Your privacy is important to us. This BasePoint Capital (referred to herein as “we,” “our” and “Basepoint”) Privacy Policy applies to our practices regarding the collection, use and disclosure of personal information that we collect via our website at www.basepointcapital.com (the “Website”) and our other interactions with you, including email, marketing communications, on-site visit to our offices, or other methods.
YOUR CONSENT
Please review this Policy periodically. You should read this entire Policy before submitting information, including personal information, to us in any form. Whenever you submit personal information to us, whether online or offline, you consent to the collection, use, and disclosure of that information in accordance with this Policy.
All personal information may be used for the purposes stated in this Policy. We may make full use of all information that is de-identified, aggregated, or otherwise not in a personally identifiable form.
This Privacy Policy is subject to our Terms of Use located at https://www.basepointcapital.com/terms-of-use/. We may update this Privacy Policy from time to time, as specified in the “Revisions to This Privacy Policy” section below.
INFORMATION WE COLLECT AND HOW WE USE IT
We collect personal information from you in the following ways: 1) from you when you voluntarily submit information directly to us; 2) using automated technology, including when you visit our Website, social media, or interact with our electronic advertisements or communications; 3) through financial affiliates and 4) using third party sources, including our service providers, through social media and other websites or services we interact with. Automated technology collects information from your computer or mobile device and includes cookies, web beacons, local shared objects, or other similar technology. More information is given below in the “Cookies and Other Technology” section below.
All personal information may be used for the purposes stated in this Policy. We may combine data collected from third party sources. See Annex 1 below for additional information.
Personal Information
We collect information voluntarily provided by our business-to-business contacts, including but not limited to name, email, phone number, and company name. We use this information to provide you with services you request, improve our service offering, and to communicate with you regarding your business.
If you opt in to text SMS/MMS communications, we collect records of those communications and related data as set forth below. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes.
Internet/Network Activity
We collect information from your computer or mobile device when you visit our website, including your domain and IP address, cookies and usage data, type of browser, operating system you use when you visit the website, and your online activities on our website. This information is used for internal analysis only in order to improve our website, monitor the performance of our servers, and administer the website.
Service-Related Information
We may collect personal information constituting nonpublic information (“NPI”), as defined under the Gramm-Leach Bliley Act and other applicable laws, about individual consumers that we receive from our clients and customers in connection with their engagement of our professional services, including personal identifiers such as names, addresses, email addresses, and financial information. Such information is governed by the privacy policies of the entity that collects the information directly from the individual. If NPI is provided to us in the course of our services to our clients, they will provide the initial notice and opt-out options to individual consumers pursuant to 12 C.F.R. § 1016.13(a). We will enter into an agreement with our clients consistent with our legal obligations and will use the NPI limited to the agreed-upon scope with our clients. We will not sell or share, or otherwise disclose this NPI for marketing purposes.
HOW WE DISCLOSE YOUR PERSONAL INFORMATION
For non-NPI information, we may disclose information we collect about you as follows:
- With consultants, service providers, and contractors that we use to support our business and operations (e.g., hosting or operating our Site, data collection, reporting, ad response measurement, Site metrics and analytics, data analysis, delivering marketing messages and advertisements, processing credit card payments, and providing fraud detection services) who have agreed to keep the information confidential and use it only to provide the applicable services. This includes recording all text SMS/MMS conversations and other interactions consistent with our obligations under, but not limited to, the Federal Trade Commission and the Security Exchange Commission.
- When we contemplate or enter into a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
- With an acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of BasePoint or its affiliates including any negotiation thereof.
For NPI information, we do not sell or share, or otherwise disclose the NPI beyond the agreed-upon scope of the agreement with our clients and customers. See Annex 1 below for additional information.
HOW WE USE “COOKIES AND OTHER TECHNOLOGY”
As you access or use our websites, we may collect information passively, by using technologies such as cookies, web beacons, pixels, and navigational and location data collection (clickstream, log files, server logs) for the purposes described in this Policy. Such automated technologies further help us to secure and keep track of your interactions with our website in order to personalize your web experience, including through offers, advertisements, language and location preferences. Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use. By disabling cookies, you won’t be able to enjoy the convenience provided by our customization.
To find more information about cookies please visit www.allaboutcookies.org.
