Privacy Statement

In connection with providing you with professional services, Hemenway Trust Company (“the Company”) gathers certain personal information.  Financial companies are able to choose how they share your personal information.  However, federal law gives consumers the right to limit some, but not all, sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

The types of personal information we collect and share depends on the service we provide to you. This information can include:

• Social Security number or Taxpayer Identification number
• Income, tax and asset information
• Account numbers, balances and transaction history
• Transaction and investment experience
• Age and Date of Birth
• Home address and mailing address

The Company gathers this type of client information through a variety of ways. Primarily, the main source of information is contained on the account opening forms, outside account statements and financial information you provide to us, such as tax returns. From time to time, this information is also obtained through the communication of authorized third party service providers, such as accountants, financial planners and lawyers.

The Company takes care to protect your personal information. The Company provides network security and controls access to client information. Client’s files are accessed only by those Company individuals and affiliated parties who need information to perform services you request. The Company also conducts periodic employee training on this policy and other procedures to safeguard Client and Company information.

All financial companies need to share customers’ personal information to run their everyday business. The Company shares its clients’ personal information only when necessary. Examples of when the Company shares such information are noted below:

(a)   A client’s personal information may be released to the following parties:

• authorized employees of the Company;
• entities controlled by the Company (such as limited partnerships set up by the Company for investment purposes);
• affiliates of the Company, such as Hemenway & Barnes LLP;
• third party service providers, such as Reynders, McVeigh LLC and other authorized investment advisors;
• those occupying a fiduciary relationship to the client, such as the client’s accountant, attorney, executor, guardian, or a trustee of assets held in trust for the client;
• federal, state, and local courts, government authorities, and regulatory agencies legally entitled to access or compel access to such records;
• A registered broker-dealer effecting a transaction requested by the client; and
• Custodians of client assets.

(b)   A client’s personal information may also be released in connection with any of the following activities:

• providing financial, investment, or economic advice;
• investing or safeguarding the client’s money;
• safeguarding the client’s securities;
• servicing and maintaining the client’s account;
• distributing or arranging for the distribution of amounts received in respect of the client’s investments;
• protecting the confidentiality or security of the client’s information or the records of the Company; and protecting against fraud, unauthorized transactions, or other liabilities. This policy notice applies not only to current clients of Hemenway Trust Company, but to former clients of the Company, as well.

Sharing of Information

The Company does not disclose your information other than as described above and will not allow your information to be used by any non-affiliates for marketing purposes nor will it be used for any joint marketing activities except as described below.

Clients of HTC will typically be informed of services offered not only by Hemenway Trust Company itself, but also by Hemenway & Barnes LLP, including client advisories and the like. If you are not a current client and have never been a client of Hemenway & Barnes LLP and would prefer not to receive such information from Hemenway & Barnes LLP, simply indicate that preference by opting out of this practice by calling or writing to the individual named below:

Director of Operations

Hemenway Trust Company LLC

25 Pelham Road, Suite 402

Salem, NH 03079

(603) 913-8022

Additional regulations apply to personal information of European Union (“EU”) data subjects under EU law, including the EU’s General Data Protection Regulation (“GDPR”).  The Company is executing procedures to comply with GDPR for the clients and data to which it applies.  Additional information will be provided if a client is covered by the GDPR regulations.

ABOUT US:  Hemenway Trust Company LLC is providing this notice.

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

We collect your personal information, for example, when you:

• Open an account or trust, or direct us to buy/sell your securities.
• Provide account information or give us your contact information.
• Make a wire transfer.

We also collect your personal information from others, such as credit bureaus, affiliates, custodians, other advisors and other companies.

Federal Law gives you the right to limit only the following:

• Sharing for affiliates’ everyday business purposes-information about your creditworthiness.
• Affiliates from using certain information to market to you.
• Sharing for non-affiliates to market to you.

State laws and individual companies may give you additional rights to limit sharing.

 

DEFINITIONS

Affiliates: Companies related by common ownership or control. They can be financial and non-financial companies.  Hemenway Trust Company’s affiliate is Hemenway & Barnes LLP.

Non‐affiliates: Companies not related by common ownership or control.  They can be financial and nonfinancial companies. The Company does not share with non-affiliates so they can market to you.

Joint Marketing: A formal agreement between non- affiliated financial companies that together market financial products or services to you. The Company does not joint market with non-affiliated companies.