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TERMS OF USE



Please read this disclaimer carefully, by making use of this site, you indicate
your acceptance of the terms stated below.  If you do not accept these terms,
then do not use this site.

This internet site (the “Site”) and the materials that it contains have been
prepared by Choate, Hall & Stewart LLP (the “Firm”) for informational purposes
only. They do not constitute legal advice. Your use of this Site, including for
the purpose of communicating electronically with our attorneys, does not create
an attorney/client relationship between you and the Firm. Although efforts are
made to keep the contents of the site current, it may not reflect the latest
legal developments. The application of specific laws and legal principles will
vary according to location and individual circumstances. Anyone viewing
information contained in this Site should not act upon it without seeking
professional counsel from an attorney authorized to practice in his or her
jurisdiction.

The Firm does not solicit anyone to seek representation based upon viewing
this Site.

The Firm may alter, suspend, or discontinue this Site at any time for any
reason, without notice or cost. The Site may become unavailable due to
maintenance or malfunction of computer equipment or other reasons.


ACCESS TO THE SITE

By using this Site, you agree to waive any claim you might otherwise have
against the Firm that arises from your use of this Site or information provided
by this Site. In addition, by using this Site you agree to indemnify, hold
harmless and defend the Firm from any claims, damages, losses, liabilities and
all costs and expenses of defense, including but not limited to, attorneys’
fees, resulting directly or indirectly from a claim by a third party that
alleges injury, damage or harm in whole or in part arising from the provision by
you of information from, or claimed to be from, this Site, or that in any way
arises from your use of this Site or information provided by this Site in
violation of these terms.


COPYRIGHT & TRADEMARKS

This Site and all the information it contains, or may in the future contain,
including, but not limited to, articles, memoranda, bulletins, reports, press
releases, opinions, text, directories, guides, photographs, illustrations,
trademarks, trade names, service marks and logos (collectively, the “Content”),
is the property of the Firm, its partners, members, and employees, and is
protected from unauthorized copying and dissemination by U.S. Copyright law,
trademark law, international conventions, and other intellectual property laws.
Certain of the trademarks and logos displayed on the Site are owned by third
parties. Nothing contained on this Site should be construed as granting, by
implication, estoppel, or otherwise, any license or right to use this Site or
any Content displayed on this Site, through the use of framing or otherwise,
without the prior written permission of the Firm or such third party that may
own the trademark or copyright of material displayed on this Site.

Subject to your full compliance with these terms, the Firm authorizes you to
view the Content, make a single copy of it, and print that copy, but only for
your own lawful, personal, noncommercial use, provided that you maintain all
copyright, trademark and other intellectual property notices contained in such
Content, and provided that the Content, or any part thereof, is not modified.


DISCLAIMER OF WARRANTIES

To the fullest extent permissible pursuant to applicable law, the Firm disclaims
all warranties, express or implied, including, but not limited to, implied
warranties of merchantability and fitness for a particular purpose.
Specifically, but without limitation, the Firm does not warrant that: the
information on this Site is correct, accurate or reliable; the functions
contained on this Site will be uninterrupted or error-free; or defects will be
corrected, or that this Site or the server that makes it available are free of
viruses or other harmful components.


RESPONSE TO ONLINE REQUESTS

From time to time, Choate, Hall & Stewart may offer to provide information or
materials via email or otherwise to interested persons. Choate, Hall & Stewart
reserves the right, in its absolute discretion, to reject any requests for such
information or materials, or to discontinue the provision of such information or
materials to any person, for any reason whatsoever.


LINKS TO OTHER SITES

This Site may contain links to non-Firm sites. These links are provided to you
only as a convenience. Such linked sites are not under the control of the Firm
and the Firm is not responsible for the contents of any linked site, or any link
contained in a linked site. The inclusion of any link does not imply endorsement
by the Firm of the site, and the Firm shall have no responsibility for
information that is referenced by or linked to this site.


ELECTRONIC CORRESPONDENCE TO THE FIRM AND AFFILIATED SERVERS

Opportunities to send email or to subscribe to email distribution lists through
the Site are provided solely to let individuals send comments and communications
to use and to request information from us, and they do not give rise to an
attorney/client relationship. These messages are forwarded through the Site to
the appropriate persons within the Firm so that they may respond to the
questions or comments or provide the information requested, if they elect to do
so, which is at their discretion. In the event that the Firm is requested to
contact a visitor to this Site, contact information may also be used for
purposes of making that communication. Any electronic communication between you
and the Firm will not be privileged or confidential; may be disclosed to other
persons; and may not be secure. Therefore, you should not send any email to the
Firm that contains confidential or sensitive information. Further, all
information submitted is the exclusive property of the Firm. The Firm is
entitled to use any information submitted for any purpose, without restriction
(except as stated in the Privacy Statement) or compensation to the person
sending the submission. The user acknowledges the originality of any submission
communicated to the Firm and accepts responsibility for its accuracy,
appropriateness, and legality.


