Privacy Policy

Information We Collect

Personal Information

Pursuant to the business relationship established between Buxton Helmsley and its clients, whether individual or corporate/institutional entities, Buxton Helmsley collects and processes certain personal information about individuals. The collection and processing of such information is necessary for Buxton Helmsley to fulfill its contractual and legal obligations, administer accounts, and provide the services requested by clients.

For individual clients, settlors/trustees/beneficiaries of trusts, or owners/principals of companies or other investment vehicles, Buxton Helmsley may collect and process, without limitation, the following categories of personal information:

• Personal identifiers, including but not limited to name, postal address, email address, telephone number, and other contact information;
• Demographic information, such as age, date of birth, occupation, and marital status;
• Financial information, including but not limited to source of wealth, investment experience and objectives, risk tolerance, income information, and other financial data required under applicable law or regulation;
• Government-issued identifiers, including but not limited to Social Security Number, taxpayer identification number, or other national identification numbers; and
• Commercial information, including records of products or services purchased, obtained, or considered, and other transaction and account data related to the relationship with Buxton Helmsley.

For employees, officers, directors, principals, or other representatives of Buxton Helmsley's corporate or institutional clients, Buxton Helmsley may collect and process, without limitation, the following categories of personal information:

• Personal identifiers, including but not limited to name, business contact information, and professional email addresses;
• Professional or employment-related information, including but not limited to title, position, role, duties, area of responsibility, and corporate affiliation; and
• Identification and verification information as required by applicable laws and regulations concerning due diligence, anti-money laundering, know-your-customer requirements, and other compliance-related matters.

The provision of personal information as described herein is voluntary; however, failure to provide certain requested information may result in Buxton Helmsley being unable to establish, maintain, or administer client accounts or relationships, or to provide the requested services. Buxton Helmsley reserves the right to collect additional categories of personal information as necessary or appropriate to fulfill its legal, regulatory, or business obligations.

Information Collected via Technology

When you visit our Site, we may collect certain information by automated means, such as cookies, web server logs, web beacons, and JavaScript. The information we collect in this manner includes:

• Your IP address, network location, and browser characteristics;
• Device characteristics, operating system, and browser type;
• Referring URLs and information on actions taken on our Site;
• Dates and times of website visits; and
• Other information that does not personally identify you.

We use both persistent cookies (which remain on your computer until you delete them) and session cookies (which expire when you close your browser).

Sources of Information

The personal information we collect about you comes primarily from:

• Account applications or other forms and materials you submit to us during the course of your relationship with us;
• Your transactions and experiences with Buxton Helmsley;
• Consumer reporting agencies (such as credit history information);
• Background screening and compliance databases;
• Public records and publicly available information; and
• Third-party data providers.

In addition, depending on the products or services you require, information may be collected about you indirectly from monitoring or other means (e.g., recording of telephone calls and monitoring emails) in compliance with applicable laws and regulations. In these circumstances, the information is not accessed on a continuous or routine basis but may be used for compliance or security purposes.

How We Use Your Information

We may use your personal information to:

• Administer, operate, facilitate, and manage your relationship and/or account with Buxton Helmsley, including sharing such information internally as well as disclosing it to third parties;
• Contact you by post, telephone, electronic mail, or facsimile in connection with your relationship and/or account;
• Provide you with information, recommendations, or advice concerning products and services offered by Buxton Helmsley;
• Process your transactions and fulfill our contractual obligations;
• Verify your identity and conduct appropriate due diligence;
• Comply with legal and regulatory obligations, including anti-money laundering regulations;
• Protect against fraud, financial crimes, and unauthorized access;
• Assess and manage risk and fulfill our legitimate business interests;
• Enhance and improve our services and the Site; and
• Facilitate our internal business operations.

If your relationship with Buxton Helmsley ends, we will continue to treat your personal information as described in this Policy to the extent we retain it.

Disclosures of Your Information

Disclosures Within Buxton Helmsley

In order to provide efficient and reliable services and to improve our product and service options available to you, more than one entity within Buxton Helmsley may be given, or given access to, your personal information. For example, one Buxton Helmsley entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts, or as part of its arranging for the performance of specialized services. When sharing your personal information internally, we adhere to applicable legal and industry standards regarding the protection of personal information.

Disclosures to Third Parties

Buxton Helmsley does not disclose your personal information to third parties, except as described in this Policy. Third-party disclosures may include sharing such information with:

• Non-affiliated companies that perform support services for your account or facilitate your transactions with Buxton Helmsley, including those that provide professional, legal, or accounting advice to Buxton Helmsley;
• Financial institutions with whom we have joint marketing agreements;
• Regulatory authorities and law enforcement agencies, as required by law;
• Others as necessary to comply with legal process, such as responding to a subpoena or court order;
• Others to protect our rights and interests and those of our business partners or pursuant to your express consent; and
• Others to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities.

Non-affiliated companies that assist Buxton Helmsley in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that Buxton Helmsley dictates.

You should know that Buxton Helmsley will not sell your personal information.

Data Retention and Deletion

We retain your personal information for as long as it is required by us for legitimate business purposes, to perform our contractual obligations, or as required by law or regulatory obligations which apply to us. Specifically:

• Account information is typically retained for a minimum of 7 years after account closure to comply with regulatory requirements;
• Transaction records are generally kept for a minimum of 7 years from the transaction date;
• Communications related to inquiries, complaints, or disputes may be retained for up to 10 years;
• Marketing preferences and subscription information is retained until you opt-out or request deletion.

