Client Privacy Policy Notice

This informational notice covers how Beaumont Financial Partners, LLC and its separate division, Beaumont Capital Management, (collectively “Beaumont”) safeguards your nonpublic personal financial information.

Protecting the privacy of client information is one of our fundamental responsibilities. This notice summarizes our policy regarding the confidentiality and non‐disclosure of client information. We do not sell or rent any personal information we gather from clients, and will only share such information with others as stated in this notice.

Personal Information Collected

Beaumont clients provide, or may provide, their personal information and information about their family to Beaumont. Some examples of the information we may request include:

  • Name, address, phone number, social security number, tax identification number and date of birth.
  • Assets, employment history, income, liabilities, retirement goals and legal documents.
  • Account balances, account numbers, statements and custodians.
  • A photocopy of a valid driver’s license, passport, green card or military identification. Beaumont or the custodian may require this information when opening new accounts for clients. Many financial institutions in the United States require a copy of at least one of these documents to comply with Uniting and Strengthening America by Protecting Appropriate Tools Required to Intercept and Obstruct Terrorism, also known as the USA PATRIOT Act.

Beaumont may also receive client information from the custodians used for client accounts or other custodial firms including:

  • Duplicate copies of monthly statements and trade confirmations
  • Daily electronic downloads of clients’ account information (e.g. all transactions and positions).

The custodian must receive authorization from the client before providing the aforementioned information with Beaumont. This is usually part of the account opening process.

Why We Collect Personal Information

The personal information we collect is necessary to help us provide informed investment management, financial planning and/or tax services to you.

How We Handle Your Personal Information

As emphasized above, we do not sell, rent or distribute information about current or former clients or their accounts to third parties. We do not share such information with anyone, except as needed in the normal course of business, such as to: open accounts, meet required compliance reviews, and complete transactions in your accounts.

For example:

  • In order to open accounts or complete transactions for you, it may be necessary to provide aforementioned identifying information to custodians, companies, individuals, or groups not affiliated with Beaumont. In addition, Beaumont may provide the custodian with a copy of the Investment Advisory Agreement with the client.
  • At times, we may contract with non‐affiliated companies to perform services for us (i.e. CPAs for tax preparation and Financial Recovery Technologies for class action recovery). If it is necessary, we may disclose information that we have collected from you to these third parties. In these instances, we only release the information that is necessary for the third party to complete its assigned responsibilities (i.e. tax cost basis). In addition, we require that these third parties treat your personal information with the same high degree of confidentiality that Beaumont does.
  • For clients with a Beaumont Capital Management (BCM) account, Beaumont has hired Envestnet Asset Management, Inc. to handle many of the back‐office functions (i.e. opening new accounts, trading, billing and reporting) for BCM. As a result, Beaumont will need to provide confidential client data to Envestnet to complete these back office services.
  • We will release information about you if you request us to do so or if we are compelled to do so by law. If you decide to close your account(s) or your account becomes inactive, we will continue to adhere to our privacy policy.

It is always our intent to protect and maintain the integrity of any client information collected, or received during the course of the relationship. Beaumont has contractual agreements with third party vendors stipulating the limitations of any information to which they may have access. In short, all non‐public client information is kept confidential and not shared, sold, copied or otherwise used. However, Beaumont clients have the option to opt‐out of having their information shared with any third parties. If you are a client, or once you become a client, and would like to opt‐out of having your information shared please contact your relationship manager or call the number at the end of this notice.

Confidentiality and Security Procedures

Beaumont emphasizes the importance of confidentiality through operating procedures, employee training and our client privacy policy. We also maintain electronic, physical and procedural safeguards to help protect your nonpublic personal information.

How You Can Protect Your Information

If you access your accounts on‐line, you should confirm that the anti‐virus software and firewall/spyware protection is current on the computer(s) that you use. We also strongly recommend that you select a unique User ID and Password that does not contain any personal information (i.e. SSN, DOB, Name, phone #, etc.) and change the password periodically. Additionally, we recommend that you do not provide any of your account information, including online account user names or passwords, to anyone. This is especially important if you receive the request via email, or over the phone, by an unfamiliar source. We also suggest that you regularly review the activity on your brokerage statements. Please contact us immediately if you notice any suspicious or irregular activity relating to your account(s); or if you believe your information has been compromised.

Annual Notification

As required by federal law, Beaumont will provide you with annual notification of our client privacy policy. Beaumont reserves the right to amend this policy at any time. We will promptly provide clients an updated copy of this policy if we make material changes.

MASSACHUSETTS DISCLOSURE

Massachusetts law (Sec. 203A) requires disclosure that information on disciplinary history and the registration of the adviser and its associated persons may be obtained by contacting the Public Reference Branch of the U.S. Securities and Exchange Commission at (202) 551‐8090 or the Massachusetts Securities Division, One Ashburton Place, 17th Floor, Boston, Massachusetts 02108 or (617) 727‐3548.

COMPLIANCE WITH PRIVACY REQUIREMENTS

Beaumont maintains compliance with Massachusetts requirement 201 CMR 17.00 and applicable federal guidelines. The firm has a designated Information Security Manager, as defined in its Written Information Security Program (WISP). This Program is consistent with the stringent requirements of Massachusetts, and outlines the responsibilities of the firm and its personnel to protect client data. Although the WISP requirements only pertain to residents of Massachusetts, the firm extends these standards to all clients. Beaumont is also aware of and considers the stipulations set forth by each state. In addition, the Securities and Exchange Commission’s (SEC), Regulation S‐P provides further guidance and requirements for handling and protecting non‐public client information (NPI). Beaumont also adheres to and applies these standards to its business and handling of client information.

NOTIFICATION OF BEAUMONT FINANCIAL PARTNERS, LLC’S PROXY POLICY

In accordance with SEC Rule 206(4)‐6 of the Investment Advisers Act of 1940 relating to Proxy Voting, Beaumont is notifying you of its following Proxy Policy: As a matter of current policy, Beaumont Financial Partners, LLC, does not vote proxies on behalf of its clients. While all Beaumont’s Investment Advisory Agreements grant the firm the legal ability to do so, we are not required to. If our current proxy policy changes, we will promptly notify our clients.

ANNUAL FORM ADV OFFERING

Federal law, through the U.S. Securities and Exchange Commission (SEC), requires Beaumont Financial Partners, LLC to provide the following annually.

Per Rule 204‐3 of the Investment Advisor’s Act of 1940, an investment advisor is required to annually provide clients with either (1) a complete, Disclosure Document (Form ADV, Part 2A); or (2) a summary of material changes to the Disclosure Document since the last update and also offer to provide a copy of the full Document upon request, without charge. This must be done within 120 days of its fiscal year end. If at any time you would like a complete copy of our Disclosure Document, please call or write, using the following information, and we will be sure to send you a copy.

Beaumont Financial Partners – 250 1st Avenue, Suite 101 – Needham, MA 02494 – (781) 400-2800.

Additionally, our Disclosure Document is available via our website, www.bfpartners.com.

You do not need to call or do anything as a result of this notice, however feel free to contact us if you have any questions.