Last Updated April 2024
At Brown Advisory, we believe that you deserve frank and open communication on all aspects of our relationship. In this spirit, we provide this annual summary of our policies relating to confidentiality, privacy of client information, identity theft program, mutual funds, conflicts of interest, trading commissions, proxy voting and Form ADV annual notices.
Confidentiality and Privacy Policy
(Regulation S-P and S-AM Notice)
Brown Advisory takes the confidentiality of your personal information and the privacy of your account very seriously. Our commitment to safeguard your personal information goes beyond our legal obligation to process your transactions accurately and securely. Whether we serve you online, in person, on the telephone or by mail, the principles that guide the way in which we conduct business are built upon our core values of trust and integrity.
To protect your personal information from unauthorized access and use, we use security measures that are designed to comply with federal law. These measures include physical, electronic and procedural safeguards that are designed to protect your personal information, including various measures to protect such information while it is stored electronically. We train and consistently remind all employees to respect client privacy (including the identity of our clients) and to recognize the importance of the confidentiality of such information. Those who violate our privacy policy are subject to disciplinary action.
Federal law (Regulations S-P and S-AM) requires us to inform you that we have on record personal information about you and that we obtain such information from you directly (e.g., information you provide to us on account applications and other forms, such as your name, email and mailing address, Social Security number, driver’s license numbers (or comparable), occupation, risk tolerance, assets and income) and indirectly (e.g., information on our computer systems about your transactions with us, such as your account balance and account holdings).
In addition to the personal information described above, we collect certain information about your use of our online services, such as IP addresses and the information on our websites that you access. As explained in more detail in our Cookie Policy, we use cookies to collect and store this and other information about your visit to, or use of, our online services.
Like all investment firms, in order to better serve clients, Brown Advisory needs to share certain non- public personal information in the normal conduct of our business with other members of the Brown Advisory corporate group and with unaffiliated companies with whom we have service agreements. We share your personal information in order to process transactions, maintain your account(s) and offer our services to you. This sharing allows us to: (i) provide better and more complete investment and strategic advice; (ii) develop new services that meet additional needs you may have; and (iii) comply with legal and regulatory requirements applicable to us and others in providing services to you. When we share information with unaffiliated companies that are under contract to perform services on our behalf, such as vendors that provide services directly related to your account relationship with us, we seek to require these companies to keep your information confidential and not use such information for any unrelated purpose. We may also be required to share non-public personal information to respond to court orders, regulatory requests and legal investigations and in connection with regulatory requirements and inquiries.
We do not sell information about you to third parties, we do not jointly market with non-affiliated companies, and we do not otherwise disclose information about you to non-affiliates so they can market to you.
For U.S. Persons Only: If you are a new client, we can begin sharing your information internally for marketing purposes 30 days from the date you are provided with this notice. When you are no longer our client, we continue to share your information as described in this notice. You may limit our ability to share information internally with other members of the Brown Advisory corporate group for marketing purposes by calling 410-537-5380 or by emailing [email protected]. If you opt out, your selection will be treated as permanent unless you tell us otherwise.
Additional information for UK and EU/EEA residents is available at https://www.brownadvisory.com/us/additional-information-uk-and-eueea-residents.
Pursuant to Section 503 of the Gramm-Leach-Bliley Act, this notice may be reduced or eliminated in future years. However, our Confidentiality and Privacy Policy will remain in effect and is available for your review at any time at https://www.brownadvisory.com/us/disclosures or by contacting your Client Service team. We will provide notice to you in case the Policy changes or as otherwise required by law.