Privacy Policy

Effective: August 2021

BTM Financial LLC (“us”, “our”, or “we”) values your trust, and protecting your information is an important part of how we conduct our business. We believe it is important for you to know how we treat Personal Information that we may have about you. This U.S. Privacy Policy and Notice (“Policy”) is provided on behalf of our entities, as well as other persons or entities acting on our behalf.

This Policy describes how we collect, use, share, and protect (“process”) Personal Information, as well as your rights regarding this processing. Additional State specific privacy disclosures may be found at the end of this Policy.

Who Is this Policy Applicable to?

This Policy is applicable to (1) U.S. residents who use BTM Financial LLC services, and (2), non-U.S. residents who use BTM Financial LLC’s services and about whom we have Personal Information. This Policy does not apply to employees, job applicants, or contingent workers of BTM Financial LLC. Employees, job applicants, and contingent workers can find details about BTM Financial’s collection and use of their information here: US Personnel Privacy Notice. To the extent a BTM Financial affiliate provides a separate privacy policy or privacy statement applicable to consumers of its services, that affiliate’s privacy policy or privacy statement will supersede this Policy with respect to those consumers.

U.S. Personnel Data Protection Notification

OVERVIEW

BTM Financial (“us”, “our” or “we”) recognises its obligations in relation to the processing of its employees personal data under applicable data protection and privacy laws. This US Personnel Data Protection Notification (this “Notification”) provides information in relation to the collection, storage, access, use, and disclosure (“processing”) of your personal data by BTM Financial entities based in  the US that you are employed by (the “Firm”), including:

• Types of personal data the Firm processes;
• How the Firm collects your personal data;
• The purposes for which the Firm processes your personal data;
• The monitoring the Firm conducts;
• When the Firm discloses your personal data;
• How the Firm protects your personal data;
• How the Firm retains your personal data;
• Personal details relating to your family members and other individuals
• What marketing the Firm does; and
• Your rights under applicable laws.

This Notice applies only to US Resident employees, job applicants, and independent contractors. This Notice describes the rights you have over your Personal Information held with us.  

Types Of Personal Data The Firm Processes

Personal Data

The Firm and its authorized service providers may process information about you, which constitutes personal data under applicable data protection and privacy laws, including:

• Identifiers such as a
  • personal or work related contact information, such as name, current and previous postal address, unique personal identifier, telephone number, email address, employee ID
  • government-issued identifiers, such as social security number, driver’s license number, state identification numbers, passport number, or other similar identifiers as required and permitted by applicable laws and regulations;
• Any categories of Personal Information as described in state or federal law, including your ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual orientation, criminal offences or proceedings, age, date of birth, gender, marital status, details related to your family members, country of residence, and citizenship;
• Biometric information;
• Your credit report if a credit check requirement applies to your position;
• Internet or other electronic network activity information;
• Information about your citizenship and, if applicable, immigration status;
• Information about your emergency contacts, dependants and beneficiaries;
• Audio, electronic, or visual information, including an image of your passport or driver’s license which generally includes a head and shoulders photograph, and other photographic or video images of you (e.g., on Corporate Directory or on Firm issued security passes);
• Professional or employment-related information, including your occupation and prior work experience, role/position/title, and area of responsibility; and
• Education information. 

How The Firm Collects Your Personal Data

The Firm and/or its authorized service providers may collect and record your personal data from a variety of sources as further specified in this section. 

• From you or as a result of the employment relationship.
• From unaffiliated third party(ies) for limited use to a particular purpose(s) to fulfill limited purpose(s) or as may be permitted or required by law such as
  • Running pre-employment checks, in compliance with the Fair Credit Reporting Act (“FCRA”) where applicable,
  • Processing references on behalf of the Firm,
  • Health service providers, in compliance with the Health Insurance Portability and Accountability Act (“HIPAA”) where applicable,
  • Pension and benefits administrators,
  • Learning and development organizations,
  • Data analysis and survey companies,
  • Citizenship / immigration status verification companies,
  • Payroll processing companies, and
  • Any other services related to Human Resources
• From government, legal regulatory, supervisory, or other authorities under applicable laws or regulations.

The personal data we obtain through these sources will include your personal details, contact details, identification documents, personal identifiers, and financial account information.

Some of this information will be publicly accessible and some will be gained from databases that we access through authorized third parties.

