June 30, 2022

CALIFORNIA PRIVACY NOTICE

Pursuant to the California Consumer Privacy Act of 2018, and California Privacy Rights Act (collectively, the “CCPA”), Boston Financial Investment Management, LP (“BFIM,” “we,” or “us”) are providing the following details regarding the categories of Personal Information that we collect, use, and disclose about California residents.

Collection and Disclosure of Personal Information

The following chart details which categories of Personal Information we collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business purposes, including within the 12 months preceding the date this Privacy Policy was last updated.   

Categories of Personal Information	Disclosed to Which Categories of Third Parties for Operational Business Purposes
Identifiers, such as name, contact information, Social Security Number, IP address that can reasonably be linked or associated with a particular consumer or household, and online identifiers.	affiliates; service providers; business partners; legal authorities
Personal information as defined in the California customer records law, such as name, employment information, bank account information, signature, address, and telephone number.	affiliates; service providers; business partners; legal authorities
Internet or network activity information, such as browsing history, search history and interactions with our online properties or ads.	affiliates; service providers; legal authorities
Professional or employment-related information, such as work history, position in company, and prior employer.	affiliates; service providers; business partners; legal authorities
Characteristics of protected classifications under California or federal law, such as sex, age, race, gender, disability, national origin, medical conditions and information, citizenship, primary language, and immigration status.	affiliates; service providers; business partners; legal authorities
Biometric information, such as fingerprints, subject to applicable law.	affiliates; service providers; legal authorities
Geolocation data, such as approximate location of devices used to access our website or online application portal, derived from IP address.	affiliates; service providers; legal authorities
Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.	affiliates; service providers; legal authorities
Sensitive Personal Information Personal Information that reveals an individual’s Social Security, driver’s license, state identification card, or passport number; racial or ethnic origin, religious or philosophical beliefs, citizenship, immigration status;Biometric information processed for purposes of uniquely identifying an individual; Personal Information collected and analyzed concerning an individual’s health;Personal Information collected and analyzed concerning an individual’s sex life or sexual orientation.	affiliates; service providers; legal authorities

We do not “sell” and have not “sold” Personal Information (including Sensitive Personal Information), and we do not “share” or otherwise process Personal Information (including Sensitive Personal Information) for purposes of cross-context behavioral advertising, as defined under the CCPA.  We have not engaged in such activities in the 12 months preceding the date this Privacy Policy was last updated.  Without limiting the forgoing, we do not “sell” or “share” Personal Information (including Sensitive Personal Information) of individuals under the age of 16.

Purposes for the Collection, Processing, and Disclosure of Personal Information

We collect, process, and disclose Personal Information to operate, manage, and maintain our business, and to provide products and services, including to:

• Provide the functionality of the Services and fulfilling your requests.
• To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related benefits, or customer service.
• To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints via the Services.
• To complete your transactions, verify your information, and provide you with related benefits, or customer service.
• To send administrative information to you, such as changes to our terms, conditions, and policies.
• To allow you to send messages to another person through the Services if you choose to do so.

• Provide you with our newsletter and/or other marketing materials and facilitating social sharing.
• To send you marketing-related emails, with information about our Services, and other news about our company.
• To facilitate social sharing functionality that you choose to use.

• Analyze Personal Information for business reporting and provide personalized services.
• To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so that we can improve our Services.
• To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
• To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

• Aggregate and/or anonymize Personal Information.
• We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information.  We do so to generate other data for our use, which we may use and disclose for any purpose, since it no longer identifies you or any other individual.

• Accomplish our business purposes.
• For data analysis, for example, to improve the efficiency of our Services;
• For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
• For risk management, fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
• For detecting and preventing misuse of the Services;
• For developing new products and services;
• For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
• For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
• For determining the effectiveness of our promotional campaigns, in order that we can adapt our campaigns to the needs and interests of our users; and
• For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users in order that we can focus our energies on meeting our users’ interests. 

We may also process your Personal Information or disclose it to a third party in the event of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). 

In addition, we use Personal Information collected about our job applicants for sourcing and recruiting talent, including to manage the applicant selection process, conduct reference checks, and analyze the diversity of job applicants, in accordance with applicable law.

Collection, Processing, and Disclosure of Sensitive Personal Information

Subject to your consent where required by applicable law, we collect, process, and disclose Sensitive Personal Information for purposes permitted under applicable law, including for purposes of:  providing goods or services, as requested; ensuring safety, security, and integrity; countering wrongful or unlawful actions, short term transient use such as displaying first party, non-personalized advertising; performing services for our business, including maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of our business; activities relating to quality and safety control or product improvement; and other collection and processing that is not for the purpose of inferring characteristics about an individual. 

California Retention Period

We retain Personal Information (including Sensitive Personal Information) for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include: 

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations). 

SEE OUR PRIVACY POLICY at the footer of https://www.bfim.com/

Sources of Personal Information

We collect this Personal Information from you, through the services, and from other sources, such as publicly available databases; affiliated entities; and third-party service providers.

Individual Rights and Requests

Requests to Know, Correct, and Delete

If you are a California resident, you may make the following requests:

• “Request to Know”

You may request that we disclose to you the following information:

• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
  • The specific pieces of Personal Information we collected about you;
  • The business or commercial purpose for collecting (if applicable)Personal Information about you; and
  • The categories of Personal Information about you that we disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable).
• “Request to Correct” 

You may request to correct inaccuracies in your Personal Information.

• “Request to Delete”

You may request that we delete Personal Information we collected from you.

To make a Request to Know or a Request to Delete, please contact us at dataprivacy@bfim.com, 646-569-2300 or toll free at 1-833-358-2395 or in accordance with the “Contacting Us” section above.  We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request.  We may need to request additional Personal Information from you, such as email address, in order to verify a request, verify your identity and protect against fraudulent requests.  You may make a request on behalf of a child who is under 13 years old if you are the child’s parent or legal guardian.  If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.

If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section entitled “Individual Requests.”  Not all kinds of requests can be made by authorized agents in all states. As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.

Right to Non-Discrimination

You have the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA. 

De-Identified Information

Where we maintain or use de-identified data, we will continue to maintain and use the de-identified data only in a de-identified fashion and will not attempt to re-identify the data.

Changes to this California Privacy Notice

We may change or update this California Privacy Notice from time to time.   When we do, we will post the revised Privacy Policy on this page with a new “Last Updated” date.

Contact Us

If you have any questions regarding this California Privacy Notice or our privacy practices, please contact us at dataprivacy@bfim.com.