Privacy

Notice

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LMCG Investments, LLC (“LMCG”) considers Customer privacy to be fundamental to our relationship with you. We are committed to maintaining the confidentiality, integrity, and security of your personal information. It is therefore our policy to respect the privacy of current and former Customers and to protect personal information entrusted to us. We have established internal policies to protect your information, while allowing us to serve your needs.

Why Are You Receiving This Notice?

This notice describes LMCG’s privacy policy concerning our handling of your personal information. You are receiving this privacy notice because you are either a Customer of LMCG, or are considering becoming our Customer. The term “Customer” refers to clients of LMCG who are individuals, and certain trusts, and individuals who invest in a private fund managed by LMCG. We must provide this notice explaining our privacy policy when a Customer opens an advisory account with us or invests in a private fund managed by us. We must also provide a written notice, annually, to reflect any material change to our privacy policy.

The additional notice attached as Annex A applies only to certain EU Customers.

Safeguarding Privacy

LMCG maintains strict policies and procedures to protect your personal information. We restrict access to your information to our employees and marketing representatives who require it to provide you with our services. We maintain physical, electronic and procedural safeguards to protect your personal information. We treat the information we gather about you in a confidential manner.

Collecting Your Information

As part of our relationship with you, we may collect non-public personal or financial information directly from you or from other sources. We also collect information from applications or other forms. These may include your transactions with LMCG, marketing representatives, financial representatives, private funds, brokers, and financial institutions.

Information collected may include:
• Personal information, such as your name and address, phone number, e-mail address and social security number
• Financial information, such as your income, assets and goals
• Information about your account or investment with us, such as your account holdings and transaction history

Sharing Your Information

As part of servicing or maintaining our relationship with you and for other legally permitted or required purposes or as requested by any governmental agency or authority or to the extent reasonably necessary to prevent fraud and unauthorized transactions, LMCG may disclose your non-public personal and financial information, if applicable. This may include providing such information to service providers working with us to complete a transaction, to your custodian or consultant, and to your marketing representative, financial representative, private fund, broker or financial institution, to service your account or investment.

Unless specifically authorized in writing, we do not share your personal information with other companies not affiliated with us or engaged by us for marketing purposes. To further illustrate our commitment to our Customers, we will not share personal information with our affiliates unless you request or consent to the sharing (“opt-in”).

Even after your account with LMCG has terminated, we will continue to protect your personal information and only share that information as permitted and required by law.

Who We Are

For the purposes of this policy, “LMCG Investments, LLC” or “LMCG” includes LMCG Investments, LLC, any subsidiaries it may have from time to time, and any private investment funds managed or sponsored by any of them from time to time.
For questions concerning this policy, please contact us in writing to:

LMCG Investments, LLC
Legal and Compliance Office
200 Clarendon Street, 28th Floor
Boston, MA 02116