While the Firm makes every effort to ensure that all your personal data are accurate, complete and up to date, you should regularly update and/or correct your personal data via the Firm’s Human Resources portal. The Firm shall not be responsible for the authenticity of any personal data or sensitive personal data or any losses arising from any inaccurate or deficient personal data or sensitive personal data that you supply to us.

The Purposes For Which The Firm Processes Your Personal Data

The Firm and/or service providers and/or third parties acting on our or their behalf, may process data for the following business purposes:

• Auditing related to interactions with the consumers and auditing compliance with this specification and other standards, including.
  • For reporting (including without limitation transaction reporting) to, and audits by, national and international regulatory, enforcement or exchange bodies and complying with court orders associated with us;
  • For Monitoring purposes as defined within and in the Global Monitoring Notice, subject to applicable law; and
  • To provide operational support and development of our businesses including to evaluate customer service, efficiency and cost, as well as for risk management purposes.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity, including
  • For security and risk management purposes, including to enable the Firm to identify you and to manage your access to Firm premises and interactions with clients, colleagues and other third parties; to manage conflict of interests, outside business interests and conduct risk; and
  • To carry out money laundering and conflict checks and for fraud, market abuse,  tax evasion,  insider trading, financial crime prevention and identification purposes (and this includes consideration of information regarding political affiliations and criminal offences committed or alleged to have been committed).
• Performing services on the Firm’s behalf as a business, including
  • To the extent reasonably necessary to manage and administer the employment relationship and the policies and procedures relating to the employment relationship including for: payroll, benefits, tax and time management; performance assessments and evaluations; sickness and absence management; workplace health and safety; disciplinary and grievances; flexible work and leave requests; internal reporting; learning and development; compensation decisions; internal mobility, licensing and registration requirements, and the provision of employment references;
  • To manage and administer the Firm’s Diversity Program which enables the Firm to measure its progress with regards to the composition of our employee base and the effectiveness of our diversity and inclusion strategy, to promote Diversity Networks or to invite you to training or career advancement opportunities (all of these being our legitimate interests);
  • For recruitment purposes, to confirm your references and educational background and to consider your suitability for any current or future recruitment requirements;
  • For internal training purposes; and
  • To contact you about services and products we offer (with your prior consent where required by applicable law).
• As otherwise necessary under law, including
  • To exercise and defend its legal rights anywhere in the world; and
  • For internal training purposes; and
  • To assist with investigations, complaints, regulatory requests, litigation, arbitration, mediation or requests from individuals in connection with any reorganizations, consolidations, liquidations or other any transactions changing the corporate form of the Firm

The Monitoring The Firm Conducts

“Monitoring” means the systematic and/or repetitive surveillance, tracking (including the use of cookies or similar technology), analyzing, profiling (as defined below) and/or reviewing of an individual’s (i) verbal and electronic messaging and communications, (e.g., telephone, facsimile, SMS, instant message, email, Bloomberg, Skype and video conferencing and any other electronic or recordable communications), and (ii) use of and access to technology owned by or made accessible by the Firm, or any other persons, including but not limited to systems that facilitate communications, information processing, transmission, storage and access, as well as remote access (and any data moving through and/or residing thereon; and (iii) use of and access to Firm premises (collectively “Firm Systems”) as further specified in the Global Monitoring Notice.

“Profiling”that includes any form of systematic and extensive processing of personal data to evaluate, analyze or predict personal aspects concerning an individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements. For further information on how the Firm conducts profiling of employees refer the Global Monitoring Notice. You are permitted to use Firm Systems for limited personal use. All information stored on or transmitted through the use of the Firm Systems and all recordings and transcripts of telephone conversations are the Firm’s property.

The Firm engages in monitoring of employee use of Firm Systems. You should not use Firm Systems for personal use if you do not wish your personal use and communication to be monitored.

