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.
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:
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.
The Firm and its authorized service providers may process information about you, which constitutes personal data under applicable data protection and privacy laws, including:
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.
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 Firm and/or service providers and/or third parties acting on our or their behalf, may process data for the following business purposes:
“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 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:
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.
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.
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'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.
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:
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.
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.
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.
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:
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.”
We may use information you provide us through our online services to:
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.
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.
We, our services providers, and third party business partners use information collected from cookies, web beacons, and similar technologies for the following purposes:
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.
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.
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.
Our online services are not directed to or intended for individuals under 18 years of age.
We may obtain Personal Information from the following sources:
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”):
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:
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:
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.
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:
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.
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.
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.
For the purposes of CCPA, we do not sell your Personal Information.
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:
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.
4 Canterbury Road, Denville, NJ -07834, United States
Unit No. 807, Tower-B4, Spaze I Tech Park, Sector-49, Sohna Road, Gurgaon Haryana, India (122018)