We collect and maintain nonpublic personal information to provide investment management services. This may include information collected from you or about your transactions with us or with nonaffiliated third-party providers.
The nonpublic personal information we collect from you and maintain may include, but is not limited to:
IR+M may share your nonpublic personal information with a nonaffiliated third-party provider in a limited and controlled manner for some of the following reasons: as required or permitted by law, at your direction, to provide investment management services to you, to process transactions and maintain accounts with agents and vendors who perform services for us, or for other business purposes. We hold these third-party providers to the same high standards, that we use to ensure the security, confidentiality, and integrity of your nonpublic personal information. We will not sell your nonpublic personal information to anyone.
We are committed to safeguarding your nonpublic personal information. Some of the ways that we protect your nonpublic personal information is by:
We at IR+M will work with you to protect your nonpublic personal information and strive to keep all your information accurate.
If you have questions or believe that our records are incorrect, please contact your Client Portfolio Manager by email or at (617) 330-9333.
This privacy notice is effective March of 2024 and replaces all previous statements of our client privacy policy and can be amended at any time. We will keep you informed of changes as required by law.
Thank you for the opportunity to work with you.
Your relationship and trust are very important to IR+M.
We collect personal and other information from you directly when you provide it to us through the website. We may also automatically collect certain information about you and your computer, smartphone, or other device when you use, access, or interact with our Site.
You can visit the Site without submitting any information that we can use to identify you personally. However, if you use certain features on the Site, such as the “Contact Us” feature, or when you submit an application for a position with us, you will be required to provide personal information. Such information could include, for example, your name, email address, phone number, or resume. Our online contact form also contains a “comments” field through which you may submit additional personal information.
When you use the Site, we automatically receive and record certain information from your computer (or other device) and your browser. This may include such data as your IP address and domain name, the pages you visit on the Site, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Site, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity.
We also use cookies on the Site. Cookies are small files that are stored on your computer by your web browser. A cookie allows the Site to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Site during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Site, and the link you used to leave the Site. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.
The Site or the emails that you receive from IR+M may use an application known as a “web beacon” (also known as a “clear gif” or “web bug”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it can allow an email sender to determine whether a user has opened a particular email.
We also may partner with certain third parties to collect, analyze, and use some of the personal and other information described in this section. For example, we may allow third parties to set cookies or use web beacons on the Site or in email communications from us.
IR+M uses the information that we collect for a variety of purposes. These purposes include, for example: to respond to your questions or requests concerning the Site or other services offered by us; to fulfill the terms of any agreement you have with us; to fulfill your requests for our services or otherwise complete a transaction that you initiate; to send you information about our services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails and advertising; to deliver confirmations, account information, notifications, and similar operational communications; to improve your user experience and the quality of our products and services; to comply with legal and/or regulatory requirements; and to manage our business.
In addition to the purposes above, we use the information that we collect automatically through the Site for such purposes as: counting and recognizing visitors to the Site; analyzing how visitors use the Site and various Site features; improving the Site and enhancing users’ experiences with the Site; creating new products and services or improving our existing products and services; enabling additional website analytics and research concerning the Site; engaging in interest-based advertising (as described below); and managing our business.
IR+M may link information gathered through the Site with information that we collect in other contexts. But in that event, we will handle the combined information in a manner consistent with this Policy.
We share your information with other parties for a variety of purposes, as described below.
We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, the Site uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.
IR+M does not respond to Do Not Track Signals at this time.
IR+M uses third-party service providers that perform services on our behalf, including web-hosting companies, mailing vendors, and analytics providers. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above.
We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:
From time to time, IR+M may also share aggregated information about Site users, such as by publishing a report on trends in the usage of the Site. Such aggregated information will not identify you personally.
You may opt out of receiving marketing emails from us by following the instructions in those emails or by emailing us at privacyoffice@incomeresearch.lnx.prosekbeta.com.
This Site may contain links to third-party websites. If you use these links, you will leave the Site. We have not reviewed these third-party sites and do not control and are not responsible for any of these sites, their content, or their privacy policy. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites listed on our website, you do so at your own risk.
We employ physical, technical, and administrative procedures to safeguard the personal information we collect online. However, no website is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Site or to us, and you transmit such information at your own risk.
The information that we collect through or in connection with the Site is transferred to and processed in the United States for the purposes described above. IR+M also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Site or by providing any personal or other information to us, you expressly consent to such transfer and processing.
Content on this Site is directed at individuals over the age of 18 and is not directed at children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13.
IR+M may make changes to the Site in the future and as a consequence will need to revise this Policy to reflect those changes. IR+M will post all such changes on the Site, so you should review this page periodically. If we make a material change to the Policy, you will be provided with appropriate notice.
Should you have any questions or concerns about this Policy, you can contact us at privacyoffice@incomeresearch.lnx.prosekbeta.com or by mail at the following address:
Income Research & Management
115 Federal Street, 22nd Floor
Boston, MA 02110
Attention: Privacy Office