To Whom The Firm Discloses Your Personal Data

To the extent permitted by applicable law, the Firm may process your personal data, for the purposes specified in this Notification, and disclose such personal data:

• Within the BTM Financial Group of companies;
• To our service providers, processing your personal data on our behalf or otherwise providing the Firm with professional or other services, including BTM Financial affiliates and vendors which conduct administrative, legal, operational, technology and customer service functions in various jurisdictions or third parties who offer services directly to employees via a corporate arrangement;
• To third parties, such as clients and prospective clients, trading venues, exchange or clearing houses, with whom you interact on behalf the Firm;
• To fraud prevention and other similar agencies, and other financial institutions, with whom information is shared for money laundering checking and fraud prevention purposes;
• To persons to whom we give our rights or obligations
• To a prospective seller or buyer in the event that we sell or buy any business or assets or if all or substantially all of our assets are acquired by a third party, in which case personal data held by us about our employees will be one of the transferred assets;
• To national and international regulatory, enforcement or exchange bodies or courts anywhere in the world or at their request;
• As required by applicable law or regulations; and
• To any third party to whom you authorize us to disclose your personal data.

California Residents’ Data Privacy Rights 

Under The California Consumer Privacy Act (“CCPA”) provides certain data privacy rights to California Residents.

If you are a California Resident and we have your Personal Information, under CCPA as of January 1, 2020 the following applies:

Notification of Personal Information Collection We collect, use and process your Personal Information, as described within this Notice, for expected internal reasons, Legal obligations, and servicing a transaction or providing a service. In addition we may use your information to detect security and fraud as well as technical support functions.  

Further detail on categories of and Personal Information collected about you, sources of, purposes for collecting, as well as Third Parties we disclose Personal Information to, are described within this document.

Will This Policy Change?

We reserve the right to modify or supplement this Notice at any time. Therefore, we recommend that you review this Notice, updated and posted on this Site, regularly for changes. The Effective Date of this Notice, as stated above, indicates the last time this Notice was revised.

Your continued use of our services after we have changed this Notice signifies your acceptance of the revised terms.  Under certain circumstances (i.e., with respect to material changes to this Notice), we may also elect to notify you through additional means, such as by posting a notice on the Site or sending you an email.

To the extent, a BTM Financial affiliate provides a separate privacy policy or privacy statement applicable to consumers of its services, that affiliate’s privacy policy or privacy statement will supersede this Policy with respect to those consumers. Additionally, clients, plan participants, and other individuals who, by virtue of the financial services we provide, have their Personal Information protected by the Gramm Leach Bliley Act (“GLBA”), can find details on how BTM Financial LLC processes your information in the GLBA privacy notices below, which supersedes this Policy.

Additionally, clients, plan participants, and other individuals who, by virtue of the financial services we provide, have their Personal Information protected by the Gramm Leach Bliley Act (“GLBA”), can find details on how BTM Financial LLC processes your information in the GLBA privacy notices below, which supersedes this Policy.

BTM Financial Privacy Pledge

(BTM Financial's long-standing commitment to safeguard the privacy of information our clients entrust to us is essential to our goal to be the world's first choice for financial services. Protecting the confidentiality and security of client information has always been an integral part of how we conduct our business worldwide.

We pledge to continue to ensure that our global business practices protect your privacy.

Where applicable, more specific privacy policies are posted on the home pages of our individual businesses.)

Includes processing information for non-U.S. residents about how and why we process Personal Information, as well as links to the privacy statements or policies of some BTM Financial affiliates.

The Privacy Pledge listed above also includes our Global Cookie Policy.

Global Cookie Policy?

How do we use Cookies and similar Technology?

We, our associated firms and/or other persons acting on our or their behalf use cookies and similar technology to collect, use and share information when you visit our websites or interact with us on-line e.g. via email or other electronic means.

Cookies are small, usually randomly encoded, text files that help your browser navigate through our websites. The cookie file is generated by our website when you access it and is accepted and processed by your computer's browser software or when you interact with us on-line. The cookie file is stored in your browser's folder or subfolder.

Cookies and similar technology enable BTM Financial LLC to capture and compile statistical information about how you use our websites and interact with us on-line, including information relating to the frequency of visits, IP addresses, readership data, (such as the average length of visits, which pages are viewed or shared during a visit or other interactions with our content such as time spent viewing videos, PDFs read and links clicked), authentication information, acceptance or rejection of website terms, periods of inactivity, time zones, language preferences and other regional information.

We, our associated firms and/or other persons acting on our or their behalf use this information for the following purposes:

• To assess the effectiveness of advertising and readership content;
• To improve the website content and performance;
• To estimate our audience size and usage pattern;
• To speed up your searches;
• To enable log in and authentication when you log onto our sites;
• To recognize you when you return to our sites;
• To deliver a better and more personalised service by allowing us to customise our site according to your individual interests; and
• To deliver marketing communications that may be of interest to you, including ads or offers tailored to you.