ENFORCEMENT OF TERMS AND CONDITIONS

These Terms are governed and interpreted pursuant to the laws of the
Commonwealth of Massachusetts, United States of America, notwithstanding any
principles of conflicts of law.

All disputes arising out of or relating to these Terms shall be finally resolved
by arbitration conducted in the English language in Boston, Massachusetts, USA
under the commercial arbitration rules of the American Arbitration Association.
The parties shall bear equally the cost of the arbitration (except that the
prevailing party shall be entitled to an award of reasonable attorneys’ fees
incurred in connection with the arbitration in such an amount as may be
determined by the arbitrator). All decisions of the arbitrator shall be final
and binding on both parties and enforceable in any court of competent
jurisdiction. Notwithstanding this, application may be made to any court for a
judicial acceptance of the award or order of enforcement. Notwithstanding the
foregoing, the Firm shall be entitled to seek injunctive relief, security, or
other equitable remedies from the United States District Court for the District
of Massachusetts or any other court of competent jurisdiction. If any part of
these terms is unlawful, void, or unenforceable, that part will be deemed
severable and will not affect the validity and enforceability of the remaining
provisions. The Firm may, at its sole discretion and without notice, revise
these terms at any time by updating this posting.


SENDING

Please do not send any confidential information via e-mail through this website.
Sending an e-mail to Choate does not give rise to an attorney-client
relationship, and will not be deemed to disqualify Choate from undertaking any
engagement for a current or future client. Before any attorney-client engagement
may be formed, Choate will need to check for possible conflicts of interest, you
will need to consider whether you wish to retain Choate as counsel, and we will
need to consider whether we wish to accept the potential engagement. In the
meantime, Choate reserves the right to represent parties with interests adverse
to you.


PRIVACY POLICY

Choate PRIVACY POLICY

Choate, Hall & Stewart LLP, is a firm of lawyers, with its sole office in
Boston, Massachusetts.  We are subject to Rule 1.6 of the Massachusetts Rules of
Professional Conduct, which provides that we shall not reveal confidential
information relating to the representation of a client.  An affiliate of the law
firm, Choate Investment Advisors, is a registered investment advisor.  Clients
of our Wealth Management Group receive services from both Choate, Hall & Stewart
LLP and Choate Investment Advisors.  This Privacy Notice applies to both
entities.

This Choate Privacy Policy (“Privacy Policy”) explains how Choate, Hall &
Stewart LLP, and Choate Investment Advisors (collectively “Choate”, “we”, “us”,
“our”) collects, uses, shares, and protects certain personal information
obtained from our clients and from visitors to our main websites [www.choate.com
and www.choateia.com] and the Choate WMG portal [www.choateweb.com] (the
“Sites”), in connection with the legal, investment advisory, and other services
we offer (collectively, the “Services”).  By visiting the Sites or using the
Services, you consent to our collection, use, and disclosure of your information
under the terms of this Privacy Policy.

Choate may obtain “Nonpublic Personal Information,” which is personally
identifiable information about you that is not publicly available that we obtain
and use in connection with providing the Services.

Amendments to this Privacy Policy will be posted to the Sites and/or in
connection with the Services and be effective when posted.  Your continued use
of the Services following the posting of any amendment to the Privacy Policy
shall constitute your acceptance of such amendments.

1. What Nonpublic Personal Information does Choate collect?

The type of Nonpublic Personal Information we collect depends on the Services
that Choate provides for you.  The Nonpublic Personal Information may include,
but is not limited to, the following information of yours and/or of a family
member:

 * Contact information, such as name, email address, and mailing address;
 * Financial information, such as income;
 * Account information, such as banking and debit cards numbers, investment
   account numbers, and associated account balances and usage;
 * Transaction information, such as brokerage and investment transactions;
 * Identification and demographics information, such as passport number,
   driver’s license or other state identification numbers, lifestyle
   information, social security number, and gender; and
 * Device identifiers, such as IP address.

2. How does Choate collect Nonpublic Personal Information?

We may collect your Nonpublic Personal Information directly from you, via email,
mail, telephone, the Sites, in person meetings, and cookies (see our cookies
policy, below.)  We also may receive Nonpublic Personal Information from others,
such as banks and other financial institutions, and from transactions with
Choate or others.

