Fernwood Investment Management, LLC

Notice of Privacy Policy

Fernwood Investment Management, LLC is committed to protecting the privacy of our customers and former customers. In order to issue and service high quality financial products and services, we collect personal information about you. We do not sell the information you have entrusted to us to third parties and we disclose your personal information only as necessary to provide the products and services you expect from a financial services leader. To help you understand how we protect your personal information, this notice describes our current privacy policy and practices. During the continuation of your relationship with Fernwood Investment Management, LLC, we will advise you of our privacy policy and practices at least once annually, as required by law.  This policy is applicable to information for current and former clients.

You do not need to take any action as a result of this notice, but you do have certain rights as described below.

INFORMATION WE MAY COLLECT AND USE

We collect information that assists us in servicing your financial needs. This information helps us provide you with a high standard of customer service, process your transactions, provide products that may interest you and fulfill legal and regulatory requirements. The personal information we collect includes information collected on applications and related forms such as, name, address, social security number, bank reference, annual income and net worth.

We do not collect medical or health information in connection with securities business, except in relation to an application for a variable insurance product.

HOW WE TREAT YOUR INFORMATION

Fernwood Investment Management, LLC may share the information described above with our service providers. These providers may require access to information about you to process or service transactions you have requested, to provide efficient customer services, or to inform you of our products or services you may find useful. Our service providers may be affiliated or unaffiliated, and may include financial service providers. Please be assured that we require these service providers to safeguard your personal information and to use or disclose it only for the work they are performing on our behalf, or as permitted by law.

We may provide information to regulatory authorities and law enforcement officials in accordance with applicable law, or to others when we believe in good faith that the law requires it. In the event of a sale of all or part of one of our businesses, we may share customer information related to that business as part of the transaction. From time to time, we may be required to give information about our business to regulatory authorities or as required by law.  This may include personal information about you.  We do not sell your personal information to anyone.

SECURITY OF INFORMATION

Keeping your information secure is one of our most important responsibilities. We maintain physical, electronic and procedural safeguards to protect your information. Employees are authorized to access your information only when they need it to provide you with products and services or to maintain your accounts.

MAKING SURE INFORMATION IS ACCURATE

We want to make sure that we have accurate information about you. Generally, upon written request, we will make your personal information available for your review. Information we have collected in connection with or in anticipation of a claim or legal proceeding will not be made available. If you believe that any of our records are inaccurate, you may notify us in writing of any corrections, amendments or deletions that you believe should be made. Questions about accessing or correcting your personal information should be directed to:

Fernwood Investment Management, LLC, 400 Crown Colony Drive, Suite 101, Quincy, MA 02169, Attn: Client Services Department or [email protected]  Please describe the information you wish to see or corrections required.

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