Privacy Policy

Effective: March 15, 2022

This Privacy Policy applies to the information that Bellwether Asset Management, Inc. (“Bellwether”) collects from our current and potential business clients, including through our website, https://www.bellwetherco.com, applications, and our services (the “Site”).

We control the data we collect about current and potential business clients and we use, share, store, and otherwise process it as disclosed in this policy, unless otherwise specifically stated or agreed between us and you or the company for whom you work and on whose behalf you interact with us. When we collect or otherwise process information on behalf of our clients, we operate as a service provider and process data as directed by our clients. Any collection, use, sharing, and other processing of personal information on behalf of our clients is governed by our client’s privacy policy and practices.

Please also review our Terms of Use, which govern your use of the Site. By providing us with your information, you agree to the collection, use, disclosure or other processing of your information as described in this Privacy Policy or at the time you provide information. If you do not agree with this Privacy Policy and the Terms of Use, do not access or use the Site or provide personal information to us.

General Audience Site

The Site is for general audiences and is not intended for use by anyone younger than the age of 18. We do not knowingly collect personal information from individuals younger than age 18.

How We Collect Information

We may collect information from you directly, automatically when you visit the Site, and sometimes from third parties. Some of this information may be considered “personal information” under various applicable laws. We consider information that identifies you as a specific, identified individual (such as your name and email address) to be personal information. We will also treat additional information, including IP addresses and cookie identifiers, as “personal information” where required by applicable law. Note that we may de-identify personal information so that it is non-personal, such as aggregating or converting it to a code, sometimes using a function commonly known as “hash”. We will treat de-identified information as non-personal to the fullest extent allowed by applicable law.

Information You Provide to Us Directly

We may ask you to provide certain information to us directly, such as contact information (e.g. name, email address, and company name) and other information that you choose to provide. For example, you may provide information to us when you submit a message to us through the Site, such as your name, email address, and content of your message.

Information We Collect Automatically When You Access and Use the Site

We and our third party business partners (including any third party service providers or third party analytics or content or advertising providers) may use a variety of technologies, including cookies and web beacons, that automatically or passively collect information whenever you access or interact with the Site (“Usage Information”). Usage Information includes the hardware model, browser and operating system you are using, the URL or advertisement that referred you to our Site, any search terms you entered into a search engine that led you to our Site, the areas within our Site that you visited, and the time of day you visited our Site, your time zone, location information, and mobile network (if applicable), among other information. We may also automatically collect your IP address or other unique identifier for any computer, mobile phone, or other device used to access our Site.

The methods used to collect Usage Information may include the following:

• Cookies and Log Files. Cookies are small data files placed on a device when it is used to visit the Site or otherwise access our online content. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our web pages. We may use both session and persistent cookies (which remain on your computer after the browser has been closed). For more information about cookies and managing cookies visit www.allaboutcookies.org.
• Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.
• Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

In addition, we may use a variety of other technologies that collect Usage Information and similar information for security and fraud detection purposes and to enforce our intellectual property rights.

Information Third Parties Provide About You

We may receive information about you from third parties, such as your employer if you are accessing our Site or using our products or services on behalf of a company. If you are on another website and agree to receive information from us, that site may share information with us so that we may contact you. We may also supplement the information we collect with outside records from third parties, such as public databases, publicly available social media pages, joint marketing partners, and third parties who enhance the information we have about you in order to provide you with information, services or products you have requested, to tailor content, to offer you opportunities to purchase products or services that we believe may be of interest to you, and for other purposes.

Social Media Features

The Site may permit you to interact with a third party platform, for example, by including a button allowing you to link to a third party platform (such as LinkedIn) or interacting with you through your social media account (“Social Media Features”). When you access a third party platform through a button on our Site, both we and the third party may have access to certain information about you and your use of the Site and the third party platform, and these third party companies may collect information about your visit to our Site through the Social Media Features we have integrated into the Site. Note that through the Social Media Features, these third party companies may be able to collect certain information about your visits to the Site regardless of whether or not you affirmatively interact with the Social Media Features and whether or not you are logged into (or have) an account with the third party platform.

If you use Social Media Features, your interaction and personal information may be publicly disclosed on the Site and on the third party platform. If others give us access to their profile, page, or other content on a third party platform, we may also receive information about you if it is accessible through that content. Your use of Social Media Features is subject to our Terms of Use.

