Last Updated: January 2019
BDF LLC (“BDF”) maintains physical, electronic, and procedural safeguards that comply with federal standards and the European Union’s (“EU”) General Data Protection Regulation (“GDPR”) to protect its clients’ nonpublic personal information (“information”) and to the extent applicable, information that may directly or indirectly identify you (“personal data”). For the purposes of policy, and to the extent that GDPR applies, “information” shall also include “personal data.” Through this policy and its underlying procedures, BDF attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.
In order for BDF to conduct its business with you, BDF will collect information about you from the following sources: (1) information BDF learns in performing investment management and wealth planning reviews on your behalf, whether personally or in writing, by telephone or otherwise; (2) information from transactions you have with us or others; (3) information BDF receives, with your authorization, from third parties such as accountants, legal counsel, financial advisors, insurance agents, banking institutions, brokerage firms and others; and (4) information we collect from you when you visit our web site (“Site”) such as cookies or when you fill out a form on our Site. Please be aware that we are the sole owners of the information collected on our Site and will not sell or share this information with anyone unless otherwise specified.
Personal information BDF collects includes, but is not limited to: client’s name, address, birthdate, social security number, bank account number(s), tax identification number, other government-issued identification numbers; other forms and documents client sends to the Advisor, gender, information to create client’s online account (such as username and password); and any other information about client’s transactions with Advisor.
BDF will only use your information for the purpose of providing investment advisory services to you, including, but not limited to: (1) to monitor, audit, evaluate and otherwise administer our services; (2) to communicate with you; (3) in an effort to protect against fraud and identity theft; (4) comply with applicable legal requirements, relevant industry standards, contractual obligations, and our policies and terms; and (4) for other purposes as required or authorized by law, including other purposes for which you have provided your consent and our legitimate interests.
To lawfully process your information, BDF retains one or more of the following lawful bases: (1) your voluntary consent in connection to providing you with BDF’s investment services; (2) as necessary in order to fulfill certain contractual obligations; (3) as necessary to comply with applicable rules, laws, and regulations; and (4) as necessary in connection to the legitimate interests of our firm and/or a third party.
In terms of your rights, to the extent permitted by applicable law, you may request: (1) to have your personal information corrected; (2) to opt out of receiving marketing communications at any time; (3) to file a complaint with an applicable government regulator; (4) to access the information BDF holds about you; (5) to restrict or object to the processing of your information, or request that your information is erased; (6) to receive a copy of the information you have provided to BDF, in a structured, commonly used format (known as “data portability”); (7) have a copy of your personal information provided to you or another controller where technically feasible; (8) to withdraw your consent to information that you provided to us voluntarily, or otherwise consented to its use.
In accordance with the above, BDF may take steps to verify your identity before granting you access to your information.
It is the policy of BDF to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to the client. BDF may disclose the client’s information if BDF is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with BDF, including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment Advisor, account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the client for processing and/or transmittal by BDF in order to facilitate the commencement/ continuation/termination of a business relationship between the client and a nonaffiliated third party service provider (i.e., broker-dealer, investment advisor, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for BDF (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.
BDF does not share your information with third parties so that they may directly market to you. BDF does not have any affiliates.
To the extent permitted by applicable law, BDF retains your information for the period necessary to serve the purposes for which BDF obtained it. BDF may also retain your personal information beyond such period in accordance with applicable laws, regulations, or another lawful basis, including but not limited to, compliance with our contractual obligations, legal obligations, regulatory obligations, legal claims, or another legitimate interest.
BDF will endeavor to ensure your personal information is kept accurate, complete, up to date and relevant. Please let BDF know if any of your details change. If you feel your information is not accurate, complete or up to date, please notify us and we will take reasonable steps to ensure it is corrected. You can contact us using the details listed below.
To the extent GDPR applies, BDF is the data controller for this policy located at the address below.
Additional Information about Our Site
For additional information about our Site policies, please refer to the Appendix below.
Changes to this Policy
BDF will provide each client with initial notice of the firm’s current policy when the client relationship is established. BDF shall also provide each such client with a new notice of the firm’s current privacy policies at least annually. If, at any time, BDF adopts material changes to its privacy policies, the firm shall provide each such client with a revised notice reflecting the new privacy policies.
Should you have any questions regarding the above, please contact:
As our Site is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Links to Third-Party Websites
As a convenience to you, BDF may provide hyperlinks to websites operated by third parties. When you select these hyperlinks, you will be leaving our Site.
BDF has no control over third party websites, their content, or security. Accordingly, when you access these third party websites it is at your own risk. We encourage you to read the associated privacy policies by such third party websites to learn more about their data privacy management practices. BDF may, in its sole discretion, block links to our Site without prior notice.
Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across Sites or online services.
We do not track users across time or over multiple websites, we do not receive, or respond to, browser do-not-track signals or other similar mechanisms. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
To learn more about setting up a Do Not Track signal, please visit https://allaboutdnt.com/.