LINKS AND THIRD PARTIES
Digital Advertising Alliance
You can also opt out from companies like Google, Instagram, Facebook and other participating companies through the Digital Advertising Alliance in the USA: http://www.aboutads.info/choices/. You can also opt out of participating companies from the Digital Advertising Alliance of Canada in Canada: http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe: http://www.youronlinechoices.eu/, or opt out using your mobile device settings.
This Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies on third party websites, which are covered by such third parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third party websites to learn about their privacy practices.
This Policy only addresses the use and disclosure of personal information we collect directly from our clients and website users. Other entities that may provide us with personal information, or websites that may be accessible through our website have their own privacy policies and data collection, use and disclosure practices. We urge you to review the privacy policy of any entity that collects information directly from you. We are not responsible for the policies or practices of third parties.
INTENDED AUDIENCE OF WEBSITE; COPPA COMPLIANCE
We are in compliance with the requirements of the Children’s Online Privacy Protection Act (“COPPA”). We do not knowingly collect information from minors in the United States or elsewhere with or without the consent of their parents or guardians. If you are not 18 or older, you should not visit or use our website or otherwise engage in our services. If you become aware that a child has provided us with personal information without appropriate consent, then please contact us using the details below so that we can take the appropriate steps in accordance with our legal obligations and this Policy.
RETENTION OF PERSONAL INFORMATION
We will retain your personal information (collected through offline and online methods) for as long as it is necessary for the purposes described in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.
CONTACT PREFERENCES AND UNSUBSCRIBING
BasePoint may want to communicate with you in a manner you find helpful. If you no longer wish to receive email marketing communications from us, you may unsubscribe from receiving marketing-related emails by using the unsubscribe method provided in our communications (e.g., by clicking on the “unsubscribe” link in the email to unsubscribe). Such communications may include information about services or promotions. Please note that unsubscribing from our promotional material will not prevent BasePoint from contacting you for other reasons, such as order confirmations, or responses to customer service inquiries.
SMS Terms and Conditions
Upon messaging opt-in, the end user agrees to receive messages from BasePoint Capital for the purposes of direct client communications regarding account notifications, meeting confirmations, and transaction related inquiries. Messages are strictly informational and only sent to clients who have an established relationship with the firm. End users can opt out by replying STOP or request more information by replying HELP. Message frequency varies. Message and data rates may apply.
REVISIONS TO THIS PRIVACY POLICY
We may revise this Privacy Policy at any time and from time to time without advance notice, by posting an updated and revised version of this Policy on the Website. We will provide you with notice of any material revisions by posting the new effective date or last edited date of the Privacy Policy. The revisions are effective immediately upon posting and we encourage you to check this Policy often so you are aware of the most current terms and conditions that apply to you. Your use of the website after such notice is provided indicates your consent to the revised terms.
GOVERNING LAW
This Policy and our privacy practices will be subject exclusively to the laws of the State of New York, United States of America. We make no representation that this Policy and its practices comply with the laws of any other jurisdiction.
CONTACTING US
If you have any questions or suggestions about our privacy policy or want to know more about information we have collected about you, please contact us at inquiry@basepointcapital.com.
CALIFORNIA RESIDENT BUSINESS-TO-BUSINESS CONTACTS ONLY: YOUR CALIFORNIA PRIVACY RIGHTS
This Privacy Rights Act Notice (“Notice”) provides additional information to our Business-to-Business contacts who are residents of California whose Personal Information is collected by us pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). If you are not a California resident, this Notice does not apply to you. Please visit our Privacy Policy (“Policy”) for more information. Any capitalized terms undefined in this Notice have the same definition as the Policy.
PERSONAL INFORMATION COLLECTED, DISCLOSED OR SOLD
Information Collected
Within the past 12 months, we have collected the categories of personal information about California consumers as described in Annex 1 to this Notice. To review these categories click Annex 1.
Business-to-Business (“B2B”) Information
If you are a contact person for our business clients, partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, you have certain rights under California law, as set forth in this Notice with respect to the information we collect from you in that role. We collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information and communications consistent with your role in facilitating that business relationship. We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship. We do not disclose that information outside our business relationship without your consent. For more details see Annex 1.
Information Sold or Shared
We have not sold or “shared” (as the term is defined by the CCPA) your personally identifiable information in the preceding 12 months. This does not include trusted third parties and service providers who assist us in operating our platforms, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect others’ rights, property, or safety.
