Effective June 30, 2017
Updates to this Policy
Collection of Your Information
We collect information from 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 the websites you accessed immediately before and after your visit to the Sites.
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 Website 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 may share Your Information with affiliated entities within the Black Creek Group. We may also share Your Information with certain unaffiliated third parties in some circumstances, including the following:
- Vendors and Suppliers. We may share Your Information with unaffiliated vendors, suppliers, authorized representatives, service providers, and agents so that they may help us to maintain the Sites, store Your Information, fulfill your requests, or otherwise provide services or support Black Creek’s business.
- Government Agencies / Law Enforcement. In certain circumstances, Black Creek might be called upon to release Your Information in response to a court order, subpoena, search warrant, law, or regulation. Black Creek plans to cooperate in responding to such requests, taking appropriate measures to ensure that the requesting party understands the sensitive nature of Your Information that they may receive. Black Creek also reserves the right to disclose Your Information in the event that we have reason to believe that someone is causing or threatening to cause injury to or interference with our rights or property, the rights or property of others, the operation of the Sites, any user of the Sites, or anyone else that could be harmed by such activities or if someone is otherwise engaging in behavior that is otherwise illegal or harmful to others.
We may also share aggregated anonymous data concerning our users with third party analytic services, business partners, and others interested in how the Websites are used. We do not share Your Information with unrelated third parties for their own direct marketing purposes.
We use reasonable efforts 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 our 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). We are not responsible for deleting information about you from the databases of any third parties.
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.
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