Marble Harbor Investment Counsel is committed to keeping your non-public personal information (“Information”) secure and confidential. We do not disclose your Information to anyone unless it is required or permitted by law, at your direction, or is necessary to provide our advisory services to you or on your behalf. The following information is intended to provide you with a better understanding of our privacy policy with respect to your Information.

Marble Harbor collects and maintains your Information in the course of providing you with advisory services. This Information is received from the following sources:

• Information that you provide to us to open and maintain your account, such as your name, address, telephone number, Social Security Number, birth date, email address, financial information;
• Information that we generate to service your account, such as account statements and internal reports;
• Information we may receive from third parties with respect to your account, such as trade confirmations and custodial statements; and
• Information we receive from your third party representatives, such as your attorney or accountant.

Marble Harbor may share your Information with third parties as permitted or required by law, or as authorized by you. For example, we may share your Information under the following circumstances:


• To other firms as directed by you, such as accountants, lawyers, etc.;
• To specified family members (as authorized by law and/or you);
• To third parties that assist us in servicing your account, such as a custodian or broker;
• To third parties that perform or provide services for us such as, accounting firms, software vendors and technology consultants; and
• To government and regulatory agencies and others, when required by law.

Our service providers are obligated to keep the Information we share with them confidential and use it only to provide services specified by Marble Harbor.


Marble Harbor will internally safeguard your Information by restricting access to only those employees who provide services to you or those who need access to your Information to service your account. In addition, we will maintain physical, electronic and procedural safeguards that meet federal standards to protect your Information. We require our employees to adhere to a Code of Ethics, which obligates them to maintain the confidentiality of all client Information.

If you have any questions or concerns about this Privacy Notice, please contact us at 617-956-6710.

This Privacy Notice applies to our current, former and potential clients and investors in our private investment vehicles. April 2018

Marble Harbor Investment Counsel, LLC (“Marble Harbor”) is an independent investment adviser organized in November 2005. The information contained on this website is intended for the use of citizens and residents of the United States only. Due to various state and foreign regulations and filing requirements, Marble Harbor and its representatives may only provide investment advisory services in those states and countries in which they are appropriately registered or otherwise exempt or excluded from registration requirements.

Marble Harbor’s web site is limited to the dissemination of general information regarding its investment advisory services to United States residents residing in states where providing such information is not prohibited by applicable law. Accordingly, the publication of our web site on the Internet should not be construed as Marble Harbor’s solicitation to effect or attempt to effect transactions in securities or the rendering of personalized investment advice or services for compensation over the Internet.

Furthermore, the information resulting from the use of tools or other information on this Internet site should not be construed, in any manner whatsoever, as the receipt of, or a substitute for, personalized individual advice from Marble Harbor. Any subsequent, direct communication by Marble Harbor with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides.

Nothing on this web-site should be interpreted to state or imply that past results are an indication of future performance.

Email messages are not encrypted, and may be subject to interception by a third-party. For this reason, do not include any non-public personal information in any email that you send to Marble Harbor.

Marble Harbor may provide links to other web-sites as a convenience to visitors. Marble Harbor does not, directly or indirectly, control the entities that provide or operate those web sites, and we are not responsible for their practices (including, but not limited to, their privacy practices). Marble Harbor does not make any representations with respect to the contents of any third-party sites or any products, services or information offered on those sites.