Federal legislation requires Bolton Global Capital, Inc. (“Bolton”) and Bolton Global Asset Management (“BGAM”) to notify its customers of our privacy practices. This document describes how we handle your personally identifiable nonpublic information.

Information We Collect

While using our products or services, we may collect the following types of nonpublic personal information about you:

  • Information we receive from you on applications or other forms;
  • Information about your accounts and transactions with us or others;
  • Information necessary to verify your identity in order to secure access to your nonpublic personal information;
  • Information we receive from customer reporting agencies; and
  • Other information you provide to us, include information needed for us to comply with all applicable laws and regulations governing the products and services we provide you

Information We Disclose

Bolton and BGAM respects and protects the privacy of those who use our products and services. We may disclose information about you to our staff, affiliates, representatives, their affiliated businesses, and third parties who provide you with financial products and services. Nonaffiliated third parties may include retirement plan sponsors, mutual funds companies, insurance companies, other broker-dealers, or clearing firms.

We treat information concerning our former customers the same way we treat information about our current customers. If you close your account(s) with Bolton or BGAM, we may share your nonpublic personal information with the new broker-dealer or custodian that you choose to aid in the transfer of your investments. In the event the representative servicing your account(s) leaves Bolton or BGAM to join another firm, the representative is allowed to retain copies of your personal information in order to continue servicing your account(s) at the new firm. The representative remains obligated to keep your personal information confidential and is only allowed to use your personal information to service your account(s).

We may disclose information such as your name, address, social security number, date of birth, transactional information, or other financial information when necessary for us to provide you with financial products, services or reports on your account(s), or where disclosure is prescribed by law. Neither Bolton nor BGAM will sell or share your information to nonaffiliated third parties who intend to market their products to you.

Securing Your Information

We restrict access to your personal and account information to our employees or agents who need to know this information to provide products or services to you or need access to this information to comply with applicable laws and regulations governing the products and services we provide. We employ physical, electronic and procedural security safeguards to protect your information from loss, misuse, or unauthorized alterations.

Opting Out Of Third Party Disclosures

If you prefer that Bolton, BGAM, or its representatives, do not disclose the nonpublic personal information about you to nonaffiliated third parties, you may opt-out of those disclosures, that is, you may direct us to not make those disclosures (other than disclosures permitted by law). If you wish to opt-out of disclosures to nonaffiliated third parties, you may contact our Compliance Department at 800-649-3883 or send a written request to Bolton Global Capital Services Corp., Attn: Compliance Department, 579 Main Street, Bolton, MA 01740.

If you have any questions about our privacy policy, you may contact your Bolton or BGAM representative or Bolton’s Compliance Department at 800-649-3883

BNY Research and Commentary