PRIVACY POLICY

As you know, protecting the confidentiality and security of your information has always been an important part of the way we conduct our business.

We recognize and respect your privacy expectations and we believe that confidentiality and protection of investor information is one of our fundamental responsibilities. New technologies have dramatically changed the way information is gathered and used, but our continuing commitment to preserving the security and confidentiality of investor information has remained a core value.

We collect personal information from you so we can provide investment management services to you. The types and categories of information we collect and maintain about you includes:

  • Information we receive from you to open an account or provide investment advice to you (such as your home address, telephone number, date of birth, social security number, and financial information);
  • Information we receive from your accountant, lawyer, etc.;
  • Information that we generate to service your account (such as trade tickets and account statements); and
  • Information that we may receive from third parties with respect to your account (such as trade confirmations and other reports from brokerage firms and custodians).

In very limited instances we disclose your personal information to non-affiliated third parties, and then only in connection with providing investment management services to you and only as permitted by law. Some of the instances are listed below:

  • Disclosures to your tax preparer pursuant to your instructions;
  • Disclosures to companies that perform services on our behalf (such as our technology consultants who maintain our computer systems);
  • Disclosures necessary to service your account (such as providing account information and trading orders to custodians and brokers); and
  • Disclosures required by law.

Policies and procedures are in place that are designed to safeguard the confidentiality of your personal information. These include:

  • Physical, electronic, and other safeguards to keep your personal information safe;
  • Limitation of access to personal information to those employees who need it to perform their job duties and are trained in the proper handling of client information; and
  • Protecting information of our former clients to the same extent as our current clients.

If you prefer that we do not share your nonpublic personal information to non-affiliated third parties (other than disclosures permitted by law, which include information necessary to service your account), you may direct us not to share such information ("opt-out"). In order to opt-out, you may indicate your preference on this form and return it to us at the following address:

Derby & Company, Inc.
7 Wells Avenue
Newton, MA 02459

We are committed to protecting your financial privacy. If you have questions about this policy, please call Jonathan J. Derby at (617) 527-0033. As always, if you would like a copy of our most recent ADV Part II, please contact us and we will be happy to mail you one.