Privacy Policy

Collecting and using personal information is necessary for our business as a financial services company to offer and administer our products and services and to comply with our regulatory obligations.

This Electronic Privacy Policy applies to Websites owned and/or operated by Easterly Asset Management (“Easterly[BF1.1][BF1.2]”) that link to it. It explains the personal information that we collect when you use our Websites, how we use it, with whom we may share it, how we safeguard it, the rights you have, and how you can contact us about our privacy practices.

By voluntarily providing us with personal information, you are consenting to our use of it in accordance with this Privacy Policy.

If you are a current or former customer or client of Easterly, we will also handle your Personal Information in accordance with our Customer Privacy Notice and other privacy policies, which are linked on this page.

The Information We Collect

The information we collect falls into three general categories:

1. Information voluntarily provided by individuals or their authorized representatives
2. Information we collect from third parties
3. Information automatically obtained from electronic devices

It is collected on paper forms and written correspondence, by telephone and faxes, and using online means such as the Internet and electronic devices.

The information that we collect online depends on which of our Websites you are visiting or using, what you request or do on them, your relationship to us, interactions, and whether you can register or need to log in as a customer, client, account owner, care provider, advisor, financial professional, business partner, or other authorized user. Some information is provided by you to us while other data is automatically gathered.

When you visit our Websites, receive and respond to some of our email communications, or if you click on certain advertisements we place on other websites, we, our contracted service providers acting on our behalf, and other third parties may receive and collect certain information from and about you which may include personal information.

Information recorded and collected via email will be retained and monitored in order to respond to your requests or inquiries, comply with certain regulatory obligations, and used for analytics and quality assurance purposes.

We collect and use aggregated data such as statistical and demographic data for several purposes including operational efficiencies, product development, and marketing. Aggregated data does not directly or indirectly reveal the identity of an individual.

We may combine the information we collect from you with information obtained from other sources to help us improve your Easterly experience, and to help us better personalize our interactions with you.

If you use the Websites from outside of the United States and submit any Personal Information to us through the Websites, you acknowledge and agree that such Personal Information may be transferred to the offices and servers of Easterly and the authorized third parties referred to herein located in the United States and, potentially, in other countries (the “Other Countries”). You acknowledge and agree that the privacy and data security laws of such Other Countries may be different from the privacy and data security laws in force in the country in which you reside and agree that the privacy and security laws in effect in the applicable Other Countries may govern how your Personal Data may be collected, used, stored and/or disclosed.

Cookies

The firm’s websites, mobile apps, and online services may place or access information on your browser, primarily through small data files known as cookies and similar technologies (collectively, “cookies”). Cookies help our websites operate properly and allow us to remember your preferences, tailor content, evaluate the effectiveness of advertising and search activity, and enhance your overall experience with our products.

Our cookies fall into the following categories:

1. Necessary Cookies

These cookies are required for our websites to function and cannot be disabled through our systems. They are used to:

• Maintain site security and stability
• Enable navigation and form submissions
• Support compliance-related functionality

Without these cookies, certain materials or site features may not be accessible.

2. Audience Attestation & Preference Cookies

To comply with regulatory requirements and ensure that visitors view only content appropriate to their role, we use cookies that store audience selections and preferences.

• audience_type (e.g., “institutional,” “advisor,” “individual,” “affiliate”)
  This cookie records a visitor’s attestation that they meet the criteria to view a particular audience-specific experience (such as institutional-only or advisor-specific content). It allows us to remember that selection during future visits and helps prevent repeated eligibility prompts.

  These cookies do not verify investor status independently, but they record the visitor’s self-certification.
  

3. Functional Cookies

Functional cookies enhance usability and consistency across visits by remembering selections such as site preferences or navigation settings. These cookies help ensure that content is presented in a clear and efficient manner.

4. Analytical / Performance Cookies

We use analytical cookies to understand how visitors interact with our sites, including:

• Pages visited and time spent on content
• Traffic sources and general usage trends
• Technical performance and usability issues

Information collected through these cookies is aggregated and used to improve site performance, content organization, and the delivery of investment information. It is not used to identify individual visitors.