For details regarding the categories of third parties to whom we have disclosed your personal information, please see Annex 1.
CPRA RIGHTS AND REQUESTS
Under the CPRA, you are entitled to certain rights, and you can make requests with regard to those rights as follows:
Right to Know about the Categories of Personal Information Collected (“Right to Know”)
Right to Request Deletion of Personal Information (“Right to Delete”)
Right to Correct or Rectify Inaccurate Information about you (“Right to Correct”)
HOW TO MAKE YOUR REQUESTS TO KNOW, DELETE, OR CORRECT.
You have the right make requests for the aforementioned rights (Request to Know; Request to Delete; or a Request to Correct (a “Request”)).
To make a Request for any of the information set forth above, please submit a verifiable consumer request pursuant to the instructions below. The Request must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold, shared, or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request. We will acknowledge your Request within 10 business days and will attempt to respond substantively within 45-90 days.
You may make a Request the following ways:
- You may make a request here: inquiry@basepointcapital.com.
Once we receive your Request, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identification.
We will review all information provided by you to us, to determine whether we can respond to your Request. We will inform you of our decision to deny or grant your Request.
For any Requests to Know, you may make such Requests twice within a 12-month period.
For Requests to Correct, you will need to provide evidence supporting the inaccuracy of the current information, and we reserve the right to delete the information instead of correcting if such deletion does not impact you or you consent to the deletion.
We will retain correspondence, documents and information related to any Request for 24 months as required by law.
ADDITIONAL CPRA RIGHTS
The following are additional rights afforded to you under the CPRA.
Right to Know Sensitive Personal Information Collected
We do not collect or process sensitive personal information for the purpose of inferring characteristics or for any purposes other than those set forth in Regulations section 7027(m).
Right to Opt out of Sharing and Selling
We have not sold or shared personal information in the preceding 12 months.
RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS
You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act, including by exercising the rights specified herein.
ADVERTISING OPT OUT
You can opt out of sharing your information with third-party companies engaged in targeted advertising including social networking sites such as Google and Facebook using the following tools:
- For Websites
- For Mobile Apps
GOOGLE OPT OUT
If you would like to opt out of Google Analytics and Ads, you can. If you are on the web, you can opt out of Google Analytics by installing Google’s Opt Out browser add on here, and you can opt out of interest-based Google ads using this link.
FACEBOOK AD PREFERENCES
To understand more about Facebook advertising and manage your preferences, please visit Facebook Ads. Login to Facebook and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app) for more information.
COOKIES
You can opt out of cookies using your browser.
Please Note:
- Opt-outs are device and browser based. You must opt out on each device and each browser where you want your choice to apply.
- Opt-outs maybe stored via cookies. If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.
- We may still share your information with our service providers that help us perform functions that are necessary for our business such as vendors that host our website, credit card processors, analytics processors. These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.
RIGHT TO ACCESS INFORMATION ABOUT AUTOMATED DECISION MAKING AND THE RIGHT TO OPT-OUT OF AUTOMATED DECISION MAKING
We do not engage in automated processing which includes using any system, software, or process—including one derived from machine-learning, statistics, or other data-processing or artificial intelligence—that processes personal information and uses computation as whole or part of a system to make or execute a decision or facilitate human decision making. For more information, please contact us at inquiry@basepointcapital.com.
RETENTION OF PERSONAL INFORMATION
We will retain your Personal Information for as long as it is necessary for the purposes set out in Annex 1 and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
AUTHORIZED AGENT INFORMATION
You may designate an authorized agent to make a request on your behalf under the California Consumer Privacy Act.
Authorized agents can make requests under the California Consumer Privacy Act by emailing us at email address: inquiry@basepointcapital.com. We will require authorized agents to provide proof of the consumer’s identity and proof of designation as an the authorized agent. We may also require that a consumer verify his or her own identity directly with us before we respond to an authorized agent’s request.
We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.
CHANGES TO THIS PRIVACY POLICY
This Policy may be revised from time to time for any reason. If this Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page. Be sure to check the Policy whenever you submit personal information to us.
CONTACTING US
If you have any questions or suggestions about our privacy policy or want to know more about information we have collected about you, please contact us at inquiry@basepointcapital.com.