Information held in cookies or similar tracking technology set by BTM Financial are kept to a minimum and can only be read by BTM Financial, our associate firms, their authorized third parties or by someone who has physical access to your personal computer.

Some of our websites use Google Analytics to track your activity.

In addition to the cookies noted above, some of our websites may also serve third party cookies, which allows us, our service providers, and our third party business partners to deliver more relevant and tailored content.

Most browsers are initially set to accept cookies. However, you have the ability to disable cookies if you wish, generally through changing your internet software browsing settings. It may also be possible to configure your browser settings to enable acceptance of specific cookies or to notify you each time a new cookie is about to be stored on your computer enabling you to decide whether to accept or reject the cookie. To manage your use of cookies there are various resources available to you, for example the “Help” section on your browser may assist you. You can also disable or delete the stored data used by technology similar to cookies, such as Local Shared Objects or Flash cookies, by managing your browser’s “add-on settings” or visiting the website of its manufacturer. As our cookies allow you to access some of our website’s features we recommend that you leave cookies enabled. Otherwise, if cookies are disabled, it may mean that you experience reduced functionality or will be prevented from using the site altogether. 

Unless you have adjusted your browser setting so that it will reject cookies, our system will issue cookies when you access or use our websites or online services.By accessing or using our websites online services you consent to BTM Financial using cookies.In the event you refuse to accept cookies by adjusting your browser setting, some or all areas of our websites or online services may not function properly or may not be accessible.

How do we update this Cookie Policy?

We may change or update portions of this Cookie Policy to reflect changes in our practices and or applicable law and regulation. Please check this Cookie Policy from time to time so you are aware of any changes or updates to the Cookie Policy, which may be indicated by a change in the effective date noted at the beginning of this Cookie Policy.

U.S. Online Privacy Policy which include information on how we collect and process your personal information via cookies and websites.

U.S. Online Privacy Policy

Overview

BTM Financial LLC (“us”, “our” or “we”) appreciates that you have provided us with your personal information and protecting that information is an important part of how we conduct our business. We believe it is important for you to know how we treat information about you that we may receive through this site (“Site” or “online services”). Please read this Privacy Policy carefully before using this Site. This Online Privacy Policy currently is applicable only to United States consumers and only when they access and use this Site, and may not be applicable to transactions performed and information collected in other channels.

This Online Privacy Policy describes how we collect information when you access or use our online services and how you can update and control the use of information provided through our online services, how we use, share and protect that information, and how you can update that information. This Online Privacy Policy does not apply to other information we collect, including information collected on other websites, such as separate websites operated by our affiliates or business partners that do not post this Online Privacy Policy, or other information you may provide to us through other means.

Information Collected

We, and our affiliates, collect personal information you provide via forms, applications, surveys, documents or images you attach or upload, and other online fields.  Examples of personal information we may collect include your name, postal or email addresses, telephone, and fax or mobile numbers.  There are portions of our online services where we may collect personal information about you to fulfill your online requests (e.g. topics of interest). We may obtain information about you directly from you, through your use of our products and services and from third parties (such as credit bureaus and demographic firms).

When you visit our online services, we and companies we work with may track and collect information from the computer or mobile device you used to access our online services, including the following:

• Information about your device, such as your device model and manufacturer and Internet Protocol (IP) address of your device;
• Information about your browser, such as browser type and platform, operating system, and screen resolution; and
• Information about your browsing behavior, such as the link that brought you to our online services, any links clicked within our online services, the pages on our online services you visited, average time spent on these pages, and when they were visited.

Please see “Information about Cookies and Other Tracking Technologies” below to understand how we collect some of the data described above.  We, along with our service providers and business partners, use this data to calculate usage levels for our online services, diagnose problems, ensure that our online services function properly, and for the purposes described below under “Use of Collected Information.”