Marketing Cookies

Marketing cookies may be used to measure the effectiveness of digital outreach related to our investment products and services. These cookies help us understand engagement with our communications and may be used to deliver relevant Easterly-related content on third-party websites. They do not store directly identifying personal information such as names or email addresses.

SMS

We will not share “customer” opt-in to an SMS campaign with any third party for purposes unrelated to providing services of that campaign. We may share Personal Data, including SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages. All of the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Account Information from Other Financial Institutions

In order to provide certain advice or services to you, you may direct us to retrieve and aggregate information from accounts you have with other financial institutions. It may include current balances, transaction histories, and holdings from brokerage accounts, investment accounts, bank accounts, credit card accounts, and similar accounts you designate. By providing the name of the other financial institution, your user credentials and other necessary information, you grant Easterly and its authorized service providers the right, power, and authority to act on your behalf to access and securely transmit your personal and financial information from the relevant financial institution(s) you designate.

How We Use Personal Information

We use your personal information when directed or requested by you, to operate our business, and provide services to you, such as to:

• Personalize and enhance your experience while you are visiting or using our Websites, to make navigation easier, and to gather usage statistics,
• Help recognize you as a previous visitor and save and remember your preferences and settings and deliver relevant content to you,
• Verify your identity to allow access to your accounts, and protect the security of your account,
• Provide customer service, respond to your inquiries, correspond with you and provide you with updates about your account or service, send you electronic newsletters, contact you for customer satisfaction surveys, contests, and to conduct market research,
• Market and advertise to you as well as for interest-based behavioral advertising. We work with third-parties to display digital advertisements for products and services that may interest you.
• Administer our business, including data analytics, audits, developing and improving products and services, measuring the effectiveness of our marketing and advertising campaigns, for risk management purposes, to prevent, detect and investigate crime, including fraud and money laundering, to demonstrate compliance in regulatory examinations, and to comply with a legal process such as a court order or subpoena,
• For certain services, we will use and disclose personal information: when opening an account on your behalf with an independent brokerage firm or custodian; providing that independent third party with ongoing information required to provide continuing services to you; creating and managing your investment portfolio consistent with your investment objectives and personal preferences; and aggregating account balances and transaction activity to present to you online or in regular statements for your convenience,
• When you provide your email address to us, we and our service providers may use it to send you general notices, alerts or important news about your account, request your feedback, ratings, or opinions, and may provide updates, or offers for products and services that might interest you.
• Respond to a job opportunity you inquired about or applied for,
• We will also use or disclose your Personal Information in order to comply with legal, regulatory or administrative requirements of governmental authorities, to protect and defend the rights or property of Easterly, in urgent circumstances to protect the personal safety of users of the Websites or the public, and as permitted or required by applicable law.

We will also use or disclose your Personal Information in order to comply with legal, regulatory or administrative requirements of governmental authorities, to protect and defend the rights or property of Easterly, in urgent circumstances to protect the personal safety of users of the Websites or the public, and as permitted or required by applicable law.

How We Share Information

We may disclose or share your personal information with:

• Our own affiliates,
• Service providers to perform services or functions on our behalf, including advertising agencies to promote our brand, products, and services, across different media,
• Advertising technology partners, ad networks, search engines, and social media platforms,
• Insurance support organizations,
• Financial advisors, brokers, agents and their firms,
• Other financial institutions as part of a joint marketing agreement for products offered by Easterly,
• Consultants and advisors including law firms, accountants, auditors, and tax advisors,
• Reinsurers,
• Group policyholders (for an audit or reporting claims data),
• Regulators, tax authorities, fraud prevention agencies, law enforcement agencies, and courts,
• Third parties who conduct actuarial or research studies,
• Others as required by law, and
• Another company as part of a corporate transaction, if Easterly or any of its affiliates or lines of business is acquired, merged, divested, sold, disposed of or dissolved.

