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Updates to this Policy
Collection of Your Information
We collect information from or about you (“Your Information”) when you voluntarily provide it to us through the Sites, as well as automatically through your visits to the Sites. The information that is collected may include: first and last name, email address, telephone number, mailing address, login credentials, password, a response to a security question, whether you are a financial advisor or a broker/dealer, the name of your financial advisory firm (if applicable), your computer’s IP address, the Internet browser and operating system you are using, what pages you visit within our Sites, the length of time spent browsing pages of the Sites, and whether you accessed the Sites from a hyperlink in our email messages.
You may voluntarily provide Your Information through the Sites in a number of ways, including: (a) when you login to your account or make updates to your account information; (b) when you fill out a form on the Sites; and (c) when you contact us to request information from us.
As noted, the Sites also automatically gather Your Information related to your use of the Sites. We may use “cookies” (small text files placed in the memory of your device) or similar technologies to retain information about you and your use of the Sites, and we may engage third parties to assist us in the collection of Your Information. These technologies can automatically collect information relating to the hardware and software you use to visit the Sites and what pages you have visited. We may tie Your Information that is automatically gathered by the Sites to Your Information that we collect from other sources or that you provide to us. We may use Your Information that has been automatically gathered to help authenticate you, store and recognize your configuration and user attributes, facilitate navigation of the Sites, and customize information made available on the Sites to you. You are free to decline our cookies if your browser permits you to disable them, but if you do, some portions of the Sites may not operate property.
Use of Your Information
Sharing of Your Information
We do not share Your Information with unaffiliated third parties for their own direct marketing purposes.
We use reasonable efforts designed to maintain physical, electronic, and procedural safeguards to protect the confidentiality and integrity of Your Information. However, no security system is foolproof and we cannot fully eliminate security risks with respect to Your Information. We recommend that you do not send us any of Your Information via non-secure methods of correspondence, including via public electronic communication channels, such as Internet e-mail, which are generally not secure.
Other Sites or Services
Do Not Track
Because there is not yet a consensus on how companies should respond to browser-based do-not-track settings, the Sites do not currently respond to any browser-based do-not-track settings. However, we do not track you across unaffiliated third party websites to provide targeted advertising or for other purposes.
You may opt out of receiving promotional emails from us by updating your preferences in your account settings or by following instructions provided in the emails. Even if you request to opt out of receiving promotional emails from us, we may use your contact information to send you other types of emails.
For email updates from NASDAQ, you may opt out of receiving these email updates by following instructions provided in the emails or by updating your preferences on the page where you signed up for the email updates, which sends your request directly to NASDAQ. Because NASDAQ, and not Black Creek, is responsible for sending these emails, you must contact NASDAQ to opt out of receiving these emails.
Updating or Deleting Your Information
You generally may update Your Information that is in your account with us by following the procedures described on those portions of the Sites where you may log in to the account. In some cases, however, you may need to contact us by phone to update Your Information.
We will use commercially reasonable efforts to fulfill your request in a timely manner. We may keep a record of all information that is deleted, and we may determine what may be deleted. For example, if we are required to keep certain information for regulatory purposes, we may be prevented from deleting that information. Further, even if we delete Your Information from our “live” database, it may still be stored on other databases (including those kept for archival purposes).
Additional Information Regarding California
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information about California residents that we have collected or disclosed within the preceding 12 months:
We collect this Personal Information from you and from other categories of sources: entities with which we do business that have a relationship with you, and transfer agents.
We share this Personal Information with our affiliates, our service providers and transfer agents, and entities with which we do business that have a relationship with you and other business partners.
We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.
If you are a California resident, you may request that we:
To make a request for the disclosures or deletion described above, please contact us at this toll-free number 1-833-334-4996 or email us at [email protected]. In some instances, we may decline to honor your request where the law does not apply or where an exception applies. We will respond to your request consistent with applicable law. Nonetheless, you have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
Nevada Residents as Covered by Nevada Privacy Law
Black Creek does not sell Covered Information as defined under Nevada law. If you would like to make a further inquiry regarding the selling of your Covered Information, as defined under Nevada law, please contact [email protected].
Privacy of Children
The Sites are not directed at minors and we do not knowingly collect information from, or maintain any information regarding, persons under the age of 18.