Use of Collected Information

We may use information you provide us through our online services to: 

• respond to your questions and requests;
• provide service support;
• manage institutional risk;
• assess your satisfaction with our services;
• contact you about updates to our online services;
• conduct research and analytics (for example, regarding the use of our online services), and provide you customized content and communications that we believe may be of interest to you;
• maintain measures aimed at detecting and preventing fraud and protecting the security of personal information and our online services;
• provide specified services to you;
• allow you to utilize features within our Site by granting us access to information from your device, such as contact lists, when you request certain services;
• monitor the performance of our online services, diagnose problems and ensure that our online services function properly, make our online services easier and more convenient to use, and otherwise administer our online services;
• investigate suspected fraud, harassment, or other violations of any law, rule, or regulation, the terms, rules or policies of our online services, or the rights of third parties, or to investigate any suspected conduct which we deem improper;
• comply with laws, regulations, legal processes and law enforcement requirements; and
• otherwise operate our business, or any other purpose that complies with applicable laws and regulations.

How We Share Personal Information

Any information we collect through your use of our online services may be shared with our service providers, financial institutions with whom we jointly offer financial products, our affiliates, or as permitted or required by law (such as credit bureau agencies, business we buy or sell assets from, and law enforcement or government agencies).

If we have information from you or information that is available from other sources, including from third parties from both offline and online sources, we may use it in combination with the information that we have collected through our online services. We can use this information to better tailor and personalize our services and communications to you, both online and offline, and for any other purpose that complies with applicable law and regulation.

We may also use and share data that we collect on an aggregate or anonymous basis (such that it does not identify any individual consumers) for various business purposes, where permissible under applicable laws and regulations.

Information about Cookies and Other Tracking Technologies

We, our affiliates and/or other persons acting on our or their behalf use cookies and similar technology, such as web beacons (also known as clear GIFs or pixel tags), or similar technologies as they may develop over time.  We use cookies and similar technologies to collect, use, and share information when you visit our online services or interact with us online, e.g., via email or other electronic means.

Cookies, Web Beacons, and Other Technologies

Cookies are small pieces of data sent from a website and stored on a device.  Cookies may enable us to capture and compile statistical information about how you use our online services, including information relating to your device’s IP address, the frequency of your visits, readership data (such as the average length of visits, which pages are viewed or shared during a visit or other interactions with our content, such as time spent viewing videos, PDFs read and links clicked), authentication information, acceptance or rejection of website terms, and periods of inactivity.  To learn more about cookies, including information on what cookies have been set on your device and how cookies can be managed and deleted, https://www.allaboutcookies.org/

Our online services also use web beacons.  Web beacons are invisible tags and may be placed on a webpage, in advertisements, or in an email or other message.  They usually work in conjunction with cookies, registering when a particular device visits a particular page.  For example, web beacons may count the number of individuals who visit our Site from a particular advertisement or who enroll in a service after viewing a particular advertisement.

How We Use These Technologies

We, our services providers, and third party business partners use information collected from cookies, web beacons, and similar technologies for the following purposes:

• to allow our online services to operate as you have requested;
• to understand how our online services are accessed and used;
• to recognize you when you return to our Site;
• to assess the effectiveness of advertising and readership content;
• to deliver marketing communications that may be of interest to you, including ads or offers tailored to you; and
• for other purposes described above under “Use of Collected Information.” 

We may combine the information that we collect through cookies, web beacons and similar technologies with other personal information we have collected from you from both online and offline sources.

BTM Financial LLC works with service providers to promote its products and services both on this Site and other websites.  For example, if you visit a page on this Site or third party websites that provides information about a BTM Financial LLC product, a cookie may be placed on your browser or device that identifies the product you viewed.  This information allows us, our service providers, and our third party business partners to deliver more relevant and tailored content, such as ads for that particular product.

Other than service providers, BTM Financial LLC does not allow unaffiliated third parties to collect personal information about your activities on this Site.  Nor does BTM Financial LLC serve ads promoting unaffiliated third party products or services on this Site.

Managing Your Preferences

Many web browsers allow you to manage your preferences. You can set your browser to refuse cookies or delete certain cookies.  Unless you have adjusted your browser setting so that it will reject cookies, our system will issue cookies when you access or use our online services.  In the event you refuse to accept cookies by adjusting your browser setting, some or all areas of our online services may not function properly or may not be accessible.

Do Not Track Policy

Most browsers can be set to send signals to third party websites requesting them not to track the user’s activities.  At this time, we do not respond to “do not track” signals.  Consequently, our third party service providers may indeed track and collect information about your online activities over time while navigating to, from and on our online services, notwithstanding any “do not track” signals we may receive.