The information we collect in connection with Social Media Features is subject to this Privacy Policy; the information the third party platform collects is subject to the third party’s privacy practices (including whether the third party shares information with us, the types of information shared, and your choices about what is visible to others on the third-party platform).

How We Use Information

We may use information we collect, including personal information and Usage Information, to:

• Allow you to use the Site, such as to view the content offered through the Site;
• Enable you to use the products and services we offer, including verifying information you provide to us, including that your email address is active and valid;
• Administer and develop our business relationship with you and the company for which you work;
• Communicate with you, including to respond to any questions or comments submitted through the Site, to send you information about us and the Site and our products and services, including to send you marketing communications;
• Contact you with regard to your use of the Site or similar administrative communications, including, without limitation and in our discretion, changes to the Site’s policies;
• Tailor the content and advertising we display to you or others, on the Site or elsewhere;
• Consider an employment application you submit through the Site;
• For internal business purposes, such as to improve the Site or our products and services and comply with regulatory and legal obligations;
• Operate and protect the Site from errors and misuse of the Site, to detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, to detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies;
• As otherwise disclosed in this Privacy Policy, for other reasons that we disclose when you provide your information, or otherwise with your consent.

How We Share Information

Bellwether may share non-personal information that we collect, such as certain Usage Information, aggregate user statistics, and hashed or otherwise de-identified information (including email addresses), and/or our analyses derived from such information, with third parties in our discretion, including for targeted advertising purposes. We do not share your personal information with unaffiliated third parties for their own direct marketing purposes. We may share the information we have collected about you, including personal information, as disclosed at the time you provide us with information or with your consent, as described elsewhere in this Privacy Policy, and in the following circumstances:

Third Parties Providing Services on Our Behalf. We use third party businesses to perform services on our behalf, such as website hosting, conducting website usage analysis, sending email or other communications, or performing other services. We may provide access to your personal information to such third parties in order for them to perform these services.

Third Parties When You Direct Us to Share Information. We may share information when you direct us to do so. For example, you may be presented with an opportunity to receive marketing offers from a third party or you may interact with us through Social Media Features or other third party applications or features, through which information about you is shared. Please note that we are not responsible for the privacy practices of third parties. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.

Administrative and Legal Reasons. Bellwether may transfer and disclose information, including without limitation your personal information, Usage Information, including device identifiers, e.g. IP address, to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Use or other applicable Site policies; to respond to an emergency; or otherwise to protect our rights, property, safety, or security or that of other Site visitors or the public. We may also use device identifiers, e.g. IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies, in our discretion. Such disclosures may be carried out without notice to you.

Business Transfers. In the event that Bellwether goes through a transition such as being sold, having all or a portion of its assets acquired or transferred, whether voluntary or involuntary (such as through bankruptcy), or merging or becoming affiliated with any other division, individual or entity (including, without limitation, during the course of any due diligence process), any personal information owned or under the control of Bellwether will likely be one of the transferred assets. We reserve the right, as part of this type of transaction, to assign or otherwise transfer your information and other information we have collected from users of the Site and/or our products and services. By providing your personal information, you agree that we may transfer such information to the acquiring entity without your further consent.

Employment Applications. If you submit an employment application through the Careers page on the Site and voluntarily “self-identify” in certain ways (e.g., veteran status or gender), we may use your personal information to fulfill legal reporting requirements or to defend against employment-related claims. Please note that we may utilize a careers portal that is operated by a third party, in which case your use of the careers portal will be subject to the third party’s privacy practices as disclosed on the portal, and not to this policy.

Third Party Content and Analytics Providers and Similar Third Parties

We may use third party business partners, such as analytics companies, ad agencies, network advertisers, and others who provide us with information about the Site, users, and our advertisements, and who deliver ads to you on our behalf on our Site and elsewhere online. We and our third party business partners collect certain information about your visits to and activity on our Site and other websites and services, including through the Social Media Features, and may use this information to target advertising to you and others and to assess the effectiveness of our advertising. We may also share (or permit third parties to collect) certain information, such as Usage Information, aggregated or de-identified or hashed information (including email addresses), with these third parties for similar purposes.

