Privacy Policy

At Westfield Capital Management Company, L.P. (“Westfield”), protecting the privacy and confidentiality of your personal information is important to us. We value your business and the trust you put in Westfield. To offer you the financial services you seek, we collect, maintain, and use information about you on a routine basis. To help you better understand how your personal information is protected here at Westfield we are providing you with the following statement describing our practices and policies with respect to the privacy of customer information. In the event you terminate your client relationship with us, or become an inactive client, we will continue to adhere to the policies and practices described in this notice.

Information We Collect

As a trusted investment advisor, we collect, retain, and use nonpublic personal information about individual clients to provide products and services to them. We may collect nonpublic personal information about you from such sources as applications or other forms. This nonpublic personal information may include your address and social security number. We may also collect nonpublic personal information from your transactions with us or with others which may include account balances, account numbers and transaction history.

Who Receives Information and Why

All of the information Westfield collects is used for the purpose of delivering the services you have requested easily and efficiently. Westfield shares limited information it has about you with select companies, to the extent necessary, to help us provide our services. For example, when appropriate, Westfield may provide wire transfer instructions or settlement instructions to third party custodians to effect transactions between or from your accounts. Westfield does not disclose any nonpublic personal information about our clients or former clients to anyone, except as described herein and as otherwise required or permitted by law.

Service Providers

At times, Westfield will enter into arrangements with companies or firms whose expertise is essential for Westfield’s own services to function properly or to complete transactions. For example, Westfield works with specialized firms that provide proxy ballot voting services and firms which generate account statements for our clients. As permitted by law, certain service providers have access to customer information that is necessary to perform these functions. Westfield’s service providers are required, under a legal agreement, to safeguard your information and use it only for authorized purposes.

How We Protect Your Information

We understand that the protection of your nonpublic personal information is of the utmost importance. Guarding your privacy is a responsibility we take seriously. Westfield maintains strict procedures and policies to safeguard your privacy. We restrict employee access to client information to only those who have a business reason to know such information, and we educate our employees about the importance of confidentiality and client privacy.

Website Cookies Policy

This Cookies Policy explains what cookies are, how Westfield uses cookies and similar technologies on our website, and what you can do to manage how cookies are used.

What are Cookies

Cookies are small text files placed on your computer or mobile device by websites you visit. Westfield uses cookies to improve the functionality of our website and to track information about how the website is used to continually improve the user experience. Depending on the cookie type, cookies may be stored for the duration of your visit to a website and are then deleted from your device when you close your browser or are then saved on your device for a fixed period of time after the browser has closed and are then activated each time you visit the website where the cookie was generated.

Strictly Necessary Cookies
Strictly necessary cookies allow you to navigate our website and use its features. Without these cookies, some services (such as navigating between pages) may not work. These cookies do not track your internet browsing history and do not gather information about you that could be used for marketing purposes.

Website Functionality Cookies
Website functionality cookies are used to remember user preferences on our website and to provide you with certain functionality for ease of use. For example, Westfield may use cookies to remember choices you make, to recognize the browser from which you accessed the site, or to provide enhanced and more personal features. These cookies do not track your internet browsing history but can be used to help with marketing.

Performance Cookies
Performance cookies are used to analyze how our visitors use our website and to monitor our website’s performance. This allows us to provide a high-quality experience by customizing our website and quickly identifying and fixing any issues that may arise. The information collected by performance cookies does not contain personal information and is only used for statistical purposes.

Google Analytics Performance Cookies
These cookies are a type of performance cookie that Westfield uses to collect information about how visitors use our website. Westfield uses the information to help us improve a visitor’s website experience and learn more about their activity at our site. We do not share personal information with Google Analytics.

Salesforce Marketing Cloud Performance Cookies
These cookies are a type of performance cookie that Westfield uses to collect information about how visitors use our website. Westfield uses the information to help us improve a visitor’s website experience and learn more about their activity at our site for marketing and relationship purposes. Salesforce Marketing Cloud is connected to our Salesforce Customer Relationship Management platform. Westfield does not sell website traffic or user information to third parties for any purpose.