3. How does Choate Use Nonpublic Personal Information?

Choate uses your Nonpublic Personal Information it collects in a variety of ways
depending on the nature of our relationship with you and the Services we
provide.  We may use your Nonpublic Personal Information for our everyday
business purposes of providing Services, including, but not limited to:



Choate does not sell, disclose, or transfer any Nonpublic Personal Information
to third parties, except to third party service providers who are necessary for
us to perform the Services, such as stock brokers, cloud hosting services
providers, and as permitted or required by applicable law, rules or regulations,
or pursuant to the terms of this Privacy Policy.  We do not have any affiliates
or non-affiliated companies (i.e., companies not related by common ownership or
control), except as described herein.  We do not have any joint marketing
partners.

In the event that you decide to close an account or otherwise become an inactive
customer, Choate, will continue to follow this Privacy Policy with respect to
your Nonpublic Personal Information.

4. Your right to limit sharing.

Federal law gives you the right to limit:  (i) our affiliates from sharing
information about your creditworthiness; (ii) our affiliates from using your
Nonpublic Personal Information to market to you; and (iii) our sharing your
Nonpublic Personal Information with non-affiliates to market to you.  State laws
may give you additional rights to limit sharing.  Please direct any questions
regarding your rights to limit sharing to:  privacy@choate.com.

5. Cookies

Our Sites use cookies, messages given to a Web browser by a Web server.  The
browser then stores the cookies in a text file.  Our Sites use two types of
cookies:

Session cookies, which are temporary cookies that are deleted automatically
whenever you close all open Web browser windows.  Session cookies are used to
ensure that you are recognized when you move from page to page within the Sites
and that any information you have entered is remembered.  Session Cookies do not
collect information from your computer.  They typically will store information
in the form of a session identification that does not personally identify you.

Persistent cookies, which remain permanently on the cookie file of your
computer.  These persistent cookies contain the user ID used to access the
Sites, together with encrypted identification values associated with the user ID
in conjunction with the particular device (e.g. the PC, mobile device or other
computer from which you accessed the Sites).  These persistent cookies are used
to provide enhanced security measures, personalize your experience on the Sites,
monitor overall Site performance, enable multifactor authentication, recognize
the preferences of returning users, and provide overall Site usage reporting.
 Cookies placed on your devices do not contain any personal information, such as
an email address or name.

Although your browser may permit you to reject cookies, cookies are required to
login and navigate within our Sites.  If you choose to disallow cookies you will
be required to respond to challenge questions each time you log on to our Sites.

6. How we protect your Nonpublic Personal Information. 

We protect your account information from unauthorized access, to the best of our
ability, which is why you must enter a unique user name and password as well as
multi-factor authentication when you access the portal affiliated with Choate
Investment Advisors (the “Choate WMG Portal”).  Your password should never be
shared with anyone.

None of our other clients can access your Nonpublic Personal Information, and
only a restricted set of our employees can access your Nonpublic Personal
Information in order to provide our Services to you.  When you access password
protected portions of our Choate WMG Portal using a web browser, Secure Sockets
Layer (SSL) technology is used to protect your communications through server
authentication and data encryption.  We upgrade and maintain our technology on
an ongoing basis.

Although the Sites may link to some external sites, we are not responsible for
the privacy practices of those websites.  You may wish to review the privacy
policy of those third party external sites.

7. Minors.

We only collect, use, or retain Nonpublic Personal Information from or about
individuals under the age of 18 with prior written parental consent.  If a
parent or guardian believes that Choate has in its database the Nonpublic
Personal Information of a child under the age of 18 for which consent was not
provided, please contact us immediately at privacy@choate.com, and we will use
our best efforts to promptly remove such information from our records.  Minors
under the age of 18 must provide us with written permission of their parent(s)
or legal guardian(s) before accessing the Choate WMG Portal or using our
Services.

8. California Consumers Only

The information practices described above comply with applicable federal law.
 California laws place additional limits on collecting, using, selling, and
sharing Nonpublic Personal Information about their residents and consumers.  If
you are a California consumer, Choate will automatically limit the disclosure of
Nonpublic Personal Information to third parties and service providers as
permitted or required by applicable law or regulation.

California consumers have additional rights under the California Consumer
Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of
2020 (“CCPA”), with respect to Nonpublic Personal Information that is not
covered under certain federal laws and that identifies, relates to, describes,
is reasonably capable of being associated with, or could reasonably be linked
with a particular consumer or household under the CCPA (“Personal Information”),
including Personal Information revealing a consumer’s social security number,
driver’s license and passport numbers, and account numbers and credentials
(“Sensitive Personal Information”). If you are a California consumer, this
section summarizes your rights under the CCPA to the extent it applies, how you
may exercise them, and what Choate will do in response.

