BamSEC Privacy Policy

Introduction

BamSEC, LLC ("BamSEC", "us", "we", "our") provides an online platform to allow its users to more efficiently perform financial research when working with Securities and Exchange Commission (SEC) filings and earnings transcripts. BamSEC operates the bamsec.com website (the "Site").

This Privacy Policy is designed to help you understand how we collect, use, and share your personal information and to help you understand and exercise your privacy rights.

This Privacy Policy applies to personal information processed by us, including on our websites and other online or offline offerings. To make this Privacy Policy easier to read, our websites and other online or offline offerings are collectively called "Services." We are committed to the privacy of your information when you use the Services.

This Privacy Policy does not apply to any of the personal information that our customers may collect and process using the Services ("Customer Data"). Our customers' respective privacy policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy. Any questions or requests relating to Customer Data should be directed to our customer.

Information We Collect

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources, such as third-party services and organization, as described below.

a. Information you volunteer

When you register to use BamSEC we ask for information such as your name, email address, and credit card information, collectively (“Registration Information”).

We may also collect the e-mail addresses and/or other contact information of those who communicate with us.

We may collect personal information from individuals when we attend conferences, trade shows, and other events, or from those who may be interested in potential business opportunities with us.

b. Information we collect automatically from your usage

We may collect personal information automatically when you use our Services.

Our Site use cookies to work properly. These cookies store information such as your usage of our Services and your internet browser and device data for a period of time. For more information about our usage of cookies, please see the Cookies, Pixel Tags/Web Beacons, and Other Technologies section below.

We may collect certain information on user activity when you use our Services such as your internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.

Cookies, Pixel Tags/Web Beacons, and Other Technologies

We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies ("Technologies") to automatically collect information through your use of our Services.

Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience. We may use both session cookies and permanent cookies. You are required to re-login to BamSEC account after a certain period of time has elapsed to protect you against others accidentally accessing your account contents. Your web browser may allow you to modify your cookie preferences. Please note that cookies are required to use the BamSEC service.

A pixel tag, or web beacon, is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
  • Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
  • Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
  • Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

See "Your Privacy Choices and Rights" below to understand your choices regarding these Technologies.

  • Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:

We also use Stripe and the services it provides in order to process payments (Stripe's privacy policy can be found here).

c. Information we collect from other sources

We may obtain information about your form other sources, including through third-party services and organizations.

How We Use Information

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

Information we collect is used to fulfil our contract with you and provide you with our Services, including to:

  • manage your information and accounts;
  • provide access to functionalities and features of our Services;
  • communicate with you about your account, activities on our Services, and policy changes;
  • process financial information for products or Services; and
  • answer requests for customer or technical services.

Information we collect is also used administratively to:

  • pursue our legitimate interests, such as direct marketing, research and development, network and information security, and fraud prevention;
  • detect security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
  • measure interest and engagement in our Services;
  • improve, upgrade, or enhance our Services;
  • develop new products and Services;
  • ensure quality control and safety;
  • authenticate and verify individual identities, including requests to exercise your rights under this policy;
  • debug and repair errors with our Services;
  • perform audits relating to interactions, transactions, and other compliance activities;
  • enforce our agreements and policies; and
  • comply with our legal obligations.

We may use personal information to tailor and provide you with content and advertisement. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you include email campaigns, customer audiences advertising, and interest-based advertising.

We may also use your information for other purposes as requested by you as permitted by applicable law. For example, we may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

Also, we may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.

How we Share Information

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

The categories of third parties with whom we may share your information are described below.

  • Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
  • Business Partners. may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
  • Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as "interest-based advertising" or "personalized advertising."

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

Data Security and Storage Retention

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

International Data Transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information to countries outside the European Economic Area, Switzerland, and the United Kingdom, we will put in place appropriate safeguards to ensure that this transfer complies with the applicable laws and regulations. For more information about these safeguards, please contact us as set forth below.

Your Privacy Choices and Rights

The privacy choices you may have about your personal information are determined by applicable law and are described below.

  • Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy or to provide customer/technical support).
  • "Do Not Track." Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
  • Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

In accordance with applicable law, you may have the right to:

  • Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the "right of data portability");
  • Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
  • Request Deletion of your personal information;
  • Request Restriction of or Object to our processing of your personal information; and
  • Withdraw your Consent to our processing of your personal information.

If you wish to exercise any of these rights, please contact us as described in the below Contact section, and we will process such requests in accordance with applicable laws.

Supplemental Notice for California Residents

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 ("CCPA"). The CCPA provides California residents with the right to know what categories of personal information we have collected about them and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

Category of Personal Information Collected by us Category of Third Parties Information is Disclosed to for a Business Purpose
Identifiers
  • Advertising partners
  • Business Partners
  • Services providers
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Advertising partners
  • Business Partners
  • Services providers
Commercial information
  • Advertising partners
  • Business Partners
  • Services providers
Internet or other electronic network activity
  • Advertising partners
  • Business Partners
  • Services providers
Inferences drawn from other personal information to create a profile about a consumer
  • Advertising partners
  • Business Partners
  • Services providers

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in "Information We Collect" and "How We Use Your Information" above, respectively.

For purposes of the CCPA, we do not "sell" personal information, nor do we have actual knowledge of any "sale" of personal information of minors under 16 years of age.

Additional Privacy Rights for California Residents

  • Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
  • Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth in "Contact Us" below and provide written authorization signed by you and your designated agent.
  • Verification. To protect your privacy, we will take steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in "Contact Us" below. We will process such requests in accordance with applicable laws.

Supplemental Notice for Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us as set forth in “Contact Us” below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.

Children's Information

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in "Contact Us" below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account if applicable.

Other Important Provisions

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

Contact Us

BamSEC is the controller for the personal information we process, unless otherwise stated.

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

BamSEC, LLC
200 N LaSalle #1100
Chicago, IL 60601

Last Updated: December 7, 2021