Managing Cookies
Most web browsers automatically accept cookies, but you may take certain steps to control the use of cookies by modifying your browser to reject cookies or to notify you whenever a cookie is sent to your hard drive. You can learn more about cookies and ways to manage them at http://www.allaboutcookies.org/ or http://youronlinechoices.eu. Please be aware that restricting cookies on westfieldcapital.com may impact the functionality and performance of the site and may result in access to some services or data being denied.

Disabling cookies
Please be aware that some of our services may not function if you disable cookies. If you experience any problems resulting from deleted cookies, you should contact your web browser provider.

Third-Party Links
When you click on a link to a third-party web site or other third-party resource, the third party may place a cookie from its own site. We do not control the dissemination of these cookies. You should check the relevant third-party web site for more information about these cookies.

Supplemental Data Privacy Notice for California Residents

This Supplemental Privacy Notice for California residents applies solely to individuals who reside in the State of California. _This supplemental notice is provided to you in order for us to comply with the California Consumer Privacy Act (“CCPA”).

The CCPA provides some California residents with certain data rights regarding what we do with your personally identifiable information (“PI”). If you are a California resident and it is determined that the CCPA applies to you, this section details those rights, how you may exercise them, and what Westfield will do in response.

Please note that the rights under the CCPA do not apply to PI collected, processed, or disclosed pursuant to Gramm-Leach-Bliley Act (Public Law 106-102) and Fair Credit Reporting Act (12 CFR 1022).

If you are an individual who resides in California and whose PI is collected and processed by Westfield, you may have the right to:

• Request that we disclose, free of charge, the categories and specifics of the PI we collect about California residents (and/or, if applicable, otherwise disclose to a third-party for business purposes).
• Choose to opt-out of the sale of PI. Westfield does not sell PI.
• Request that we delete the PI we have collected. Following our verification of the request, we will comply with the request and delete any or all the PI in our possession that we collected from the California resident and/or any or all such PI in the possession of our service providers, unless otherwise restricted by law or regulation.

Supplemental Electronic Privacy Notice for European Union and United Kingdom Residents

Westfield is committed to maintaining transparency and safeguarding the personal information of all individuals, including those residing in the European Union (EU) and the United Kingdom (UK), in accordance with applicable law. While our services are not intended for individuals in the EU or UK, to the extent that our processing of personal information is subject to the General Data Protection Regulation (GDPR), the Privacy and Electronic Communications Directive (ePrivacy Directive), the UK GDPR and/or the Privacy and Electronic Communications Regulations (PECR) for EU/UK-based individuals who may interact with our services, the following supplemental notice explains how Westfield uses cookies in accordance with the GDPR, the ePrivacy Directive, the UK GDPR and PECR.

Electronic Communications and Tracking

Westfield uses essential cookies and similar tracking technologies on our website to facilitate website functionality and navigation, and non-essential cookies to analyze website traffic and usage patterns, remember your preferences and deliver targeted communications where permitted.

Westfield will not process your personal information obtained through cookies and similar tracking technologies without a clear, affirmative consent. You can manage or withdraw your consent at any time through the cookie banner presented on your first visit to our website or by adjusting your browser settings.  Please be aware that essential cookies do not require consent and are used for Westfield’s legitimate business interests strictly to enable basic website functionality.

Westfield may also seek your consent to send you market commentary, investments insights or other related information. You may unsubscribe or manage your preferences at any time by clicking the unsubscribe link in each email or by contacting westfieldinsights@wcmgmt.com.

Questions and Exercising Your Data Privacy Rights

You may contact us in order to exercise any of your rights set forth in this privacy notice by calling this toll-free number (888) 220-0992 or by emailing us at wcmcompliance@wcmgmt.com. All individuals have the right to not receive discriminatory treatment by Westfield for the exercise of the privacy rights set forth in this policy. NOTE: All data privacy requests must be accompanied by verifiable proof of identity of the requestor.

Where to Find Out More

If you have any questions about our privacy program or the way your information is maintained and used, we would like to hear from you. Please call us at 617-428-7100, or write to:

Kathryn Kearney, Partner, CFO and CCO
Westfield Capital Management Company, L.P
One Financial Center
Boston, MA 02111-2621

Your trust is important. Westfield is committed to protecting your privacy
Westfield Capital Management Company, L.P.