Privacy Policy
Investment advisers are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. Federal law gives the customer the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information.
TYPES OF NONPUBLIC PERSONAL INFORMATION (NPI) WE COLLECT
PARTIES TO WHOM WE DISCLOSE INFORMATION
All Investment Advisers may need to share personal information to run their everyday business. In the section below, we list the reasons that we may share your personal information:
- For everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus;
- For our marketing – to offer our products and services to you;
- For joint marketing with other financial companies;
- For our affiliates’ everyday business purposes – information about your transactions and experiences and information about your creditworthiness; or
- For non-affiliates to market to you.
If you are a new customer we may begin sharing your information on the day you sign our agreement. When you are no longer our customer, we may continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.
PROTECTING CONFIDENTIALITY OF CURRENT AND FORMER CLIENT’S INFORMATION
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law, including computer safeguards and secured files and building.
FEDERAL LAW GIVES YOU THE RIGHT TO LIMIT SHARING – OPTING OUT
Federal law allows you the right to limit the sharing of your NPI by “opting-out” of the following: sharing for affiliates’ everyday business purposes – information about your creditworthiness; or sharing with affiliates or non-affiliates who use your information to market to you. State laws and individual companies may give you additional rights to limit sharing. Please notify us immediately if you choose to opt out of these types of sharing.
DEFINITIONS
Affiliates – companies related by common ownership or control. They can be financial and non-financial companies; Non-affiliates – companies not related by common ownership or control. They can be financial and non-financial companies; Joint marketing – a formal agreement between non-affiliated financial companies that together market financial products or services to you.
Please call if you have any questions. Your privacy, our professional ethics, and the ability to provide you with quality financial services are very important to us.
website privacy
The rest of this Privacy Policy describes how your personal information is collected, used, and shared when you visit https://brcm.co (the “Site”).
PERSONAL INFORMATION WE COLLECT
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
We collect Device Information using the following technologies:
– “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
– “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
– “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
Additionally when you reach out via our contact form through the Site, we collect certain information from you, including your name, email address, phone number and message. We refer to this information as “Form Information.”
When we talk about “Personal Information” within the web privacy subsection in this Privacy Policy, we are talking both about Device Information and form Information.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the Form Information that we collect generally to make direct contact with you. Additionally, we use this Form Information, when in line with the preferences you have shared with us, to provide you with information or advertising relating to our products or services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Google Analytics to help us understand how our customers use the Site–you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
Behavioral Advertising
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
FACEBOOK – https://www.facebook.com/settings/?tab=ads
GOOGLE – https://www.google.com/settings/ads/anonymous
BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
Do Not Track
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
Your Rights
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
Additionally, if you are a European resident please note that your information will be transferred outside of Europe, including to Canada and the United States.
Data Retention
When you contact us through the Site, we will maintain your Form Information for our records unless and until you ask us to delete this information.
Changes
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.
Contact Us
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at info@brcm.co.
Last Updated: January 9, 2024