Social Media

We use social media platforms to provide product and service information, articles, news, events and career opportunities. These platforms enable online sharing and collaboration among users who have registered to use them. Any content you post on social media pages, such as pictures, videos, information, opinions, “Likes”, or any Personal Information that you make available to other participants on these social platforms, is subject to the terms of use and privacy policies of those platforms. We may receive certain information about you when you use our Social Media pages, including your social media account ID and profile picture.

Some of our Websites may include social media buttons or icons (“plug-ins”) that enable users to easily share information on a social media platform. These plug-ins may log certain information such as your IP address, browser type and language, and what webpages you view and when. If you are logged into those social media platforms while using our Websites, they may also link such collected information with your profile on that platform. We do not control these third-party tracking technologies. We encourage you to review the privacy policies on social media platforms where you have an account to better understand how these third parties collect and treat such information. We are not responsible for the privacy or security practices of the social media platforms we use.

How We Protect It

We use a combination of security measures and maintain physical, technical, and administrative safeguards designed to keep your Personal Information safe.

For example, we employ encryption techniques such as Transport Layer Security (TLS) and authentication technologies intended to safeguard the transmission of your personal information over the Internet. Some of our Websites utilize a timeout feature, which will automatically log you out of your account after a period of idle time.

You should be aware that no method of transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure. There are steps you can take to help protect yourself, such as:

• Install anti-virus and anti-spyware software on your computing device.
• Update your software when updates or patches become available to help address vulnerabilities that phishing scams and viruses may seek to exploit.
• If you maintain an account that you access through our Websites or Apps, you are responsible for protecting and maintaining the confidentiality of your user id and password, passcode, answers to security questions and restricting access to your computing device.
• If you have an Easterly account that is accessible online and become aware of any suspicious activity, it is your responsibility to contact us immediately.
• Internet email is not necessarily secure. For that reason, do not use unsecured email to communicate sensitive or personal information to us that you may consider to be confidential.
• Always use an encrypted webpage or application to transmit personal or financial information. An “https://” and a padlock icon displayed in the address bar of your web browser will confirm you are on encrypted sections of our Websites.
• We recommend never disclosing your financial details on any social media site.
• Easterly Apps should only be downloaded directly from the official Google Play or Apple App Store.

Be Aware of Fake Messages

To help protect yourself, do not trust any unsolicited telephone call, email or text message that requests your personal information. Fraudsters can make telephone numbers and messages look like they come from legitimate sources, including Easterly, and include links, QR (quick response) codes, or instructions directing you to a website designed to trick you into revealing information. If you receive a suspicious message that appears to be from Easterly, do not reply, open any attachment, or click on a link. Instead, contact us directly to confirm the legitimacy of the message you received.

Learn more about how to protect yourself on the Internet.

How long do we retain your personal information?

Depending on the nature of our relationship with you, we may retain your personal information for a number of years after our relationship ends. We will retain it in accordance with our Records Management Policy to maintain business records for analysis and audit purposes, to comply with our record retention obligations under applicable law and regulations, and to defend or bring any complaints or legal claims. The length of time will depend on the specific purpose for which we collected and used your Personal Information.

Children

Our products and services are not marketed to or intended for use by minors. We do not knowingly collect personal information online from anyone under the age of 18. By using our Websites or Apps, you represent that you are 18 years of age or older. No one under 18 years of age should use our Websites or Apps.

International Visitors

Easterly’s Websites and Apps are hosted in the United States and Canada and are not directed at users located outside the United States. If you are a resident of other countries, you should note that by providing your personal information, you consent to:

• The transfer of your personal information to the United States or Canada which may not have the same data protection laws as the country in which you reside; and
• The use of your personal information in accordance with this Privacy Policy.

For California Residents

This Notice describes our privacy practices with respect to personal information we collect or obtain about California residents that is covered by the California Consumer Privacy Act and California Privacy Rights Act, as amended (collectively, the “CCPA”).

Please keep in mind that not all personal information collected from California residents is subject to the CCPA. The law does not apply to your personal information when it is protected by others, including the Gramm-Leach-Bliley Act, the California Financial Information Protection Act, the Health Insurance Portability and Accountability Act (HIPAA), the Fair Credit Reporting Act, the Driver’s License Protection Act, or certain insurance laws.