As a law firm, much of the data we collect and process is not subject to CCPA
consumer rights.  Without limiting the foregoing:

 * Personal Information subject to an evidentiary privilege, such as the
   attorney-client privilege and/or attorney work product protection, is not
   subject to consumer rights to know (consumer-specific information and
   copies), delete, modify, or opt-out under the CCPA as described below;
   however, we do include this Personal Information in our description of
   Personal Information, below.
 * Publicly available information (as defined by the CCPA) is not Personal
   Information under the CCPA and not included in the disclosures described
   below and is not data to which consumers have rights under the CCPA.

California consumers have the right to request:

 * Disclosure of
   * The categories of Personal Information, including Sensitive Personal
     Information, collected by Choate;
   * The categories of sources from which the Personal Information is collected;
   * Our business or commercial purpose for collecting, selling, or sharing
     Personal Information;
   * The categories of third parties to whom we disclose Personal Information,
     if any; and
   * The specific pieces of Personal Information we have collected about you.
 * Disclosure of categories of Personal Information sold or shared, and the
   categories of third parties to whom the Personal Information was sold or
   shared;
 * Disclosure of categories of Personal Information sold, shared or disclosed
   for a business purpose, and the categories of persons to whom the Personal
   Information was disclosed;
 * Deletion of the Personal Information from our records, and that we direct any
   service providers or contractor to delete your Personal Information from
   their records, unless this proves impossible or involves disproportionate
   effort;
 * Limitation of our use and disclosure of Sensitive Personal Information, and
   you have a right to know if your Sensitive Personal Information may be used
   by or disclosed to a service provider or contractor, for additional,
   specified purposes; and
 * Correction of inaccurate Personal Information about you. 

We will require a verifiable request from the California consumer before we
comply with a CCPA request.  You may use an authorized agent to submit a right
to know request or a request to delete.  To use an authorized agent, you must
provide the agent with written authorization.  In addition, we may require that
you verify your own identity, and we may deny a request from an agent that does
not submit proof that they have been authorized by you to act on your behalf. 
Such requirements will not apply where you provided the authorized agent with a
power of attorney pursuant to Cal. Prob. Code Section 4000 to 4465. 

Please note that we are not required to:

 * Retain any personal information about you that was collected for a single
   one-time transaction if, in the ordinary course of business, that information
   about you is not retained;

 * Reidentify or otherwise link any data that, in the ordinary course of
   business, is not maintained in a manner that would be considered personal
   information; or

 * Provide the personal information to you more than twice in a 12-month period.

We are not required to delete Personal Information if it is necessary for our
business to maintain the Personal Information to:

 * Complete the transaction, engagement or services for which the Personal
   Information was collected;
 * Detect security incidents, protect against malicious, deceptive, fraudulent,
   or illegal activity, or prosecute those responsible for the activity;
 * Debug to identify and repair errors that impair existing intended
   fuctionality;
 * Comply with applicable federal or state law;
 * Carry out solely internal uses that are aligned with your expectations based
   on your relationship with Choate; or
 * Use internally the Personal Information in a lawful manner that is reasonably
   aligned with your expectations based on your relationship with us.

Please also note that we are not obligated to comply with consumer requests to
the extent that doing so would infringe on our, or any other person’s or party’s
rights, or conflict with applicable law.

We may disclose your Personal Information for the following purposes:  (i) if
you direct us to share Personal Information; (ii) to comply with your requests;
and (iii) as otherwise required or permitted by applicable law, and this may
override your rights under the CCPA or other applicable privacy laws.

Choate may not discriminate or retaliate against you for exercising any of the
rights cited above.

In the preceding 12 months, Choate has collected the following categories of
Personal Information about California consumers from the following sources and
for the following purposes.  The CCPA requires that Choate reference specific
categories of Personal Information specified in the CCPA.  Choate may collect
only certain pieces of Personal Information described in a given category and
may not collect certain pieces of Personal Information described in each
category.



In the preceding 12 months, Choate has not sold any Personal Information about
California consumers.

In the preceding 12 months, Choate has shared or disclosed for a business
purpose the following categories of Personal Information about California
consumers:



We will keep your Personal Information while you have an account with us or
otherwise engage us or while we are providing services to you. Thereafter, we
will keep your Personal Information for as long as is necessary:

 * To respond to any questions, complaints or claims made by you or on your
   behalf;
 * To show that we treated you fairly; or
 * To keep records required by law.

We will not retain your Personal Information for longer than necessary for the
purposes set out in this policy. Different retention periods apply for different
types of Personal Information.

When it is no longer necessary to retain your personal information, we will
delete it.

If you have any questions regarding our Privacy Policy, or would like to
exercise any of your rights as described in this Privacy Policy, you can do so
by sending your requests to:

Email address:  privacy@choate.com; or

Toll free number:  1-833-590-0125

You may also send an email via the Contact page provided on the Sites.

Choate, Hall & Stewart LLC

Two International Place

Boston, MA 02110

LAST UPDATED:  November 02, 2023

 


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