As our client, you are entitled to know how we protect your nonpublic personal information and how we limit its disclosure.

This privacy policy applies to individuals and institutions who are clients of our firm or have been clients in the past. This privacy policy describes our policies and practices for collecting, disclosing, and safeguarding “nonpublic personal information,” which may include financial or other information about you.

Information We Collect

We collect nonpublic personal information about you from the following sources:

Information we receive from you on your client agreements, account opening forms, subscription agreements, or other forms. This information includes, for example, your name, address, email address, social security number and/or other government issued identifiers, professional, educational, or employment-related information transactions, assets and income, and other financial information.

Information We Disclose

We do not disclose your nonpublic personal information to anyone, except as permitted or required by law. This means, most importantly, that we do not sell client information – whether it is your personal information or the fact that you are our client – to anyone. Instead, we use your information primarily to complete transactions that you request. Here are the details:

• To implement your wealth management plan, including the selection of investment managers, it may be necessary to provide identifying information to nonaffiliated third parties.
• We share nonpublic personal information with our parent company affiliate Focus Financial Partners, LLC for its internal and external auditing purposes.
• In certain instances, we may contract with nonaffiliated third parties to perform services for us and, where necessary, disclose your information (described above) to them. In all such cases, we provide the third party with only the information necessary to carry out its assigned responsibilities and only for that purpose. Further, we require these third parties to treat your nonpublic information confidentially.
• Finally, we will release your nonpublic information if you direct us to do so, if we are required by law to do so or in other limited circumstances permitted by law – for example, to protect your account from fraud.

What Happens If You Close Your Account

If you decide to close your account(s), we will adhere to the privacy policies and procedures described in this notice.

Who Has Access to Your Personal Information

We restrict access to your nonpublic personal information to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with state and federal regulations to guard your nonpublic personal information.

We Will Keep You Informed

This publication replaces all previous statements of our privacy policy. As required by law, we will notify you annually of our privacy policy. We reserve the right to modify this policy at any time and will keep you informed of changes.

For California Residents

SCS complies with the California Consumer Privacy Act of 2018 (“CCPA”) by providing California residents with the following rights with respect to their personal information:

The right to know what personal information SCS has collected, used, disclosed and sold.  To submit a request to know, California residents may call SCS at 617-204-6400, or by sending an email to SCS at scsadministration@scsfinancial.com.  California residents may also designate an authorized agent to make a request for access on their behalf by sending an email to SCS at scsadministration@scsfinancial.com.

The right to request that SCS delete any personal information it has collected.  To submit a request for deletion, California residents may call the Investment Manager at 617-204-6400.  California residents may also designate an authorized agent to make a request for deletion on their behalf by sending an email to SCS at scsadministration@scsfinancial.com.

When California residents exercise these rights and submit a request, SCS will verify their identity by asking them for their email address, telephone number, and/or information about their account with SCS. SCS will endeavor to honor customers’ requests unless such a request conflicts with certain lawful exemptions under the CCPA. Please note that SCS is only required to honor such requests twice in a twelve (12) month-long period.

Exercise of these rights will have no adverse effect on the price and quality of SCS’s services.

For the twelve (12) month-long period prior to the date of this privacy policy, SCS has not sold any personal information about its customers; nor does it have any plans to do so in the future.