This means, for example, that the CCPA does not apply to personal information collected in connection with obtaining or seeking to obtain a financial product or service (insurance, retirement, or investments) from Easterly. If you are a customer or client of Easterly, an insured, owner, or beneficiary under a policy, or have inquired or applied to obtain a product or service from us, such personal information is instead subject to other laws and our Customer Privacy Notice applies to you.

This Notice does not apply to employees or job applicants. If you are a job applicant, employee or contractor of Easterly, please refer to our Personal Information Privacy Statement for details on how we use your personal information.

This Privacy Notice describes how we collect, use, and disclose the Personal Information of California consumers and your rights under the CCPA. This includes information about your activities on our Sites (such as pages viewed and links clicked on), and your general geolocation, IP address, unique personal identifier, online identifier and similar identifiers to display advertising about our products and services that are tailored to your individual interests. You have the right to opt out of this type of sharing by clicking on the “Do Not Sell or Share My Personal Information” link or by using a browser-based opt-out preference signal.

Information We Collect

One or more of our various businesses have collected the following categories of Personal Information from California residents within the last twelve (12) months:

Sources

We obtain Personal Information provided voluntarily by you when you visit or use our websites and mobile applications or submit an inquiry, request, or a concern directly to us or our service providers online, by mail, email, or telephone.

We also collect information from third parties and publicly available sources, which include data service providers, social media platforms, market research firms, financial professionals, other financial services firms, employers and group plan sponsors, travel companies, and consumer reporting agencies.

Business Purposes for Collecting Personal Information

Collecting and using Personal Information is necessary to our business as a financial services company in order to develop, enhance, and administer our products and services, respond to your requests, inquiries and concerns, inform and educate you about our company and events, support our diversity, equity and inclusion initiatives, for vendor management, and for advertising and marketing purposes. It also helps us to confirm your identity for certain transactions you request or that are initiated on your behalf, improve our website and mobile application user experience, authenticate users, prevent and detect fraud and potential security issues, and fulfill our legal, accounting, and regulatory obligations such as tax reporting.

When we collect Sensitive Personal Information, we only use or disclose it for the following permissible purposes:

• To perform or provide services requested by you or reasonably expected by an average consumer who requests such services,
• To prevent, detect, and investigate security incidents,
• To detect and respond to malicious, deceptive, fraudulent, or illegal actions directed at Easterly,
• To ensure the physical safety of a person,
• For short-term, transient use, including non-personalized advertising displayed during your current interaction with us, and
• To perform services on our behalf, such as maintaining or servicing accounts, and processing transactions.

We currently do not collect or use Sensitive Personal Information for the purpose of inferring characteristics about consumers.

Disclosures of Personal Information

In the preceding 12 months, we may have disclosed your Personal Information for a business or commercial purpose, as permitted or required by law, or as otherwise explained in this section. Before disclosing Personal Information to a service provider, we enter into a contract that describes our business purpose for disclosing and requires the service provider to keep the Personal Information confidential and to use it only for purposes of performing the contract between us.

Depending on which of our businesses collected it, your Personal Information may have been disclosed to:

• You, and where appropriate, your authorized representatives, legal agents, family members, or other persons acting on your behalf or to whom you ask, instruct or authorize us to disclose your Personal Information,
• Our contracted service providers who provide a service to or on behalf of Easterly, including analytics service providers, payment providers and intermediaries, and event coordinators,
• Third parties for purposes of cross-context behavioral advertising,
• Our auditors, consultants, accountants, attorneys and others providing professional advice to Easterly,
• Other Easterly or Manulife affiliates,
• Other financial institutions and reinsurers,
• Financial intermediaries (your agent, advisor, broker, or brokerage firm and its staff), aggregators, clearinghouses, clearing or settlement systems,
• Group policyholders, plan sponsors and their third-party administrators,
• External custodians and business partners of Easterly,
• Applicable governmental, regulatory, supervisory, law enforcement, tax or similar agencies,
• Any other person or entity Easterly reasonably thinks customary, necessary or advisable for the business purposes disclosed in our Privacy Notices or to whom Easterly is obliged by applicable law or regulation to make the disclosure,
• Any other party where Easterly has obtained your consent or authorization.