Our Security Procedures

At BTM Financial LLC, our goal is to protect your personal information submitted to us through our online services. We maintain reasonable physical, electronic, and procedural safeguards that comply with applicable law to guard nonpublic personal information about you against loss, misuse or unauthorized access, disclosure, alteration or destruction of the information you have provided to us through our online services. We have internal policies governing the proper handling of consumer information by personnel and requiring third parties that provide support or marketing services on our behalf to adhere to appropriate security standards with respect to such information.

Links to Other Websites

This Online Privacy Policy only applies to the use and disclosure of information we collect through our online services. Our online services may contain links to other websites such as other BTM Financial LLC websites and sites belonging to third parties that are not affiliated with us. The inclusion of a link on our online services does not imply endorsement of the linked website or service by us. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites, or links posted on our online services. Information you disclose to other parties or through such sites is subject to the privacy and security practices and policies of those parties or websites.  We disclaim all liability, to the extent permissible, with regard to your access to such linked websites.  Access to any other websites is at your own discretion and we encourage our users to read the privacy statements of each and every website or online services visited in order to learn how such third parties may treat your information.

International Users

Our online services are United States-based and are controlled, operated and administered by BTM Financial LLC from its offices within the United States of America, and are made available to you on an unsolicited basis, without any marketing or promotion regarding these online services to you from BTM Financial LLC or its personnel.  This Online Privacy Policy is provided in accordance with and subject to applicable U.S. law.  If you decide to continue to access our online services from your location outside the United States, you hereby agree that your use of those services is subject to this Online Privacy Policy and your personal information will be transferred or processed in the United States.

Protecting Children’s Privacy Online

Our online services are not directed to or intended for individuals under 18 years of age.

Changes to this Online Privacy Policy

We reserve the right to modify or supplement this Online Privacy Policy at any time. Therefore, we recommend that you review this Online Privacy Policy, updated and posted on this Site, regularly for changes. The Effective Date of this Online Privacy Policy, as stated above, indicates the last time this Online Privacy Policy was revised.

Your continued use of our online services after we have changed the Online Privacy Policy signifies your acceptance of the revised terms.  Under certain circumstances (i.e., with respect to material changes to this Online Privacy Policy), we may also elect to notify you through additional means, such as by posting a notice on the Site or sending you an email.

What Are the Sources of Personal Information?

We may obtain Personal Information from the following sources:

• you;
• our clients, their agents or representatives, applications, forms, surveys, or other documents or images, or from your dealings and transactions with us and other sources;
• our Affiliates;
• third parties, including consumer reporting agencies, service providers, joint marketing vendors, demographic firms, and other financial institutions;
• websites or mobile applications owned or operated by us;   
• your use of our products and services; and
• sources that are publicly available.

What Personal Information Do We Process?

The type of Personal Information we process may vary depending on whether you deal with us as an individual or in connection with one of our corporate or institutional clients, your use of particular services, as well as the jurisdiction where you reside. We may process the following categories of information, among others (collectively defined as “Personal Information”):

• Identifiers, including the following:
  • contact information, such as your name, phone numbers, address, email address, device or browser identifiers, usernames and passwords, voiceprint, security questions and answers;
  • government-issued identifiers, such as your Social Security number, passport number, or other similar identifiers as required and permitted by applicable laws
• Characteristics of classifications, such as your age, gender, marital status, nationality, or citizenship;
• Commercial and financial information,such as account balances, statements, transactions, your source of wealth/income, investable assets, loans, investment experience and objectives, creditworthiness and credit history, and risk tolerance;
• Professional or employment related information, such as your current employer and job history; and
• Internet, mobile application, or other electronic network activity information, to the extent you access one of our websites or mobile apps, including your usage of the website or application and your location.

Why Do We Process Personal Information?

