CLIENT PRIVACY POLICY NOTICE

This notice summarizes how Beaumont Capital Management, LLC (“BCM”) safeguards client non-public personal information. It also explains how we use client information in order to provide investment management services. We value the trust our clients have placed in us and are committed to protecting the confidentiality of their information. Please review this document to learn more about our policy regarding the nondisclosure of non-public personal information.

Personal Information Collected

Dual contract and direct BCM clients provide information concerning their personal identity and circumstances, family, or entity to BCM. Such information may 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.
  • BCM or the custodian may require a photocopy of a valid driver’s license, passport, green card, or military identification 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 the USA PATRIOT Act.

Additionally, BCM often receives client information from custodians or Turnkey Asset Management Programs (TAMPs) including:

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

The custodian, source advisor, and/or TAMP must receive authorization from the client before sharing the aforementioned information with BCM. 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 services to you. The information allows us to serve client financial needs, process account transactions, provide customer service, offer new products or services, and fulfill regulatory and legal requirements.

How We Handle Your Personal Information

We do not sell, rent or distribute information about current or former clients or their accounts to third parties except as provided in this notice. We only share nonpublic personal information as necessary in the normal course of business, such as to open accounts, satisfy required compliance reviews, and complete transactions in client accounts. For example:

  • In order to open accounts, complete transactions, or otherwise service client accounts, it may be necessary to provide identifying information to custodians, TAMPs, companies, individuals, or groups not affiliated with BCM. In addition, BCM may provide the custodian/TAMP with a copy of the Investment Advisory Agreement with the client.
  • At times, we contract with non-affiliated companies to perform services for us. As necessary, we share information we collected from clients with such companies. We only release the information necessary for the third party to complete its assigned responsibilities. In addition, we require these third parties treat your personal information with the same high degree of confidentiality as BCM.
  • In addition to our TAMP clients, BCM uses certain third-party order management, billing, and reporting systems. As a result, BCM provides confidential client data to these third parties to complete these back-office services.
  • We will release client non-public personal information upon the client’s request or if we are compelled to do so by law or the requirements of a regulatory organization.
  • BCM uses “cookies” to track traffic and session data on its website, with the goal of measuring website usage and improving user experience. Your browser or device may allow you to block, delete, or otherwise limit the use of cookies.
  • BCM may use client non-public personal information in our own marketing efforts—to offer our products or services to you.
  • 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. BCM 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 is not shared, sold, copied, or disclosed except as stated above.

BCM at times will aggregate certain non-personal information and share this information with other firms. For example, BCM will often share aggregate ETF holding information with ETF sponsors as well as with our research affiliate, AIM. However, BCM 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 non-public personal information shared, please call the number at the end of this notice.

Confidentiality and Security Procedures

BCM emphasizes the importance of confidentiality by training employees, implementing operational procedures, and ensuring only appropriate personnel have access to client information. We maintain electronic and physical safeguards to help protect client non-public personal information.

How You Can Protect Your Information

If you access your accounts online, you should confirm that the anti-virus software and firewall/spyware protection is current on the computer(s) that you use. Avoid using public computers, such as at a library, internet cafe, or hotel, to access your accounts whenever possible. We also strongly recommend that you select a unique User ID and Password that does not contain any personal information (e.g., SSN, DOB, name, phone number) and is not identical to other passwords you use. An additional best practice is to not provide any of your account information, including online account usernames or passwords, to anyone, especially 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, particularly withdrawals and transfers. 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, BCM provides an annual notification of its client privacy policy to clients. BCM 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

BCM strives to maintain 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 law 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 applies these standards to all clients. BCM is also aware of and considers the stipulations set forth by individual states. In addition, the Securities and Exchange Commission’s Regulation S-P provides further guidance and requirements for handling and protecting non-public client information. BCM understands the importance of complying with our own policy, industry practices, and federal and state regulations.

NOTIFICATION OF BEAUMONT CAPITAL MANAGEMENT, LLC’S PROXY POLICY

BCM strives to maintain 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 law 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 applies these standards to all clients. BCM is also aware of and considers the stipulations set forth by individual states. In addition, the Securities and Exchange Commission’s Regulation S-P provides further guidance and requirements for handling and protecting non-public client information. BCM understands the importance of complying with our own policy, industry practices, and federal and state regulations.

ANNUAL FORM ADV OFFERING

Federal law, through the U.S. Securities and Exchange Commission (SEC), requires Beaumont Capital Management, LLC to 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 is required per Rule 204-3 of the Investment Advisers Act of 1940 and must be completed within 120 days of the firm’s 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 Capital Management, LLC – 75 2nd Avenue, Suite 700 – Needham, MA 02494 – (888) 777-0535.

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

No action is required as a result of this notice; however, please contact us if you have any questions.