Business Purposes for Disclosure of Personal Information

• To perform services on our behalf, including providing customer service, processing or fulfilling orders, account maintenance, distributions, and transactions, processing payments, event registration or travel bookings, financing, and quality control,
• For risk management purposes, identity verification, information security, fraud detection and prevention,
• To prevent money laundering, terrorist financing, bribery, and corruption,
• Administer our business including operational efficiencies and improvements, product enhancements, and business development purposes,
• To demonstrate compliance with our regulatory obligations,
• For reinsurance purposes,
• For tax reporting,
• Advertising and marketing,
• In connection with legal proceedings, such as responding to a subpoena or court order,
• In the event of any planned or actual company reorganization, merger, sale, or transfer of our business.

How long do we retain your Personal Information?

Depending on the nature of our relationship with you, we may retain your Personal Information for a number of years after our relationship ends. We will retain it in accordance with our Records Management Policy to maintain business records for analysis and audit purposes, to comply with our record retention obligations under applicable law and regulations, and to defend or bring any complaints or legal claims. The length of time will depend on the specific purpose for which we collected and used your Personal Information.

Your Rights

Right to Know

You have the right to request that we disclose certain information to you about our collection of your Personal Information. Upon our receipt of your verified request, we will provide you with the following:

• The categories of Personal Information we have collected about you,
• The specific pieces of Personal Information we have collected about you,
• The categories of sources from which we have collected your Personal Information,
• Our business or commercial purpose(s) for collecting or sharing your Personal Information,
• The categories of third parties with whom we have disclosed your Personal Information.

Please note that even if your request is validated, we will not disclose sensitive information such as a Social Security Number, driver’s license number or other government-issued identification number, financial account number, health insurance or medical identification number, account password, or answers to security questions.

You also have the right to request that we disclose certain information to you about our disclosures of your Personal Information to third parties. Upon our receipt of your verified request, we will provide you with the following:

• The categories of Personal Information we have collected from you,
• The categories of Personal Information that we disclosed about you for a business purpose.

Right to Correct

You have the right to request that we correct or update your Personal Information if it is inaccurate. We will use commercially reasonable efforts to correct it upon receiving a verifiable request. We may choose to delete your Personal Information rather than correct it. We may not be able to agree to your request if it may violate any law or regulatory requirement or cause other information to be incorrect.

Right to Opt-Out of Sale or Sharing

You have a right to request a business that sells or shares Personal Information not to sell or share yours. Easterly does not sell the Personal Information about current or former customers (including the personal information of minors under the age of 18) to any third parties.

We may “share” certain personal information with third parties, such as advertising technology partners and ad networks, for interest-based behavioral advertising when we engage them for our digital advertising. These third parties use cookies, pixel tags, and similar technologies to collect and store information to enable cross-contextual advertising.

This includes information about your activities on our Sites (such as pages viewed and links clicked on), and your general geolocation, IP address, unique personal identifier, online identifier and similar identifiers to display advertising about our products and services that are tailored to your individual interests. You have the right to opt out of this type of sharing by clicking on the “Do Not Sell or Share My Personal Information” link or by using a browser-based opt-out preference signal.

Right to Limit Use and Disclosure of Sensitive Personal Information

We currently limit our uses and necessary disclosures of Sensitive Personal Information only to those purposes permissible under California law as described above in the “Business Purposes for Collecting Personal Information” section of this Policy. Where we also do not use or disclose it for the purpose of inferring characteristics about consumers, we do not offer a right to limit our use and disclosure of your Sensitive Personal Information. In the event our practices change, we will update this Policy and provide you with an option to limit our use and disclosure of your Sensitive Personal Information.

