A Massachusetts corporation, incorporated on February 11, 1993.

(Adopted by the ad hoc Executive Committee for review of guidelines)

General Statement.

We recognize and respect the privacy expectations of today’s customers and the requirements of applicable federal and state privacy laws. We believe that making you aware of how we use your non-public personal information (also “personal information”), and to whom it is disclosed, will form the basis for a relationship of trust between us and the public that we serve. The present Privacy Policy and Guidelines provide that explanation. We reserve the right to change the present Privacy Policy and Guidelines from time to time consistent with applicable privacy laws.

In the course of our business, we may collect information about our clients’ business from the following sources:
from information we receive from you or your authorized representative;
from your transactions with, or from the services performed by, us, our affiliates, or others;
from our Internet Web sites;
from the public records maintained by governmental entities that we either obtain directly from those entities, or from our affiliates or others.

Our Policies Regarding the Protection of the Confidentiality and Security of Your Personal Information

We maintain physical, electronic and procedural safeguards to protect any protected or personal information from unauthorized access or intrusion. We limit access to the Personal Information only to those employees, contractors and agents who need such access in connection with providing products or services to you or for other legitimate business purposes. We will at all times comply with all laws and regulations to which we are subject regarding the collection, use and disclosure of individually identifiable information.

Our Policies and Practices Regarding the Sharing of Protected Information

We may share our clients’ information only within the company. We also may disclose the clients’ information in the very limited exclusions:
to our representatives to provide you with services you have requested;
to third-party contractors or service providers who provide services or perform marketing or other functions on our behalf;
to governmental entities to meet our legal requirements connected to the collection, retention and disclosure of individually identifiable information;
to law enforcement in connection with investigations, or civil or criminal subpoenas or court orders.

In addition, we will disclose the collected information when you direct or give us permission, when we are required by law to do so, or when we suspect fraudulent or criminal activities. We also may disclose your Personal Information when otherwise permitted by applicable privacy laws such as, for example, when disclosure is needed to enforce our rights arising out of any agreement, transaction or relationship with our clients.

One of the important responsibilities of some of our affiliated companies is to record certain documents in the public domain, as required for certain real estate transactions in the normal course of business. Such documents may contain the clients’ protected information.

Statutory Basis.

All “non-public personal information” as defined in Title V of the Gramm-Leach-Bliley Act (15 U.S.C. Section 6801, et seq.) and the implementing regulations thereunder (collectively, the “GLB Act”), as the same may be amended from time to time, that we receive from any individual or organization, concerning “customers” and/or “consumers” (as defined in the GLB Act) will at all times be collected, used and disclosed in accordance with the requirements and prohibitions of the GLB Act.