Privacy Policy

Reynders, McVeigh Capital Management, LLC (“Reynders, McVeigh”, “we” or the “Firm”) respects your right to privacy. We are committed to maintaining the confidentiality and integrity of nonpublic personal information, and we want our clients and prospective clients to understand what information we collect and how we use it. Please read our Privacy Policy and reach out to us if you have additional questions or concerns.

CONFIDENTIALITY AND SECURITY

At Reynders, McVeigh, we take our responsibility to protect the privacy and confidentiality of clients’ and prospective clients’ information very seriously. We maintain appropriate physical, electronic, and procedural safeguards to guard nonpublic personal information. Our infrastructure is comprised of 100% cloud-based solutions. All cloud solutions use industry best practices for security and compliance including firewall protection, data encryption, multi-factor authentication, password complexity requirements, messaging security protection, endpoint antivirus protection, data loss prevention, and 24/7 monitoring of systems. Furthermore, vendors with access to nonpublic personal information undergo an annual due diligence verification process to ensure their informational safeguards adhere to our strict standards.

We provide our Privacy Policy to clients at the start of new relationships and annually thereafter. We continue to adhere to the practices described in this policy after clients’ accounts close.

WHY WE COLLECT YOUR INFORMATION

Reynders, McVeigh gathers information about our clients and their accounts in order to: 1) know clients’ identities and thereby prevent unauthorized access to confidential information; 2) design and improve the products and services we offer to clients; and 3) comply with the laws and regulations that govern us.

WHAT INFORMATION WE COLLECT

Reynders, McVeigh is required by industry guidelines to obtain personal information about you in the course of providing investment management services to you. We use this information to manage your account, direct your financial transactions, and provide you with valuable information about the assets that we manage for you. We gather this information from documents you provide to us, forms that you complete, and personal conversations. This information may include:

  • Your name, address, and social security number.

  • Proprietary information regarding your beneficiaries.

  • Information regarding your earned wages and other sources of income.

  • The composition and value of your managed portfolio.

  • Historical information we receive and maintain relating to transactions made on your behalf by Reynders, McVeigh, your custodian, or others.

  • Information we receive from your institutional financial advisor, investment consultant, or other financial institution with whom Reynders, McVeigh has a relationship and/or with whom you may have authorized us to gather and maintain such information.

HOW WE PROTECT YOUR INFORMATION

To fulfill our privacy commitment for prospective, current, and former clients, Reynders, McVeigh has safeguards in place to protect nonpublic personal information. Safeguards include, but are not limited to:

  • Policies and procedures to protect your nonpublic information and comply with federal and state regulations.

  • Contractual agreements with third-party service providers to protect your nonpublic personal information.

SHARING INFORMATION WITH NON-AFFILIATED THIRD PARTIES

We only disclose non-public client information to non-affiliated third parties (e.g., client’s custodian or broker) without prior client consent when we believe it necessary to conduct our business or as required or permitted by law, such as:

  • If you request or authorize the disclosure of the information.

  • To provide client account services or account maintenance.

  • To respond to regulatory authorities, a subpoena or court order, judicial process, or law enforcement.

  • To perform services for the Firm, or on its behalf, to maintain business operations and services.

  • To help us to prevent fraud.

  • With attorneys, accountants, and auditors of the firm.

  • To comply with federal, state, or local laws, rules, and other applicable legal requirements.

  • We do not sell your information and do not make any disclosure of client nonpublic personal information to other companies who may want to sell their products or services to you.

OPT-OUT NOTICE

If, at any time in the future, it is necessary to disclose any client personal information in a way that is inconsistent with this policy, Reynders, McVeigh will provide you with proper advance notice of the proposed disclosure so that you will have the opportunity to either opt-in or opt-out of such disclosure, as required by applicable law.

You are advised that we believe that sharing your private information under the circumstances noted above is either mandated by law or necessary to conduct our business and to best service client accounts. If you wish to opt out of any third-party disclosures, please contact us immediately. Opting out may render us unable to provide services to you and therefore necessitate that we terminate our management agreement with you.

At Reynders, McVeigh, we pledge to continue conducting our business in a manner that conforms with our pledge to you and all of our clients, their expectations, and all applicable laws.

If you have any questions or concerns about this Privacy Policy, please contact your portfolio manager or the Firm’s Compliance Department at:

Reynders, McVeigh Capital Management, LLC
10 Post Office Square, Suite N1010
Boston, MA 02109
(617) 226-9999