law. We are prohibited by law from changing this policy to share your nonpublic personal information more broadly without first advising you.
If you have any questions about the above policy, please do not hesitate to contact us.