These third parties may set and access their own tracking technologies on your device (including cookies, web beacons or other technology) and may otherwise collect or have access to your personal information over time, including about your visits to our Site as well as other websites and online services. Companies that we share information with, including ad agencies and networks, may use the information, often in combination with their existing information, in order to present more relevant advertisements that may be of interest to you, and to help us and third parties to do the same.

Your Advertising Choices. Some of these third parties may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. Both NAI and DAA provide information regarding procedures for opting-out of targeted online advertising from participating companies. For information from NAI about opting out, click here [visit the NAI opt-out page]. For information from DAA about opting out, click here[visit the DAA opt-out page]. Note that these are cookie-based opt-outs. If you disable your cookies or upgrade your browser after opting out, or if you use different computers or browsers, you will need to indicate your opt-out choices across those other computers and browsers.

For mobile applications, you may be able to limit certain advertising practices using the settings on your phone, tablet, or other mobile device. Also, on most mobile devices, you can install the DAA’s AppChoices app to make choices about cross-app interest-based advertisements from participating third parties. You may review additional information on opting out of mobile devices at www.networkadvertising.org/mobile-choice.

Please note that opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online.

We also use Google Analytics, which uses cookies and other technologies to collect and analyze information about use of the Site and provide other reports. This service may also collect information regarding your use of other websites, apps, and online resources. For information about opting out from Google, click here[visit Google's ad settings help page], and to download the Google Analytics opt-out browser add-on from Google, click here[download add-on].

“Do Not Track” Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser, except as specifically required by law. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.

International and Cross Border Transfers

Bellwether is a United States company. If you use our Site outside of the United States, by using the Site and/or providing us with information, you understand, acknowledge, and agree that we may collect, process, and store your personal information in the United States and other countries for the purposes described in this Privacy Policy. By providing your information, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States and other jurisdictions, where laws regarding processing of personal information may be less stringent than the laws in the country where you reside and/or are a citizen. Personal information processed or stored in another jurisdiction may be subject to access requests from governments, courts, or law enforcement in accordance with the laws of that jurisdiction.

Security

We use commercially reasonable security measures to protect against loss, misuse and alteration of your personal information under our control. However, no system can be 100% secure. While we strive to safeguard your personal information, we cannot guarantee or warrant the security of any information you disclose or transmit to us, or that we transmit to you, or guarantee that it will be free from unauthorized access by third parties. You use the Site and provide us with information at your own initiative and risk.

Changing Your Preferences and Access, Updating or Deleting Your Personal Information

You are responsible for maintaining the accuracy of the information you submit to us. You may update or correct the personal information you have provided by contacting us at Legal@bellwetheram.com. We will make good faith efforts to make requested changes in our active databases as soon as reasonably practicable. Please note that it is not always possible to make changes on our backup databases and residual data may remain on backup media or for other reasons.

If you receive marketing communications from Bellwether you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in the emails. Please note that we reserve the right to send you certain communications relating to your account or use of our Site or our services, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.

Third Party Links and Content

The Site may contain links to other web sites that Bellwether does not control, and other content hosted and served by third parties. The third parties whose content appears on the Site may collect information about you through the use of cookies and web beacons, may independently collect or solicit personal information, and may have the ability to track your use of their sites and services. Likewise, our content may be included on third parties’ web pages and web sites that are not associated with Bellwether and over which we have no control. We may collect Usage Information through Bellwether content appearing on third party sites.

This Privacy Policy does not apply to non-Bellwether websites that may link to the Site or be linked to or from the Site. Please review the privacy policies on those websites and applications directly to understand their privacy practices. Bellwether is not responsible for the privacy practices of any third party.

Changes to This Privacy Policy

To the extent permitted by applicable law, we reserve the right to change this Privacy Policy and will notify you of material changes by posting the revised Privacy Policy on our Site. In some cases, we may provide you with additional notice (such as by adding a statement to our homepage or by sending you a notification using contact information you have provided). Your continued use of our Site or continued interaction with us after the effective date of the revised Privacy Policy (or such other act as specified in the revised Privacy Policy) will, to the fullest extent permitted by applicable law, constitute your consent to those changes. However, we will provide notice and obtain your consent (opt-in or opt-out) if required by law.

Contact Us

If you have questions about this Privacy Policy, please contact us at Legal@bellwetheram.com.