We use Personal Information to better tailor and personalize our services and communications to you and for any other purpose permitted by applicable law, including the following purposes:

• to administer and operate services, including, without limitation, validating your identity, fulfilling online requests, maintaining or servicing accounts, verifying customer information, authorizing or confirming transactions, retaining records of transactions, for billing and/or tax purposes, and provide other services that you may request;
• to provide operational and technical support and development of our businesses, including to improve or enhance our services, evaluate customer service, efficiency and cost, as well as for risk management purposes;
• to carry out credit checks (where applicable), money laundering, conflict checks, for fraud and financial crime prevention purposes, or other activity required under applicable laws;
• to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity;
• in order to comply with legal and regulatory requests made to us or any Affiliates anywhere in the world, and to assist with law enforcement, investigations, complaints, regulatory requests, litigation, arbitration, mediation, and other legal processes;
• for auditing or monitoring purposes, such as to establish the existence of facts (e.g., keeping records of transactions), to maintain compliance with regulatory or self-regulatory practices, to comply with applicable laws, and for other purposes permissible under applicable law; and
• to conduct research and analytics, and for marketing purposes such as offering products and services to you in accordance with applicable law.

With Whom Do We Share Personal Information?

We may share Personal Information at your request or to complete a transaction for which the Personal Information was collected, provide a service to you, assist you in exercising your rights with respect to your information, detect security incidents or illegal activity, conduct our regular business activity including quality assurance and marketing to you, and as required by law (for instance with regulators and law enforcement agencies).

We may share Personal Information for the purposes listed within this Policy to the following categories of recipients:

• our Affiliates;
• your agents, representatives, and other persons acting on your behalf or to whom you instruct or authorize us to disclose your Personal Information;
• if you are a representative of an entity or institution, to the entity or institution you represent;
• our service providers;
• third parties that are necessary to administer services to you or the client you represent or are associated with, such as general partners of funds we advise or manage;
• your employer or former employer, if you are or were a participant in a service for which your employer or former employer is a client of BTM Financial LLC
• our agents and representatives, such as attorneys, auditors, and other professionals;
• government, legal regulatory, supervisory, or other authorities under applicable laws;
• prospective purchasers and assignees in the event our business, or a portion thereof, is sold or assigned; and
• other third parties as may be required for the purposes set forth within this notice, or where we have obtained the appropriate authorization if required.

We may also use and share Personal Information on an aggregate or deidentified basis (such that it does not identify individuals) for various business purposes, where permissible under applicable laws.

We do not sell Personal Information, and we have not done so for at least the past twelve (12) months prior to the effective date of this Policy.

What Additional Privacy Rights May You Have?

California Residents

For California residents, the California Consumer Privacy Act (“CCPA”) provides certain rights regarding the information that we collect. In particular, you may have the following rights:

Notification of Personal Information Collection

We collect, use, and process your Personal Information, as described within this Policy, for expected internal reasons, legal obligations, and servicing a transaction or providing a service. In addition, we may use your information to detect security and fraud as well as technical support functions.

Further detail on categories of and Personal Information collected about you, sources of Personal Information, purposes for collecting Personal Information, as well as Third Parties to whom we disclose Personal Information, are described within this Policy.

Access to Specific Pieces of Information

You may request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months.

Upon your valid request, we will provide a report outlining specific pieces of Personal Information collected about you the consumer that you have requested. You may make this request a maximum of two times within a twelve-month period.

Deletion of Personal Information

You may request that we and our service providers delete any Personal Information that we collect from you. If you do so, please note we may have a legal reason to retain your information, as permitted by the CCPA, in accordance with the original reason provided for collecting and processing Personal Information as described within this document.

We retain Personal Information in accordance with our information management policies, which establishes general standards and procedures regarding the retention, handling, and disposition of our records, including Personal Information. Personal Information is retained as long as necessary to meet legal and regulatory requirements. Retention may be extended if we are required to preserve Personal Information in connection with litigation, investigations, and proceedings.

Opt Out of Sale

For the purposes of CCPA, we do not sell your Personal Information.

Anti-Discrimination

We will not discriminate against you for exercising your CCPA rights.

In order to provide a response, BTM Financial LLC may ask that you provide clarifying or identifying information to verify your request. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm that the Personal Information relates to you.

You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.

Agents who make requests on behalf of individuals will be required to verify their authority to make the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.

To allow us to process your CCPA request, please submit your request via the channels below:

Will the U.S. Privacy Policy Change?

We reserve the right to modify or supplement this Policy at any time. Therefore, we recommend that you review this Policy, updated and posted on this Site, regularly for changes. The Effective Date of this Policy, as stated above, indicates the last time this Policy was revised.