We review our retention policies regularly and will securely delete or anonymize your personal information once it is no longer needed for the purposes for which it was collected, unless retention is required by law.

While we make every effort to ensure that all information we hold about you is accurate, complete, and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

Information Security

Buxton Helmsley is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized Buxton Helmsley employees or agents and, as described above, our service providers are held to stringent standards of privacy. We also maintain physical, electronic, and procedural safeguards to protect the information against loss, misuse, damage or modification, and unauthorized access or disclosure.

Some of the central features of our information security program include:

• A dedicated information security team that designs, implements, and provides oversight to our information security program;
• The use of specialized technology such as firewalls, intrusion detection systems, and advanced endpoint protection;
• Testing of the security and operability of products and services before they are introduced;
• Internal and external reviews of our systems infrastructure, including regular penetration testing and vulnerability assessments;
• Monitoring of our systems to detect weaknesses and potential intrusions;
• Implementing controls to identify, authenticate, and authorize access to various systems or sites, including multi-factor authentication for sensitive systems;
• Protecting information during transmission through various means including, where appropriate, TLS 1.2 or higher encryption standards; and
• Providing Buxton Helmsley personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

Privacy and the Internet

The following additional information will be of interest to you as a visitor to this Site:

• Users of private Buxton Helmsley web sites are required to identify and authenticate themselves prior to accessing our services. Generally, identification and authentication take place through the use of your user name and a password, or via multi-factor authentication where additional security is required.
• The private areas of our Site are built upon a secure infrastructure with multiple layers of protection, including measures ranging from proper physical security of our machines to system intrusion detection capabilities. Within such private sites, Buxton Helmsley uses industry-standard encryption technologies to protect your information from external compromise.
• Security is a cooperative effort between Buxton Helmsley and the users of the Buxton Helmsley web sites. Please remember that your password and any other login credentials are personal to you and should not be made available to any other person. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them.
• "Cookies" are small text files that may be placed on your web browser when you visit our website. We use both first-party and third-party cookies for the following purposes:
  • Essential cookies: Required for the operation of our website
  • Analytical/performance cookies: Allow us to recognize and count visitors and analyze website traffic
  • Functionality cookies: Enable the website to remember your preferences
  • Targeting cookies: Record your visit, pages visited, and links followed
• You can manage cookie preferences through your browser settings to accept, refuse, or delete cookies. Disabling cookies may affect your experience on our website as some features may not function properly.
• "Clickstream" data (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences) may be collected by Buxton Helmsley itself, or by our service providers, using cookies, web beacons, page tags, or similar tools that are set when you visit our website or when you view an advertisement we have placed on another website.
• Our Site may contain links to other websites. The linked sites are not under our control, and we are not responsible for the privacy practices or the contents of any linked site. We encourage you to review the privacy policy of any website you visit before you submit any personal information.
• Our Site responds to Do Not Track (DNT) signals. When we detect a DNT signal from your browser, we will disable tracking cookies and third-party analytics tools for your session, though essential cookies needed for site functionality will still operate.
• For mobile applications, if applicable, we collect device identifiers, location data (with your permission), and usage information. You can manage permissions through your device settings.

Your Rights and Choices

Access, Correction, and Deletion

You are entitled to access any personal data about you held by Buxton Helmsley by sending a written request to the applicable individual identified in Section 10. You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorized disclosure of your personal information. We will process your request within the time provided by applicable law.

When you request access to your personal information, our verification process includes:

• Confirming basic identifying information (such as name, email, and account number)
• Requiring responses to security questions linked to your account
• For sensitive information requests, we may require additional documentation such as a notarized statement

You are also entitled to have Buxton Helmsley modify or delete any information that you believe is incorrect or out of date. Please inform us promptly if you wish your personal information to be corrected or deleted.

Steps to exercise your rights:

1. Submit a written request specifying which right you wish to exercise
2. Complete our identity verification process
3. Receive confirmation of your request processing
4. Allow up to 45 days for request fulfillment (with possible 45-day extension with notice)

Marketing Communications

You have the right to prevent us from contacting you for marketing purposes. When we send a promotional communication, you can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional email or by contacting us directly.

You can manage your communication preferences by:

• Clicking the "unsubscribe" link in marketing emails
• Logging into your account and updating communication preferences
• Contacting us directly via the information in Section 10
• Specifying contact restrictions (email only, postal mail only, etc.)

Children's Privacy

Our Site and services are not directed to individuals under the age of 13. We do not knowingly collect personal information from individuals under 13. If we learn we have collected or received personal information from an individual under 13, we will delete that information.

Changes to Our Privacy Policy

Buxton Helmsley reserves the right to change this Privacy Policy at any time. We will notify you of significant changes by sending a notice to the primary email address specified in your account or by placing a prominent notice on our Site. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Site and this privacy page for updates.

How to Contact Us

If you have any questions or comments about this Privacy Policy, if you would like us to update information we have about you, or if you wish to exercise any of your rights as described above, please contact us at:

Jurisdiction-Specific Provisions

California Residents

If you are a California resident, you may have additional rights regarding your personal information under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). These rights may include:

• The right to know about personal information collected, disclosed, or sold;
• The right to request deletion of personal information;
• The right to correct inaccurate personal information;
• The right to opt-out of the sale of personal information; and
• The right to non-discrimination for exercising your CCPA rights.

For complete information about your California privacy rights, please see the detailed information below.

Additional Information for Other Jurisdictions

Depending on your country or state of residence, you may have additional rights regarding your personal information. Please contact us using the information above for more details on how to exercise these rights in your jurisdiction.