Right to Request Deletion

You have the right to request that we delete certain Personal Information we collected from you. We will use commercially reasonable efforts to honor your verified request. If we agree to your request, we will also notify, if possible, our service providers, contractors and third parties of your deletion request. However, in many cases we cannot delete all or some of it due to our regulatory obligations to retain certain information, or as required or permitted by other applicable laws, such as for fraud prevention and similar purposes. We will explain to you what we will delete and what we cannot, and the reason for retention.

Right of Non-Retaliation

We will not discriminate against you for exercising your privacy rights, such as denying you products and services, charging you different rates or prices, or suggesting or providing a different level of service to you.

How to Exercise Your Rights

To submit a request to exercise any of your rights provided in this notice, please use or submit your request by phone by calling us at 888-814-8180.

We must be able to verify your identity and relationship to Easterly before we take action on your request. Please provide sufficient information to assist us, including a transaction date, account or policy number, and state of residence. Let us know if there is anything specific that you are requesting. We may request additional information from you to help us verify your identity and process the request. You do not need to create an account in order to submit a privacy rights request.

You may designate an authorized agent to make a request on your behalf. If your request is submitted by an authorized agent, we will take reasonable steps to verify the agent’s identity and authorization to make the request on your behalf.

We will confirm receipt of a request to know, delete, or correct your Personal Information within 10 business days. We will respond to a verifiable request within 45 calendar days after we receive it. If we require more time (up to an additional 45 calendar days), we will provide you an explanation of the reasons why it will take more than the original 45 days to respond to your request. We will deliver our response electronically or by mail, whichever you prefer.

For Our Business Partners

Links to Other Websites
We offer you certain choices about how we communicate with you and what information we collect from you online. Some of our Websites or Apps provide features that allow you to access and update Personal Information you have provided, or manage your communications preferences.

Most browsers are initially set to accept cookies. You can change your browser’s settings to disable or refuse cookies or to inform you when they are set. You also have the ability to delete cookies that you have accepted. If you delete or disable cookies, you may not be able to take full advantage of our Websites. For example, you may not be able to sign in and access your account, or we may not be able to recognize your online preferences. We honor the Global Privacy Control opt-out signal that is sent by participating browsers when you visit our website.[DT4.1]

You can opt-out of analytics activity by setting your browser to notify you when a cookie is sent and block analytics cookies if desired. Review your browser’s Help Menu for instructions.

If you do not want to continue to receive electronic newsletters or receive marketing materials by email, you can indicate your preference by using the “opt-out” or “unsubscribe” link provided in such email messages.

You also may contact us as described in the How To Contact Us section below with questions or comments about our privacy practices.

Your Rights and Choices

We offer you certain choices about how we communicate with you and what information we collect from you online. Some of our Websites or Apps provide features that allow you to access and update Personal Information you have provided, or manage your communications preferences.

Most browsers are initially set to accept cookies. You can change your browser’s settings to disable or refuse cookies or to inform you when they are set. You also have the ability to delete cookies that you have accepted. If you delete or disable cookies, you may not be able to take full advantage of our Websites. For example, you may not be able to sign in and access your account, or we may not be able to recognize your online preferences.

You can opt-out of analytics activity by setting your browser to notify you when a cookie is sent and block analytics cookies if desired. Review your browser’s Help Menu for instructions.

If you do not want to continue to receive electronic newsletters or receive marketing materials by email, you can indicate your preference by using the “opt-out” or “unsubscribe” link provided in such email messages.

You also may contact us as described in the How To Contact Us section below with questions or comments about our privacy practices.

Changes to this Policy

We may periodically update this Privacy Policy without prior notice by posting a revised version of it on our Websites or in our Apps, indicate when it was most recently updated and include its effective date. Any changes will become effective immediately upon posting. We encourage you to periodically review this Privacy Policy to stay informed about our privacy practices. Your continued use of the Websites or Apps after any changes or revisions to this Privacy Policy shall indicate your consent to its terms.

Effective Date

This version of our Privacy Policy is effective as of December 3, 2025.

How to Contact Us

Easterly Compliance Officer
138 Conant Street, Suite 100
Beverly, MA 01915
Email: compliance@easterlyam.com