Windham Capital Management, LLC recognizes the importance of respecting the privacy of its clients. Below are details about the types of information we collect about our clients, how we use and share this information, and how we safeguard this information. Our Privacy Policy applies to our current and former clients.

Information We Collect About our Clients

Windham may collect personal information such as name, address, social security number, net worth, income, investment experience, and other nonpublic personal information that it deems necessary in order to provide financial products or services. This information may come from applications, service contracts, subscription agreements, questionnaires, or electronically through email or our website.

Windham may also collect non-personal data. This type of information includes the internet browser you are using, domain names of referring sites, the geographical location from which you are browsing our site, and your Internet protocol address. This information is used to enhance our site and better our advertising endeavors. Under no circumstances will we know who you are unless you divulge this information.

Disclosure of Information

It is Windham’s policy to share your personal information only with third parties or service providers who need to know such information in order to provide necessary services on our behalf. We limit the information available to service providers to that which is necessary for them to deliver their services. Otherwise, Windham only releases nonpublic personal information under the following circumstances: (1) we are directed in writing by you, the client, to do so, or (2) we are required by law to disclose the information. To the extent possible, third parties who receive client information will be contractually obligated to hold client data to at the least the same degree of security as Windham.

Security of Information

Windham is committed to keeping your nonpublic information secure, and restricts access to client information only to those employees and third parties who need to know such information in order to provide financial products or services. Windham employees are prohibited from copying or otherwise maintaining unauthorized copies of client data. Windham maintains physical, electronic, and procedural safeguards to ensure that all client information remains secure. It is Windham’s policy to work only with third parties who treat nonpublic personal information with the same level of importance that Windham does. Windham shall also maintain the confidentiality of all advice, recommendations and trading information relating to trades made on behalf of a client

Keeping Clients Informed

Windham reserves the right to change its Privacy Policy at any time. When any material changes do occur, all clients will be promptly notified. The most recent copy of our Privacy Policy can be found at our website at www.windhamcapital.com.

Windham has been and continues to be bound by standards of confidentiality that are even more stringent than those required by law; we have and will always protect every client’s right to privacy.

Protecting the Confidentiality and Security of Current and Former Client’s Information/Assets

Windham retains records of services that we provide so that we are better able to assist a client with its needs, and to comply with legal requirements. In order to guard client nonpublic information, Windham maintains physical, electronic, and procedural safeguards that comport with its standards of confidentiality. Windham will take appropriate steps to comply with the requirements of Rule 206(4)-2 of the Investment Advisers Act. Windham employees are prohibited from using client assets for its, his or her benefit.